EICC Validated Audit Process (VAP) VAP Operations Manual
Revision 4.0.1 – May 2012
Information and Communication Technology companies (working through the Electronics Industry
Citizenship Coalition (EICC) www.eicc.info is working to improve sustainability and social responsibility within the global supply chain.
These companies recognize a mutual responsibility to ensure working conditions in the Information and Communication Technology (ICT) industry are safe, workers are treated with respect and dignity, and that manufacturing practices are environmentally responsible. The Validated Audit Process (VAP) is a collaborative approach to Auditing, to reduce the burden on supply chain companies from multiple requests for social Audits. The VAP meets the need for a high quality, consistent and cost-‐effective standard industry assessment for labor, ethics, health, safety and environmental practices based on
the EICC code of conduct, laws, and regulations.
For more information about the VAP, please contact:
• Audits@vectra-‐intl.com • EICC Address: 1155 15TH ST NW SUITE 500 WASHINGTON, DC 20005 USA • EICC Website: http://www.eicc.info
14. Management System Introduction .......................................................................... 167 14.1 Purpose ...................................................................................................................... 167
14.2 Introduction to the Management System ...................................................................... 167
14.3 Understanding the EICC Management System Requirements .......................................... 168
14.4 Making the System Work ............................................................................................. 170
15. Small and Medium Sized Enterprises .......................................................................... 172 15.1. Introduction: ............................................................................................................... 172
15.2. Small and medium sized enterprise cultures: ................................................................. 172
15.3. Management systems in small and medium sized enterprises ......................................... 173
16.5 Evaluation of Conformance: ......................................................................................... 180
17. Conflict of Interest Policy .......................................................................................... 182 18. Waivers of Applicable Law ......................................................................................... 183
19.2 Observer Role ............................................................................................................. 184
19.3 Specific guidance for the VAP Audit Observer: ............................................................... 185
20. EICC Code Good Practices Implementation examples .................................................. 186 G. GENERAL CODE ............................................................................................................... 186
D. LABOR ......................................................................................................................... 186
F. HEALTH & SAFETY ......................................................................................................... 196
G. ENVIRONMENT ............................................................................................................. 203
D. ETHICS ........................................................................................................................... 207
E. MANAGEMENT SYSTEM .................................................................................................... 213
24.1 Off-‐Limits Portions of Facilities ..................................................................................... 229
24.2 Handling Sensitive Information ..................................................................................... 229
25 Workers’ accommodation: processes and standards ................................................... 231 25.1 A process approach ..................................................................................................... 231
25.2 PLANNING AND ASSESSING REQUIREMENTS FOR WORKERS’ ACCOMMODATION ............. 231
25.3 STANDARDS OF WORKERS’ ACCOMMODATION. ............................................................ 233
This Audit Operations Manual describes how EICC Validated Audits will be conducted and how the VAP program will be managed.
The manual is prepared in modules to facilitate providing users with the sections relevant to them.
The purpose of the manual is to:
• Communicate the objectives, scope, process and interpretive guidance for the EICC VAP (Validated Audit Program) to individuals responsible for assuring that Audits are conducted and that findings are appropriately addressed. This includes:
▬ Auditors (internal and third party),
▬ Customer staff responsible for supplier Auditing,
▬ Supplier relationship managers, and
▬ Auditee management staff • Ensure that appropriate notification is provided to Auditee’s scheduled for Audits; • Provide a consistent approach to the Audits; and
• Provide a basis for regularly evaluating and improving the program and Auditors against established performance criteria.
2. Audit Scope and Objectives
EICC Validated Audits are a joint and collaborative effort between the Auditors and the Auditees (supplier partners of participating Information and Communications Technology [ICT] companies). The goal of the Validated Audit Program is to foster improvement in Corporate Responsibility performance and build capability within the ICT sector supply base. The primary objective of each Audit is to evaluate an Auditee’s labor, ethics, occupational health and safety, environmental practices, and supporting management systems relative to the criteria set out in the EICC Audit Protocol and in applicable laws and regulations.
The VAP is based on the principles established by ISO 19011:2002, “Guidelines for Quality and/or Environmental Management Systems Auditing.” This international standard provides clear guidance on: the principles of management systems Auditing, the management of Audit programs, the conduct of internal or external Audits, and the competence and evaluation of Auditors. Although it was developed specifically for Audits of quality and environmental management systems, its major elements are equally suited to Audits that include social systems and business ethics.
Recognizing that the scope and objectives of VAP Audits extend well beyond environmental management systems, the EICC have enhanced the guidance provided by ISO 19011 to enable VAP Audits to produce in depth evaluations of the social, ethical, occupational health & safety and environmental performance of ICT suppliers as measured against the VAP Audit criteria (largely based on the EICC Code of Conduct).
The Validated Audit (VA) is part of an overall Supplier Engagement Model -‐ the process of assessing and improving labor, health and safety, environmental, and ethical practices in the ICT supply chain. It is an Audit performed by EICC VAP Auditors (see section 4.4), using the EICC Audit process and Protocols, and undergoing formal quality review by the EICC APM.
The IRCA EICC Auditor Certification process is founded on ISO 19001, Section 7, “Competence and Evaluation of Auditors” and on the Standards for the Knowledge and Skills of Social Auditors, sponsored by the US Department of State's Office of International Labor Affairs and Corporate Social Responsibility
This is a summary of the EICC Supplier Engagement Model:
The purpose of the Validated Audit is to:
• Reinforce the CR expectations of EICC with suppliers and ensure suppliers are working toward conformance;
• Verify the information in the Auditee’s most recent self-‐assessment and evaluate their conformance with the EICC Audit criteria,
• Identify opportunities for improvement in Auditee CR practices, performance and management systems; • Provide individual EICC member companies with objective information to determine whether or not CR
expectations are being met at Auditee facilities and if there are any Priority violations; and • Enable individual EICC member companies and suppliers to focus efforts where the maximum positive
difference can be made.
3. Service Level and Quality Statement for Validated Audit Process (VAP)
The EICC is committed to the improvement of conditions throughout the supply chains of its members. A key component of this commitment is a high quality Validated Audit Process (VAP).
EICC have established the following levels of service and quality for VAP Audits:
• An experienced and qualified third-‐party global Audit Program Manager (APM) with local representatives will provide overall program management
• The program will utilize leading practices from different industry sectors
• Audits will be performed by individually selected and qualified Auditors from reputable and screened Audit firms
• Standardized EICC Audit Protocols and templates will be used across the process to ensure quality and consistency
• The APM will provide ongoing guidance to Auditors and Auditees on the Audit process and the EICC Audit criteria
• A helpdesk will be available to all participants for questions, clarifications and explanation of the process, the Audit criteria, and Audit results
• The Audit report will be reviewed by two qualified and experienced members of the VAP APM using the following quality criteria: completeness; anonymization (no identifiable product or Buyer information will remain in the report), triangulation of findings (though not all data points might be reported), accuracy of findings versus Audit notes, conclusions and identification to EICC Code provision, correct spelling and grammar; proper use of Audit Protocol ratings (Major, Minor, etc.); proper interpretation of Audit criteria; consistency of findings across criteria; and adequate documented proof to substantiate findings (photos, copies of relevant documents, ...).
• Feedback on the Audit process and Auditors will be taken and analyzed after each Audit and used to improve the performance of each Audit firm and Auditor, and to adjust the process (if needed)
• The APM will provide the Audit Buyer, Auditee and Audit firm with Audit contracting, scheduling and performance updates on a weekly basis.
• A complaint mechanism is in place to address concerns about the performance of the Audit firms and the VAP APM
• Guidance is available to help Audit buyers manage Auditee corrective action plans (CAPs) and follow-‐up
• Audit buyers have the option to work through the APM to manage in collaboration with the Auditee its CAP and follow-‐up
• Audit results will be reported to the Auditee and Audit Buyer (for their selected Audits) and an annual aggregate report will be prepared for the EICC (for the industry)
• The VA Process has been reviewed by legal counsel and is in line with US anti-‐trust and EU anti competition regulation
4. Roles and Responsibilities
This section provides a general overview of the roles and responsibilities of the different parties involved with the EICC Validated Audit Program.
4.1 Validated Audit Program Manager The Validated Audit Program Manager (APM) is responsible for coordinating the EICC Validated Audit Program. These responsibilities include:
• Adhering to APM responsibilities defined in the Non-‐Technical Services Agreement (NTSA) and associated Statement of Work between the APM and the EICC.
• Managing contracts with Audit Firms on behalf of the EICC. • Assigning Audits to Audit Firms, including establishing the Audit scope, duration and team size.
• Directing the Audited facility to the “Audit Preparation for Suppliers” document and other information, as necessary, to prepare for the Audit.
• Providing Audit Firms with completed Facility Profiles, Self-‐Assessment Questionnaires (SAQs) and other relevant documents needed to facilitate Audit planning
• Reviewing draft Validated Audit Reports to ensure quality and consistency with EICC criteria and coordinating report finalization with Auditors and Audited facilities.
• Obtaining feedback comments from Auditee management; incorporating in the report and distributing the report to the Auditee and their customers approved by the facility to receive the report.
• Promptly highlighting “Priority” Nonconformances identified during the Audit to customers identified by the Auditee.
• Metrics reporting to EICC and relevant EICC working groups
4.2 Lead Auditor Lead Auditors are responsible for ensuring that the facility Audit is conducted in accordance with the Audit process, guidelines, Protocols, and quality expectations defined in this Manual. They are also responsible for soliciting suggestions for improving the overall Validated Audit Program from Audit team members and for submitting suggestions and recommendations to the APM.
The APM must approve lead Auditors.
Other specific responsibilities include:
4.2.1 Audit Preparation
• Request key documents from Auditee as listed in the “Audit Preparation for Auditees’ document.
• Review the Auditee’s Facility Profile, Self Assessment Questionnaire (SAQ), submitted records and other documentation, previous Audit reports and Corrective Action Plans.
• Distribute relevant information to each Audit team member for review.
• Form and manage the Audit team
• Establish the Audit agenda.
• Request the presence of an Auditee management representative during the Audit process, where appropriate. Management representatives must not be present during worker interviews – either individual or group.
• Coordinate the participation of an Audit observer from one of the Auditee-‐approved customers.
4.2.2 Audit Execution
• Lead the opening and closing meetings.
• Manage the Audit process while at the site.
• Conduct the Audit using this Manual and the EICC Audit Report Protocol.
• Escalate any “Priority” Nonconformances immediately to the Auditee and APM for communication and resolution.
• Notify the APM of issues affecting the ability of the Audit team to perform the Audit (e.g. lack of cooperation of facility management; inability to hold confidential interviews; extensive records falsification, ....)
4.2.3 Post-‐Audit
• Obtain information from the other Audit team members, as necessary, to complete the draft Audit report.
• Complete and submit the draft Validated Audit Report (VAR) within two (2) weeks after the Audit to the APM.
– Make changes to the draft VAR as directed by the APM
– Resolve VAR disagreements with the Audited facility (to the extent feasible)
• Provide the final draft VAR to the APM for distribution to the Audited facility and customers authorized by the Auditee.
• Provide the APM with copies of the Audit field notes, collected documents and photographs (if any) from each of the Audit team members.
• Upon completion of the final draft VAR; invoice the APM for the agreed-‐upon professional Audit service fee and travel expenses.
4.3 Audit Team Members
Auditors are responsible for ensuring that they conduct the site Audit in accordance with the Audit processes, guidelines, Protocols, and quality expectations outlined in this manual. They are also responsible for providing suggestions for improving the overall Audit program directly to the Lead Auditor. Auditor responsibilities include:
• Be familiar with the contents of this Manual.
• Review assigned sections of the EICC Audit Protocol and other documentation provided by the Lead Auditor.
• Review and be familiar with applicable national, regional and local regulatory requirements.
• Participate in the opening, closing and daily wrap-‐up meetings.
• Conduct Audits for the assigned Audit criteria focus areas.
• Prepare findings, including complete descriptions of supporting evidence, for all assigned Audit criteria questions, using the EICC Audit Protocol.
• Escalate any “Priority” Nonconformances immediately to the Lead Auditor for discussion with the facility.
• Provide the Lead Auditor with copies of all field notes and copies of evidence (documents, photos, ....) upon completion of the Audit report.
4.4 EICC VAP Auditors
EICC only allows EICC VAP Auditors, this means “EICC-‐IRCA Certified” or “VAP Qualified” Auditors to perform Audits recognized by EICC.
4.4.1 EICC-‐IRCA certification:
EICC has designed a specific course delivered by a professional and qualified service provider in preparation for the EICC-‐IRCA certification. IRCA (International Register of Certified Auditors) provides certification to those Auditors who have successfully completed the EICC Auditor course and have successfully applied to IRCA for their certification. For more general information on IRCA please visit www.irca.org
4.4.1.1. EICC Auditor Certification Grades: The EICC-‐IRCA Labor and Ethics Auditor Certification Program offers three grades (Provisional Auditor, Auditor and Lead Auditor). The table below outlines the combination of these grades and scopes.
4.4.1.2. Initial Certification: IRCA will evaluate the Auditor’s application based on the Auditor’s demonstration of the competencies needed for effective Audit of the EICC Audit Criteria. Competences Generic Auditing Competences: • Auditing principles, procedures and techniques that enable the Auditor to apply these as
appropriate to different Audits and ensure that the Auditor conducts Audits in a consistent and systematic manner
• Relevant reference documents that enables the Auditor to define the scope of an Audit and apply Audit criteria
• Organizational situations that enables the Auditor to comprehend an organization’s operational and industry context
• Applicable laws, regulations and other requirements relevant to the discipline that enables the Auditor to work within, and be aware of the requirements that applies to the organization being audited.
·∙ EICC Auditing Competences As an EICC-‐IRCA certified Labor and Ethics Auditor the Auditor has an understanding of: • Internationally accepted human rights norms, laws and regulations relating to labor and
ethics issues • Relevant industry codes of practice, legal requirements, guidelines and standards
relating to labor, ethics, health & safety and environmental issues • Relevant international, national and local judicial systems and legislative frameworks • Relevant social responsibility & labor culture, trade unions, NGOs (Non-‐Governmental
Organizations) and other interested parties within the country or area of operation. ·∙
As an EICC-‐IRCA certified Labor and Ethics Auditor the Auditor has the ability to: • Plan, conduct and report an EICC Audit • Lead an Audit team and manage the Audit process • Communicate responsibly and clearly, orally and in writing with personnel at all levels of
an organization, including workers
• Apply methods and techniques to gather and evaluate objective evidence (including payroll) and determine the conformance of a system designed to meet the EICC requirements.
• Generate accurate, appropriate and responsible Audit findings and conclusions • Uphold the principles of proper ethical conduct, fair presentation and due professional
care. ·∙
The scope of EICC-‐IRCA Certification is specific to the electronics industry and therefore requires industry sector specific competences.
4.4.1.3. Work Experience & Qualifications For all grades: The Auditor must have at least 5 years of general work experience. We consider relevant general work experience to be a technical, managerial or professional position where the Auditor is required to exercise judgment, solve problems and communicate with other managers, employees, customers and stakeholders. The Auditor must also have completed either:
• 2 years work experience (which may be included as part of the 4 or 5 years total work experience) in a job that involved the Auditor directly labor and ethics issues and demonstrates the Auditor’s understanding of relevant legislation, or
• Acceptable qualification(s) is in a closely related field (for example, Human Resources Management), which demonstrates an understanding of labor and ethics issues and relevant legislation.
4.4.1.4. Auditor Training For the Labor and Ethics scope: The Auditor must have successfully completed the IRCA certified EICC Labor & Ethics Lead Auditor course
4.4.1.5. Auditing Experience IRCA will only accept Audits that are based on the EICC Audit Criteria and have been performed in accordance with the EICC VAP Operations Manual. IRCA must be able to verify all Audit experience the Auditor submits in your log sheets. The Auditor must make sure to include detailed information of the Audits the Auditor has performed and provide sufficient contact details so that IRCA is able to perform the verification. For EICC-‐IRCA Provisional Auditor grade: No Auditing experience is required for Certification to this grade.
For EICC-‐IRCA Auditor grade: The Auditor needs to have performed at least 4 EICC Audits to the complete EICC Audit criteria within the EICC scope. Auditing activity must include document review, preparation and performance of on-‐site Audit activities and Audit reporting. The duration of these Audits must not be less than 20 days, 10 days of which must have been acquired on-‐site. IRCA will only accept Audits performed during the previous 3 year period (IRCA defines ‘previous period’ as being that period immediately prior to the date IRCA receives the
Auditor completed application), and after successful completion of the relevant acceptable Auditor training course(s). Although IRCA recommends the Auditor should complete all of the Audits under the direction and guidance of an Auditor competent as a team leader (currently certified as a EICC-‐IRCA Lead Auditor or who has equivalent competence), IRCA acknowledges that for many Auditors this will be very difficult and costly to arrange. Consequently, IRCA will accept a minimum of 1 Audit under these conditions. IRCA may require this team leader to attest to the Auditor competence to Audit as a team member. For EICC-‐IRCA Lead Auditor grade: In addition to the Audit requirement for the Auditor grade listed above, the Auditor must have completed 3 acceptable Audits, as the leader of an Audit team that included at least one other Auditor. The duration of the 3 lead Audits must not be less than 15 days, 10 days of which must have been acquired on-‐site. The Auditor must have acquired the Audit management experience during the previous 2 years (IRCA define ‘previous period’ as being that period immediately prior to the date we receive the Auditor completed application), and after successful completion of the relevant acceptable Auditor training course(s). Although IRCA recommends the Auditor should complete all of the Audits under the direction and guidance of an Auditor competent as a team leader (currently EICC-‐IRCA Certified as a Lead Auditor or who has equivalent competence), IRCA acknowledges that for many Auditors this will be very difficult and costly to arrange. Consequently, IRCA will accept a minimum of 1 lead Audit under these conditions. IRCA may require this team leader to attest to the Auditor competence to lead an Audit team.
Closure Audits: IRCA does not normally accept Closure Audits when submitted for initial certification. However, IRCA does accept Closure Audits for renewal of certification. As a general rule IRCA considers five Closure Audits to be equivalent to one full EICC Initial Audit, but recognize that some Closure Audits can be extensive. In such instances, IRCA will accept fewer than five Closure Audits (as being equal to one full EICC Initial Audit) if the Auditor provides IRCA with evidence that supports the Auditor claim.
Not accepted Audits:
• Audits of the same system that are repeated more frequently than once every 12 months.
• Audits of less than one day (6 hours of on-‐site Audit activity exclusive of breaks) duration.
• Gap analysis, close out or follow up visits • Audits performed before successful completion of the formal training
requirement. • Consultancy Audits
4.4.1.6. Fees Fees are set annually and apply for the calendar year (1 January – 31 December). Contact IRCA direct or see www.irca.org for details of current fees applicable for the Auditor country.
Application Fee IRCA needs the Auditor to pay this fee when the Auditor sends in the Auditor’s application. Alternatively, IRCA will invoice the Auditor on receipt of the Auditor’s application. This fee covers the costs of the application process and is not refunded if the application is unsuccessful. Annual Certification Fee This fee covers the annual cost of administering the Auditor’s certification. IRCA will normally invoice the Auditor for this fee when IRCA first offers the Auditor certification following the Auditor’s application, and thereafter each year one month before payment is due, except every third year when the Auditor’s renewal is due. IRCA invoices the Auditor after IRCA has completed the Auditor’s renewal, on the basis that the Auditor’s grade (and fee) may have changed as a result of renewal. Application for Regrade Fee This fee covers the costs of evaluating the Auditor’s regrade. IRCA needs the Auditor to pay this fee when the Auditor submits the Auditor’s request and, as with the application fee, the regrade fee is not refundable. If the Auditor is regraded during the year, IRCA will not ask the Auditor to pay any further certification fees for that current year. The Auditor may request a regrade at any stage during the certification period. There is no regrade fee if IRCA regrades the Auditor as part of the (3 year) renewal of certification process.
10Criteria for Certification 4.4.1.7. Renewal of Certification
The Auditor must renew the Auditor’s certification every three years, i.e. at the end of the third complete year. IRCA will write to the Auditor two months before the Auditor’s certification period expires and ask the Auditor to send IRCA the Auditor’s Audit and CPD logs and other documents. IRCA will evaluate these against the renewal requirements listed below and make a certification decision. IRCA will then write to the Auditor with the results. The renewal of certification process involves these five requirements:
• Continuing Professional Development (CPD) • Audit experience • Declaration of Complaints • Compliance with the IRCA Code of Conduct • Payment of the Annual Fee.
Continuing Professional Development For all grades: The Auditor must have completed at least 45 hours of appropriate and industry specific CPD during the 3-‐year period immediately prior to renewal of certification. IRCA needs the Auditor to provide IRCA with evidence that the Auditor has met this requirement. Audit Experience IRCA needs the Auditor to record and submit the Auditor’s Audit experience on the Audit log sheets (IRCA/106), which IRCA supplies. All Audits performed in each three year renewal period should be logged with careful attention to providing all details required in all columns of the Audit log sheet.
For EICC Provisional Auditor grade: There is no requirement to perform Audits.
For EICC Auditor grade: The Auditor needs to have completed at least 5 EICC acceptable Audits.
For EICC Lead Auditor grade: The Auditor needs to have completed at least 5 EICC acceptable Audits, any 2 of which must have been as the leader of a team, which included at least one other Auditor.
Declaration of Complaints IRCA needs the Auditor to tell IRCA about any complaints made against the Auditor’s professional conduct. Formal complaints may be made by the Audit Client, the Auditee, and related parties. It is important IRCA knows of any complaints as IRCA needs to consider these as part of the renewal of certification process. IRCA will investigate all instances of complaints. If complaints are made against the Auditor’s conduct and the Auditor does not declare them and take appropriate steps to address them, the consequences will be far more serious and may result in suspension or withdrawal of the Auditor’s certification. Compliance with the Code of Conduct IRCA needs the Auditor to make a declaration that the Auditor has always acted in compliance with the IRCA Code of Conduct. Payment of the Annual Fee IRCA needs the Auditor to pay the annual fee (please note there is no additional fee for renewal). Because the fee will be dependent on the grade we offer the Auditor after renewal, IRCA does not ask the Auditor to pay this fee until after IRCA has completed the renewal. IRCA will write to the Auditor with the results of the renewal and enclose the fee invoice and the Auditor’s new certification card. Failure to pay the Auditor’s annual fee will result in the Auditor’s certification being withdrawn.
11 4.4.1.8. How to Regrade The Auditor can apply to be regraded to another grade and/or scope at any time. When IRCA offers the Auditor initial certification IRCA will indicate the Audit experience and competences the Auditor needs to attain the next grade(s) of certification. To apply for regrade, the Auditor should complete IRCA/106 log sheets, enclose any additional information requested and send to IRCA with the regrade fee. A successful application for regrade will not normally result in a change to the Auditor’s renewal of certification date. If the Auditor decide not to apply for regrade during the Auditor’s certification period, IRCA will write to the Auditor two months before the Auditor’s certification period expires as part of the renewal of certification process and ask the Auditor to send IRCA the Auditor’s Audit and CPD logs. At this point IRCA will let the Auditor know the current regrade requirement. There is no regrade fee if the Auditor is regraded as part of the (3 year) renewal of certification process.
4.4.1.9. The Certification Period When the Auditor’s application is successful, IRCA award certification for a period of 3 years, beginning in the month IRCA awards certification. This 3 year period is referred to as the certification period. At the end of the each certification period IRCA requires the Auditor to renew the Auditor’s certification. If the Auditor is successful at renewal, IRCA awards the Auditor certification for a further 3 year certification period, and so on. During the certification period, at the end of the first and second years, the Auditor may maintain certification by payment of the annual certification fee and by compliance with the Code of Conduct. IRCA does not require the Auditor to submit any other documentation at the end of year 1 and year 2. At the end of the third year, all certified Auditors are required to complete the renewal of certification process. 4.4.1.10. Acceptability of Standards, Codes and Other Audit Criteria Since this program is specific to the electronics industry IRCA will only accept Audits performed against the EICC Audit Criteria. 4.4.1.11. Certification Cards, Certificates and the Register IRCA will send the Auditor a Certification Card following initial award of certification and annually thereafter when the Auditor pay the Auditor’s annual fee and comply with any other applicable requirements. This card is the Auditor’s primary evidence of certification and the Auditor should present this when the Auditor first begin an Audit and thereafter whenever appropriate. Although the card is issued to the Auditor, it remains IRCA property and the Auditor must return it to IRCA should IRCA ask the Auditor to. The IRCA Certificate is intended for display as a formal recognition of the Auditor’s certification to a specific grade. The Auditor should not use it as proof of certification. Please contact IRCA if the Auditor wishes to purchase a certificate. The Auditor can find details of all certified Auditors in each country on the ́Find an Auditor ́ section of the IRCA website www.irca.org. 4.4.1.12. Appeals and Complaints The Auditor has the right to appeal against any certification decision taken by IRCA. IRCA operates a quality system that includes established procedures for considering appeals and complaints. 4.4.1.13. Enforcement of Certification IRCA enforces (i.e. suspends or withdraws) certification for two reasons: 1. If the Auditor fail to meet the certification criteria for the grade to which the Auditor is certified. This enforcement occurs when the Auditor applies to renew the Auditor’s certification. In most cases withdrawal will be preceded by an offer of an alternative grade for a period during which the Auditor has the opportunity to meet the requirements and be reinstated to the grade the Auditor originally held.
2. If the Auditor breaches the Code of Conduct, IRCA reserves the right to undertake action against the Auditor’s certification if IRCA finds the Auditor to have acted contrary to the Code of Conduct. Options available include suspending, or in instances of serious or sustained breach, withdrawing the Auditor’s certification. 4.4.1.14. Confidentiality IRCA undertakes to consider as strictly confidential all information, correspondence and documentation submitted by the Auditor to IRCA in support of the Auditor’s certification activities. IRCA reserves the right to disclose details of the Auditor’s certification record to other Auditing bodies. IRCA will do so with discretion and only in instances where IRCA considers withholding this information will compromise the integrity of certification, e.g. where IRCA has taken action against (i.e. suspended or withdrawn) the Auditor’s certification and the Auditor has applied to another Auditor certification body without fully disclosing the Auditor’s record while certified by us. IRCA reserves the right to publish relevant details of each certified Auditor in the register available on-‐ line at www.irca.org. 4.4.1.15. Legal Status The certification of Auditors by IRCA and all activities associated with the administration of the register is governed in accordance with English Law and is subject to the exclusive jurisdiction of the English Courts.
4.4.2 EICC VAP qualification: An Auditor can apply for EICC qualification by sending the required details to the EICC VAP APM (Audits@vectra-‐intl.com) for review and decision on qualification.
4.4.2.1. Information template Auditor qualification information will only be accepted in the EICC Auditor qualification template. This can be requested to the APM at audits@vecta-‐intl.com.
4.4.2.2. Information requirements
• Name of company (employer): Provide full name of legal entity company name • Name of Auditor: Provide full name as written on government issued identification • Location (person is based in) (City): Provide current office location city • Location (person is based in) (Country): Provide current office location country • Title: Provide current title and describe current job responsibilities (3 bullet items) • Email: Provide company email • Phone: Provide company office phone and mobile
• Formal education degrees: Provide list of formal academic degrees, issuing institution and year of degree
• Auditor's accreditation (e.g. IRCA, RAB-‐QSA, ....): Provide list of current accreditations (topic, accreditation organization, accreditation reference number, date of issue and date of expiry) and list of expired accreditations (topic, accreditation organization, accreditation reference number, date of issue and date of expiry)
• List specific skills in Labor and Employment: Provide list of skills in Labor and Employment such as pay roll calculation, interviewing, … There is no reference list. For each skill provide example of application. Ensure examples are anonymized but detailed enough to allow for evaluation. Do not repeat skills that are included in an accreditation.
• List specific skills in Business Ethics: Provide list of skills in Ethics such as person of confidence, issue investigation, … There is no reference list. For each skill provide example of application. Ensure examples are anonymized but detailed enough to allow for evaluation. Do not repeat skills, which are included in an accreditation.
• List specific skills in Occupational Health and Safety: Provide list of skills in occupational health and Safety such as fire engineering, first aid, firefighting, … There is no reference list. For each skill provide example of application. Ensure examples are anonymized but detailed enough to allow for evaluation. Do not repeat skills that are included in an accreditation.
• List specific skills in Environment: Provide list of skills in Environment such as wastewater treatment, spill response, … There is no reference list. For each skill provide example of application. Ensure examples are anonymized but detailed enough to allow for evaluation. Do not repeat skills that are included in an accreditation.
• List specific skills in Management Systems: Provide list of skills in management systems such as PDCA cycle implementation, … There is no reference list. For each skill provide example of application. Ensure examples are anonymized but detailed enough to allow for evaluation. Do not repeat skills that are included in an accreditation.
• List specific skills in Root Cause Analysis (including Corrective and Preventive Action): Provide list of skills in RCA such as Ishikawa analysis, Pareto analysis, … There is no reference list. For each skill provide example of application. Ensure examples are anonymized but detailed enough to allow for evaluation. Do not repeat skills that are included in an accreditation.
• List external training (last 3 years): Provide listing of all external trainings relevant to Auditing, LE or EHS which are more than one day (list topic, provider, date, duration)
• List internal training (last 3 years): Provide listing of all internal trainings relevant to Auditing, LE or EHS which are more than one day (list topic, date, duration)
• Number of Audits participated in over last three years: list number of Audits for each year in last three years. This can include follow up Audits
• Languages: specify fluency (fluent, conversational, basic, notional) for written and spoken aspect of each language
• Other information which could support the Auditor’s EICC Auditor qualification: optional field to provide additional information which could help understand motivation/justification for qualification
• Date and ref of sample Audit report 1 attached (report to proof competency -‐ not older than 12 months): Attach an anonymized report in which person to be qualified was part of Audit team and contributed to the report. This does not need to be a specific EICC protocol report
• Date and ref of sample Audit report 2 attached (report to proof competency -‐ not older than 12 months): Attach an anonymized report in which person to be qualified was part of Audit team and contributed to the report. This does not need to be a specific EICC protocol report
• other attachments: list references of other attachment to application (e.g. resume,…)
• Date of Submission/Revision (MM/DD/YYYY): List date submitted
4.4.2.3. Qualification and Scoring The information provided will analyzed and scored on a maximum of 5 points for LE (labor/Ethics) and 5 points for EHS (Environment/Health/Safety) Qualification:
• Higher than 3.5: Auditor is EICC VAP qualified • Between 3.0 and 3.5: Auditor is Provisionally EICC VAP Qualified. The Auditor is EICC
VAP qualified to assist an Audit team but cannot be a topic Auditor • Below 3.0: Auditor is not EICC VAP qualified
Scoring The following scoring points apply:
• Competence and skill (maximum 2 point) o 0.5 per relevant academic degree or equivalent vocational credit o 0.5 per relevant accreditation o 0.2 per relevant public training o 0.1 per relevant internal training
• Topic application: (maximum 1 point) o 0.1 per relevant skill (in case of accreditation score is 0.5)
• Field experience (maximum 2 points) o Audit performed 0.1 per 10 (if non EICC), 0.2 per 10 (if EICC) in last 12
months (maximum 0.6 points) o Audit reporting (maximum 1.2 points – 0.6 points per report)
§ Report will be evaluated on completeness, data point justification, reporting accuracy (0.2 points per category)
o CAP management (maximum 0.2 points)
4.4.2.4. Process and fees for EICC VAP Qualification The fee is directly payable to the APM and is currently 25 USD per evaluation per person, whether the evaluation results in qualification or not
Time Action Responsible 0 Submit information for qualification Auditor 2 days Confirms if submission is accepted. It is
possible that submissions are not accepted as not all info is provided or attachments are missing
APM
5 days Issues invoice to company to applicants APM 60 days Invoice in paid Company Auditor 5 days upon receipt of payment
Qualification review APM
10 days upon receipt of payment
Result of qualification is communicated. If positive result will include Qualification Certificate
APM
4.4.2.5. Confidentiality The APM considers all information, correspondence and documentation in support of qualification activities strictly private and confidential. 4.4.2.6. Enforcement of Qualification The VAP APM enforces (i.e. withdraws) qualification if: 1. In the Quality review of an Audit report submitted to EICC the Auditor fails on three consecutive attempts to meet the EICC Quality Criteria 2. A formal and justified complaint of breach EICC or other relevant professional Auditor Code of Conduct is received. 4.4.2.7. The Certification Period When the Auditor’s application is successful, The APM awards qualification for a period of 2 years, beginning in the month the APM awards the qualification. This 2-‐year period is referred to as the qualification period. At the end of the each qualification period the Auditor should renew the Auditor’s qualification. If the Auditor is successful at renewal, The VAP APM awards qualification for another 2 years. 4.4.2.8. How to Requalify The Auditor can apply to be Requalified at any time, with exception of a withdrawn qualification where the minimum period of requalification is 2 years.
4.4.2.9. Qualification Statement and Register The APM will send a Qualification Statement in PDF format The APM will keep a register for process integrity purpose of all applications, scores and qualification numbers. The Qualification Statement is personal and not linked to the employer at the time of Qualification. The Qualification Statement has the following layout:
Patrick C Neyts EICC'Validated'Audit'Program'Manager'
Qualifica:on'number:'
Qualifica:on'date:'
Qualifica:on'valid':ll:'
5. Audit Criteria
The Audit will be undertaken using the EICC Validated Audit criteria. The criteria align with the EICC Self-‐Assessment Questionnaire (SAQ) and the EICC Code of Conduct. An Auditee’s completed SAQ will be used by the Audit team to help determine the scope of the Audit. The Audit will then validate the Auditee’s conformance with the Audit criteria. The Audit criteria cover five main areas:
• Labor • Ethics • Health & Safety • Environment • Management Systems
The Audit criteria are found in the Microsoft Excel-‐based Audit Protocol 4.0.1 or EICC-‐On. The Protocol includes all the Audit questions and guidance for Auditors on evidence gathering and worker interviews. The Excel-‐based version of the Audit criteria is the primary tool to be used for on-‐site Audits. The completed Protocol will automatically generate the Audit report.
Each criteria question has defined Nonconformance significance; the Auditor decides based on the Nonconformance definitions for each question the significance (Priority, Major, Minor, Risk of Nonconformance, Conformance, Not Applicable) only if justification is given.
Other rating options are Not Reviewed in this Audit, option only available when a Closure Audit is performed and rating for this question was Conform in Initial Audit, Out of Scope, is rating using for questions which are not scoped for this Audit (e.g. labor agent/contractor Audit).
The Auditor must provide a complete response to each question. That includes providing a concise “Findings Summary” as well as a detailed “Description of Supporting Evidence.” Three independent data points are required to substantiate a finding, however not all need to be reported depending on the rating significance (see section 8.4.1).
Fundamental to the EICC Audit criteria is regulatory compliance. Legal Nonconformances will be noted in the corresponding question in the Audit Protocol. The specific legal reference (statute name and number) must be provided in the “Description of Supporting Evidence” column of the Audit Protocol
6. Audit Team
ONLY EICC VAP Auditors from third party qualified Audit firms approved by the APM will performed an EICC Audit.
The Audit team will be thoroughly familiar with the EICC Audit criteria, and the process and Protocols developed by EICC. Auditors must be familiar with the region, country, and industry of the Auditee, and of the social, labor, environmental, ethics and health & safety issues and legal requirements relevant to the sector.
The sections that follow align with clause 6 of ISO 19011:2002, “Audit Activities.”
6.1 Team Composition and Size
The Audit team must consist of a Lead Auditor, who is responsible for completion of the Audit, and one or more additional Audit team members appropriate to the scope of the Audit. The Audit Firm must match the expertise and experience of team members to the anticipated nature of the Auditee’s operation.
Note: Only Auditors that have been evaluated and accepted by the APM may perform a VA Audit on behalf of EICC. The APM is responsible for ensuring all 3rd party Auditors meets minimum performance criteria.
6.2 Audit Scope
The Audit will most commonly be a four to six person-‐day event depending on the size and complexity of the facility. The size of the Audit team and number of Audit days will depend on a number of factors such as:
• Physical size of the facility, • Number of workers, • Process complexity, • Results of the facility self-‐assessment, and
• Type of Audit (e.g. Initial vs. Closure Audit)
The Audit scope (size of the team and duration of the Audit) will be determined by the APM, using the SAQ and other pertinent information about the site (see section 26.4).
For labor agency/contractor Audits, Audit scope includes both the labor agency/contractor site and the sites where workers are deployed. Facility tour at the deployment site should only be areas where the agency workers are deployed and common areas where workers might be interacting in, such as the break room, lunch, restrooms, ... Worker interviews should be performed at both the Auditee site and deployment site. The number of worker interviewed is square root of deployed workers in total.
6.3 Pre-‐Audit Planning
6.3.1 Audit Process Documentation
Each Auditor must review the following documents to ensure they are familiar with the Audit materials to be used and completed during the onsite Audit and after the Audit.
• Opening and Closing Meeting presentation slides, • EICC Audit Operations Manual (this document) and attachments, • Electronic Industry Code of Conduct v4.0 (2012 version)
6.3.2 Review of Auditee Documentation
A thorough pre-‐Audit review of Auditee documents (e.g. self-‐assessment questionnaire (SAQ), objectives and targets, previous Audit reports, ...) is necessary to maximize Audit efficiency by minimizing the amount of time spent reviewing documents during the Audit.
Each Audit team member will conduct a pre-‐Audit review of the documentation made available by the Auditee facility (and/or the APM) focusing on his or her section and subject area assignments.
Due to limited time, Auditors may not be able to cover all criteria sub-‐elements. It is therefore important that Auditors review available information prior to the Audit in order to determine which of their Audit sub-‐elements and subject area assignments are most applicable to the facility being Audited, and which areas should be priorities given the anticipated level of risk or previously identified Nonconformances. The APM must pre-‐approve any reduction in the number of criteria sections covered in a Validated Audit.
6.3.3 Team Meetings
The Lead Auditor should arrange one or more meetings with the Audit team prior to the Audit to discuss any issues that arose as a result of their pre-‐Audit document review, including impressions, rationale for selected Audit scope, comments, and questions. Logistics and other Audit arrangements will also be coordinated and finalized.
6.3.4 Audit Plan
To improve the efficiency of the on-‐site evaluation, Auditors should prepare an Audit plan covering their selected Audit scope. The plan should consider:
• Additional documents and records to be reviewed prior to and during the Audit.
• Estimated time requirements for each criteria section.
• Prioritized list of criteria areas to be evaluated.
• Physical locations to be visited.
• Facility management and other staff to be interviewed.
• Number of workers to be interviewed, including work shifts, plant locations, ....
• Key questions and areas of discussion for staff and workers (refer to Section 12).
• Records to be reviewed.
6.4 Notification of Site Management and Development of Site Agenda
The Lead Auditor is responsible for scheduling the Audit with Auditee management at least two (2) calendar weeks prior to the Audit.
At the time of the notification, the Lead Auditor should take care that the following items are addressed:
• Discuss the scope of and agenda for the Audit with Auditee management • Obtain directions to the site and a hotel recommendation (if needed) • Review site safety and security requirements • Identify the Audit team members
• Request any additional documents and records that are needed for the Audit team to prepare for the Audit.
• Set exact time of arrival and time of opening conference; assure participation by the site manager and staff.
• Request office space and telephone access while on site
• Request a list of key site staff or organization chart
The Lead Auditor will contact Auditee management to ensure that additional documentation is submitted in a timely fashion to allow for Audit team review prior the Audit. Finally, the Lead Auditor will make one last confirming phone call a few days before the Audit to ensure the Auditee is prepared.
For Labor Agent/Contractor Audits, Audit Firm shall ensure to contact both the management team at the Auditee location as well as the sites where the workers are deployed. Worker interviews and facility tour should be arranged at the worker deployment sites.
7. Auditee Preparation
A successful Audit depends on careful preparation by both the Audit team and the Auditee. In advance of the Audit, Auditee management needs to:
• Ensure the participation of senior managers at both the opening and closing meetings
• Appoint appropriate staff to interface with and accompany the Audit team
• Establish an agenda and schedule for the Audit together with the Audit Team Leader
• Provide the Audit team leader with documents needed by the Audit team to prepare for the Audit.
• Make appointments with appropriate management staff and ensure they are prepared for the Audit
• Ensure that all relevant information is available for the Audit team upon their arrival (e.g. maps of the facility; names and numbers of key people, ...)
• Ensure that Auditors have access to all facilities (e.g. manufacturing, assembly, distribution, canteens, dormitories, chemical storage, ...) within the Audit scope.
• Locate and collate all the requested records and documentation. Ensure that these are up to date and readily available on the day of the Audit.
• Provide the Auditors with a meeting room and access to areas of the facility that will enable worker interviews to be undertaken in a confidential manner.
• Layout of the facility or campus as applicable depending on scope of the Audit
More detailed information can be found in Section 13.3.12 of this Manual
8. On-‐Site Audit Process
There are nine components of the EICC on site Validated Audit:
8.1 Audit Team Preparation Meeting 8.2 Opening Meeting 8.3 Orientation Tour 8.4 Detailed Evaluation 8.5 Management interviews
8.6 Worker Interviews 8.7 Analysis of Findings 8.8 Daily Wrap up meetings 8.9 Closing Meeting
8.1 Audit Team Preparation meeting An Audit preparation meeting, led by the Lead Auditor and attended by all Audit team members, should take place the evening before the Audit. The purpose of the meeting is to ensure each member of the Audit team is introduced to one other as well as to align on team roles and responsibilities.
The preliminary interview schedule (who interviews whom and when) is also reviewed. However, changes to the schedule are possible as the Audit progresses and suspected Nonconformances require further investigation.
The Lead Auditor will then review the attached presentation with the Audit team to ensure each Auditor understands their role, conduct and responsibilities during the course of the Audit as well as what is expected in terms of their output.
8.2 Opening Meeting The purpose of the opening meeting is for the Audit team to introduce themselves to facility management and staff and review important aspects of the Audit such as the schedule, the specific areas to be addressed, and how the report will be prepared and delivered.
8.2.1 Audit Team Presentation
The Lead Auditor will review the Audit agenda, Audit process and scope, and any other items as requested by the facility. The opening meeting with site management should last no more than one hour. The Lead Auditor can use the PowerPoint presentation template, “EICC Audit Opening Meeting Template.” The slide set can be modified as needed. A typical agenda for the opening conference includes:
• Purpose and objectives of Audit • Audit scope • Audit approach
- Tours, interviews, record reviews, taking of field notes - Emphasize the fact that not every record or operation will necessarily be reviewed
in detail and that the team may only look at a representative sample of items to determine conformance.
- Field notes will be reviewed by the Lead Auditor to ensure that they contain only statements of fact and not supposition or inappropriate comments
- Scheduling the daily wrap-‐ups and closing meeting
• Audit schedule
• Report preparation and QA process
• Auditee management response
• Audit process flow chart
8.2.2 Auditee Presentation
The Auditee should present an overview of the facility, including: • CR program organization. • Assignment of responsibilities. • CR issues, goals and performance. • A summary review of facility operations. • Identification of important site activities occurring during the week. • Major changes since the last Audit (for follow-‐up Audits). • A review of the pre-‐Audit documentation including the SAQ and any previous Audit
reports. • Identification of key interview candidates and availability (including relevant
organization charts). • Identification of the Audit teamwork room and phone protocol. • Identification of the site work hours and visitor safety and security protocols. • Identification of computer/printer support. • Discussion of the site escort protocol for visitors. • Other information of potential interest to the Auditors and attendees.
8.3 Orientation Tour The Auditee should lead the Audit team on a brief (no more than one hour) orientation tour, which should take place immediately after the opening meeting. The purpose of the tour is to:
a) Familiarize the Audit team with the facility layout and key operations,
b) Observe general physical and working conditions,
c) Observe areas of potential high risk as identified in the Auditee self-‐assessment (SAQ) and other pre-‐Audit documentation, and
d) Identify and prioritize other areas and aspects of local operations that may require more detailed inspection and review during the Audit.
The orientation tour should provide a general overview and walk-‐through of all buildings and operations within the scope of the Audit.
8.4 Detailed Evaluation This Manual and the EICC Audit Criteria are intended as guides in the evaluation process. Daily Audit planning and preparation for each day’s Audit activities are critical to an effective Audit.
Interviews, facility inspections and program reviews should be carefully scheduled based on the Audit scope, priorities identified during pre-‐Audit preparation, and on observations made during the site tour and records review.
Tours and interviews are intended to provide insight into CR policies and practices, implementation of procedures, awareness of roles and responsibilities, and management involvement.
Documentation and records review provides information on how well CR management systems are defined, implemented, and sustained.
8.4.1 Observable, Objective Evidence When conducting interviews, making observations and reviewing relevant documents and records, Auditors must rely solely on observable, objective data and facts (not inference). A fact is information that is:
• Objective and verifiable • Stated or documented, and • Unaffected by emotion or prejudice.
Although a fact can be easily verified by checking its source, an inference is an opinion or assumption based on incomplete information. Although both play a role in Audit observations and results, an inference requires further evaluation and verification before a conclusion can be made.
Data Corroboration
Multiple data points must be used to verify a finding of conformance or Nonconformance. The purpose of this corroboration is to ensure that the Audit findings accurately reflect the facility’s policies, practices and workplace conditions at the time of the Audit. Corroboration helps ensure that Audit findings will be credible and defensible.
One process for corroboration is triangulation, which involves the convergence of data from multiple data collection sources. The idea is that one can be more confident with a result if different sources and types of data lead to the same result. In addition, more data makes it easier for the Auditee to determine the root cause of the issue and implement effective corrective and preventive action.
In most cases, Audit findings must be substantiated by at least three data points. The data points can be either different types of data, or the same kind of data, but derived from independent sources.
Rule of thumb: Three data points are always required whenever either management statements or documentation contradicts information provided by workers.
Different types of data include: documents, records, management interviews, worker interviews, and physical observations. Independent sources mean that the data is obtained from different parts of the facility; different functional areas; or different work shifts.
Examples:
• A visual observation by the Auditor, a reviewed document and a management interview are three independent data points as they are three different types of data
• A document review and interviews with two workers from different departments are also three independent data points. Although two data points are of the same type (work interviews), they were obtained from different sources
• A physical observation and interviews of two workers in the same work area are not three data points. Two worker interviews from the same work area are of the same type and from the same source.
• One data point is required for each aspect of the compliance statement if the rating is conform or minor Nonconformance
• Three data points are still required for all major or Priority Nonconformance conclusions
• Supporting evidence is only required when a non conformity is found • If Auditors take more supporting evidence off site (even for conformance) then this
should be provided to the APM when the draft VAR is submitted • Legal references are only required when a legal Nonconformance is identified • For N/A — one data point is needed and justification of N/A in conclusion • Risk of non conformance requires three data points to demonstrate that current
system does not allow to prove conformance because of weak management
Exceptions
Although Auditors must provide three data points for most issues, there are some situations where two independent data points are sufficient. The following criteria must be met whenever fewer than three data points are provided:
• For questions confirming the presence of a document (e.g. environmental permit), a third data point is not required. It is adequate to verify by a document review that a document was not in place with a corroborating statement from management.
• For questions based on a physical observation by the Auditor (e.g. Are hazardous chemicals or substances labeled properly?), a third data point is not necessary. It is adequate to provide only the observation and a corroborating management statement.
• For questions requiring worker input; if either documentation or management statements corroborate information provided by workers, a third data point is not required.
▬ If documents and/or management statements contradict the information provided by a clear majority of workers, this indicates a possible system failure (implementation or effectiveness) and a third data point is required
A suspected Nonconformance that cannot be verified with at least three data points will be cited as a “Risk of Nonconformance” in the report.
8.4.2 Finding Root Cause
In evaluating information and evidence, the Auditor must look for management system connections and root cause(s). Do not consider an identified issue in isolation.
The cause of an observed workplace issue is likely a deficiency in a management system process, such as an incomplete risk assessment or an inadequate corrective action process.
Getting to root cause and identifying system connections are important for both the Auditor and the Auditee. The primary reasons are that:
• Observations are often only symptoms of the real issue(s) • Problems can only be corrected and recurrence prevented by addressing the underlying
system cause(s).
Example: Consider the case of a worker observed not wearing hearing protection in a high noise area. It may be easy to conclude that the reason was that hearing protection was not provided. However, upon a more thorough evaluation of the evidence, the Auditor may find that the Auditee was unfamiliar with the regulation requiring the use of hearing protection, or that the worker was not trained on the need to wear hearing protection, or the Auditee lacked an enforcement/reinforcement process. These are more fundamental or root causes for the observed deficiency.
8.4.3 Program Documentation and Records Review As stated in the pre-‐planning section (6.3), the Audit team should review all available documents; such as self-‐assessments, previous Audit reports, corrective action plans, .... prior to the onsite Audit. The reason for this is to target high risk/concern areas and to allow better utilization of limited on-‐site time.
Some on-‐site document review will be necessary, however, as confidential information, such as payroll records and timecards can typically not be provided in the pre-‐Audit phase.
It is important for the Audit team to spend some time reviewing the site's compliance records (e.g. permits, plans, procedures, records) before interviewing the staff or inspecting the operating facilities. This is because many of the compliance requirements are found in these records. The Audit team will review the records for the applicable requirements and verify compliance through interviews, inspections or a review of compliance data.
The Auditors should be thorough in the review of records. However, this does not mean that every record is to be evaluated. The Auditor is free to use statistical or otherwise representative sampling in the review. Where the Auditor does not review every record and there is a Nonconformance finding, the Auditor must reflect the sampling method in the statement of finding.
The following documents and records that must be available on-‐site for Auditors to review covering at least the previous 12 months is provided in Section 13.3.12
8.4.4 Facility Inspections Inspections of the site, with special attention given to potential high risk/Nonconformance areas, should be conducted following a review of records and interviews with facility management staff. Physical inspections may include areas concerned with:
• Air emissions and emission control systems, • Hazardous waste generation and storage, • Fuel, chemical and oil storage, transport and use, • Wastewater treatment, discharge and sludge disposal, • Hazardous materials storage and handling, • Manufacturing and processing operations, • Work stations, • Worker canteen, kitchen and food storage facilities, • Recreational facilities, • Restroom/bathroom facilities, • Medical center/clinic, and • Dormitory facilities.
Worker interviews should be conducted while performing these detailed site tours. Also, with consent from the facility management, digital photographs might be taken to further support the data obtained.
8.5 Management Interviews (Facility Staff) Proper interviewing is perhaps the single most important element of the process. Auditors should focus on obtaining responses that enable accurate evaluation of past and current operating practices, in a manner that is sensitive to interviewee apprehension and nervousness. Interview candidates should include senior managers, program managers, and supervisors. Auditors should verify statements made by site staff through a review of documents, records, physical observations and worker interviews. This "verification" step is used routinely in Auditing and Auditors should ensure that site staff is aware that it is not meant to be a challenge to the veracity of their statements.
The Audit Team will conduct interviews, as appropriate, with: • Site manager(s) • Production manager(s) • Environment manager(s) • Health and Safety manager(s) • Quality manager(s) • Internal Audit Manager(s)/Auditor(s) • Human resources manager(s) • Finance manager / payroll manager (s) • Legal • Procurement manager (s) (to understand any relevant supply chain CR policy, issues and their
management) • Supply chain manager • Onsite medical staff as appropriate
8.6 Worker Interviews Worker interviews provide the Audit team with a critical complement to the opening meeting, staff interviews, site observation and documentation review. Listening to and understanding the workers can provide a realistic view of working conditions and are critical to obtaining a full range of perspectives on facility programs and performance.
Worker interviews are a particularly sensitive topic. Auditors should always ask site management to ensure that worker interviews can be conducted privately, without the presence of facility managers or other staff. Worker input must be confidential and the Auditee should agree at a senior level that they will encourage workers to be open and honest during interviews and actively protect any interviewed worker. Interviewed workers must remain anonymous and must not have their pay docked or suffer other penalties as a result. However, management may be suspicious of such activities and workers may be concerned about what will happen to them if management is aware of their participation. APM should be immediately informed if site management is unwilling to allow interviews, or if the team feels that workers talking openly with Auditors will compromise the workers. The APM will assess the situation, including contacting the Auditee, in order to determine if the Audit should continue or if the Auditors should make use of other methods of investigation where possible.
The EICC Audit Criteria and Audit Protocol contain typical worker interview questions for those sections that require worker feedback to verify facility conformance.
In order to provide statistically valid results, the number of worker interviews conducted and the number of worker records reviewed depends on the number of workers at the facility. The Audit team will select workers for interview throughout the Audit, and will require a confidential space to conduct the interviews. Interviewees will be drawn from a range of workers including permanent, temporary, subcontract labor, security, cleaners, food preparation, .... The pool of workers to be interviewed will include new workers at less skilled positions, workers from various departments and shifts, and workers of both genders. This should include worker representatives as appropriate. Auditors must use their discretion and consider industry, location, and individual facility knowledge when defining the number of employees to interview.
The number of interviews conducted should equal approximately the square root of the total number of workers (direct and indirect employed people excluding management staff) (e.g. 55 interviews for a factory with 3000 workers). This should be done with a mix of individual and small group interviews. Roughly half the workers should be interviewed individually, while the other half can be interviewed in small groups. The ratio of individual and group interviews is for guidance only, and may be modified depending on circumstances, but every effort should be made to achieve the total number recommended. Where this is not possible clear explanation for a lower number of interviews should be given in the report.
Rule of thumb: Regarding the number of workers to be interviewed, if you have interviewed at least half the target number (one half of the square root) and all worker feedback is consistent with information provided by management and documents reviewed, then it is not necessary to perform any additional interviews.
Interview time is estimated to be less than 10 minutes for individual interview with no issues and 20 minutes for individual interview where issues are raised. Group interviews are estimated at 30 minutes taking into account the additional time to get workers to attend and to give everyone an opportunity to express themselves. This length is only a guideline/suggested minimum. Auditors will rely on their training and experience to determine the length of actual interviews with individual employees. If issues are uncovered with a particular worker, the interview will be extended to fully explore the issue. Alternatively, if workers are consistently providing the same information, interviews may be the minimum timeframe.
Ensure to document the following information about worker interviews: • Gender breakdown of interviews (e.g. 36 female, 32 male and 12 juveniles) • The shift on which workers are engaged (if applicable). • Any issues with privacy and confidentiality of interviews. • Whether workers attended interviews freely • Workers were not coerced • Age range of interviews undertaken • Number of individual and group interviews undertaken • Total number of interviews undertaken
• Whether interviews were undertaken by the Auditor or professional interviewer
A minimum of 3 months of pay and time records (peak, valley and average month) will be reviewed for each worker for the 12-‐month period prior to the Audit. In the case of a Closure Audit 3 months of pay and time records will be reviewed for each worker from the period of corrective action implementation till date of Audit (not exceeding one year)
Note: The number of records per month reviewed must always equal at least the square root of the total number of workers at the site, even if you have interviewed less than that number.
Note: If workers from onsite subcontractors are present, Lead Auditor will ensure that Auditee informs subcontractor BEFORE the onsite Audit that workers employed by them will be engaged (interviewed) and that working hours and wage/benefits review might take place. Auditee will ensure that necessary information is available for review.
Note: A Closure Audit CANNOT take place unless there us at least three months on consistent implementation data of the CAP (unless the Closure Audit is related to a Priority Nonconformance) or if the Closure Audit will take place AFTER the initial audit has expired (2 years after close meeting of Initial Audit). In the latter a new Initial Audit is required.
8.7 Analysis of Findings 8.7.1 Audit Team Communication
The Audit team will meet frequently throughout the Audit to exchange information and gauge the Audit’s progress. The Audit team leader should assemble the Audit team at the beginning and end of each day to discuss findings, exchange information, determine Audit follow-‐up trails and strategies, and note areas that need attention.
8.7.2 Audit Findings
Preliminary findings must be confirmed with the management representative by reviewing the facts and supporting evidence. This can be done during the daily closing meeting. Auditors should be open to different approaches that the Auditee may use to meet the Audit requirements.
The supporting evidence for all conclusions – both conformance and Nonconformance – must be described in the appropriate field in the Audit Protocol.
If an Auditor has a question about how to interpret an EICC Audit Criteria requirement, it should be immediately directed to the APM.
a) Definitions • Audit Evidence: records, statements of fact or other information, relevant to the
Audit criteria and which are verifiable. As stated in section 8.4.1, most findings must be substantiated by three independent data points.
• Audit Findings: result(s) of the evaluation of the collected Audit evidence against Audit criteria.
b) Analysis While the Audit process is a collaborative effort between the Auditee and the Audit team, ultimately the Audit findings are based on the judgment of the Audit team. The Audit team will ensure that findings are:
• Based upon objective evidence obtained during the Audit, relative to: ▬ Intent: whether the Audit criteria have been addressed, ▬ Implementation: how well the practice meets the defined criteria, and ▬ Effectiveness: whether the policies and practices deliver the intended results
• Reflective of the issues and risks present at the site; • Focused on the most important issues;
• Based on current performance only (i.e. you cannot consider future plans in making a conformance determination);
• Structured to make it easy for management to determine a response (corrective and preventive action);
• Consistent among Audit team members; and,
• Presented in a way to motivate improvements in performance.
c) Rating of Findings A finding may be presented as a Priority (Red with White Central Star), Major (Red) or Minor (Yellow) Nonconformance to a specific requirement in the EICC Audit Criteria, or as a Risk of Nonconformance (Orange).
Out of scope (Grey) and Not Reviewed in this Audit (Brown) can be used in limited scope Audits (closure Audits) or specific targeted Audits (e.g. Labor Agent/Contractor Audit, service provider Audit, …)
The rating of each EICC Audit statement has been predefined. However, based on the identified risk, the Audit team is free to suggest either increasing the rating (e.g. Major to Priority) or decreasing it (e.g. Major to Minor). A thorough justification must be provided for any change to the predetermined question significance levels.
The following are examples of risk factors to consider when changing the rating of a finding:
• Health and safety risks to workers • Health, Safety and Environmental risks to the community • Significant restriction or abrogation of worker rights • Nonconformance to local law • Reputational risk • Operational risk
The ratings of each Audit statement were established using the following considerations:
• Major Nonconformance is seen a significant failure in the management system – one that affects the ability of the system to produce the desired results. It may also be caused by failure to implement an established process or procedure or if the process or procedure is totally ineffective. For example, the failure of an organization to verify its compliance to applicable laws and regulations is a Major Nonconformance. A Major Nonconformance would also include any “Priority” items, such as the presence of child labor in a facility. If a Priority issue is found, the Auditor must report this immediately to facility management and to the APM. Other Priority issues include: forced labor, health and safety issues that can cause immediate danger to life or serious injury, and environmental issues that can result in serious and immediate harm to the community.
• Minor Nonconformance: A minor Nonconformance by itself doesn’t indicate a systemic problem with the management system. It is typically an isolated or random incident. Examples are: an internal Audit with an overdue corrective action request pending, or a procedure that has not been revised to reflect a change in regulations.
• Risk of Nonconformance: This rating is used in a limited number of situations:
1) When there is insufficient evidence (e.g. less than 3 data points) to conclusively determine conformance or Nonconformance. This could happen as a result of insufficient time, or unavailability of key documents or individuals.
2) When there is conflicting evidence. An example of this would be when worker interview information contradicts program documentation or management statements.
3) If the condition or practice is in conformance with the requirement, but in your judgment, it would likely deteriorate to a Nonconformance without some additional action or effort on the part of facility management.
• Conformance: When the Audit team determines that a facility is in conformance with a question/provision of the EICC Audit criteria, such a finding should be stated clearly to balance the Audit report with some good or leading practices.
• Priority Nonconformances: Priority Nonconformances are the highest severity Nonconformance and require escalation by Auditors. Priority Nonconformances confirm the presence of underage child workers (below the legal age for work or apprenticeship), forced labor, health and safety issues that can cause immediate danger to life or serious injury, and environmental practices that can cause serious and immediate harm to the community. Some Codes refer to these as “Zero Tolerance” issues.
If a Priority Nonconformance is found, the Auditor must report this immediately to facility management and to the APM.
The Auditor will inform the Auditee that issues representing an immediate danger to employees must be corrected as soon as practical but no longer than 30 days after discovery. Employees must be removed from the exposure until corrective action is taken.
8.8 Daily Wrap-‐up Meetings Findings should be summarized and discussed daily in an informal session with the Auditee’s management representative(s). This is needed to prevent “surprises” at the closing meetings and to give management the opportunity to provide evidence or information that the Auditor may have overlooked.
Meetings should be kept to 30 minutes and the Auditor should:
• Discuss any “Priority” findings, including need for immediate correction or containment of ones that constitute imminent danger to life.
• Inform Auditee management that a formal communication of “Priority” items will be made to the APM, who will in turn notify the Auditee’s EICC customers.
• Make the Auditee aware of any issue where the Audit team needs additional information in order to make a determination of conformance.
• Encourage the Auditee to present/prepare additional evidence as well as alternative approaches to compliance/conformance with the Audit criteria and legal requirements.
8.9 Closing Meeting The closing meeting will take place at the end of the last day of the Audit. Major Audit findings are communicated in the closing meeting as this enables the Auditee to agree with the findings and ensure they fully understand them and therefore how to address them properly. In instances where the Auditors need to conduct further studies (e.g. review relevant legislation) to establish if an issue observed is indeed a finding, the facts of the pending issues must be agreed with the site management and the reasons for further to investigation should be articulated during the closing meeting. This is to minimize on the possibility that issues not discussed during the closing meeting coming up as a surprise item in the Audit report.
The Major and Priority Audit findings must be presented during the Closing Meeting. The Auditor can use summary slides created from the EICC Closing Meeting Template. If the situation requires a Closing Meeting presentation (site expectation, large number of people, culture) to use the EICC Closing Meeting Template. The EICC Closing Meeting Template as a talk point guide to ensure consistent messaging if the situation does not require a formal presentation (small site,…..).
The Audit Finding Acknowledgement Statement is signed at the end of the Closing Meeting and emailed to the Auditee and APM signed within 48 hours of the close meeting.
The closing meeting is also used to thank facility management for allowing the team to tour the facilities and for their cooperation during the Audit.
NOTE: Priority Nonconformances, including findings of imminent danger to workers or imminent threats to the environment and surrounding community, child labor or forced labor and records falsification must be clearly communicated to Auditee management, including the need to implement immediate containment action and to fully implement corrective and preventive action within 30 days.
The Audit team will also describe the next stage of the Audit process – i.e. the formal Audit report containing all findings, and the requirement for the Auditee to address the findings with a written improvement plan that must be provided to their approved customers upon request.
9. Validated Audit Report (VAR)
The Validated Audit Report is a formal document describing the Audit findings – both good practices and Nonconformances -‐ based on objective evidence.
The Audit team will prepare a draft report within two calendar weeks of the closing meeting and electronically transmit it to the APM in the Microsoft Excel EICC VAP Audit Protocol 4.0.1.
Report Requirements
The Audit report serves as the basis for the facility corrective action plan (CAP) and for continual improvement. It also serves as a detailed record of the conditions and practices in place at the time of the Audit. This information may be essential in addressing questions and concerns from the Auditee, government agencies and stakeholders. Therefore, Audit firms must employ a rigorous internal quality assurance process to ensure that all reports meet the EICC minimum criteria for quality and completeness.
The Audit findings are entered in the following Audit Protocol worksheets:
• General Info: Information about the Auditee, Audit team, site characteristics and the Executive Summary
• G) General Code: Information about how the Auditee has incorporated the EICC Code • A) Labor: Labor practices findings • B) Health & Safety: Findings related to occupational health & safety policies, practices and
workplace conditions. • C) Environment: Audit findings on environmental practices. • D) Ethics: Findings related to business ethics policies and practices • E) Management Systems: Findings related to the Auditee’s systems and processes that support
sustained conformance with the Audit criteria and how it ensures that its suppliers do the same
Entering general site information, Audit findings and evidence into the above-‐listed worksheets will automatically generate an Audit score, summary (Dashboard) and Audit report.
9.1 Executive Summary
The “General” tab of the Audit Protocol contains a section to create an Executive Summary. Every report must include an executive summary that provides a concise, high-‐level summary of the major Audit findings only. The following is an example of an acceptable executive summary:
Executive summary
The Audit of Acme Cable Company evaluated the facility's labor, ethics, occupational health & safety and environmental practices, and supporting management systems against the EICC Audit criteria as contained in the EICC VAP Audit Protocol (version 4.0.1) and applicable laws and regulations.
The Audit took place from April 20 to April 23, 2012. 3 EICC VAP Auditors spend a total of 12 persondays onsite.
No exception management or integrity issues were encountered during the Audit.
The Audit findings are based on objective evidence gathered through management, staff and worker interviews, pertinent documents and records and workplace observations.
The findings include four (4) Major Nonconformances, one (1) Risk of Nonconformance and 12 Minor Nonconformances with the Audit criteria.
Summary of Major Findings:
• Labor • A3.1: Weekly working hours for 70 percent of the workers exceeded
the EICC limit in both peak and off-‐peak production months. The average number of hours worked per week for this group of workers ranged between 85 and 150 hours.
• Health and Safety • B2.2: The facility does not conduct fire evacuation drills in
Workshops A and C for the afternoon and night shifts.
• B6.3: None of the guide pulleys for the five wire drawing machines in Workshop A were provided with guarding to prevent inadvertent contact and injury to workers.
• Management System • D5.1: The facility established two labor objectives in January 2010
(reduce worker turnover and overtime). No goals or performance metrics were set for either objective, and facility management does not regularly track progress in achieving them.
9.2 Description of Findings
A finding statement must be provided in Column F for every Audit criteria question covered in the Audit. The questions are contained in the Audit Protocol worksheets: A) Labor, B) Health & Safety, C) Environment, D) Ethics and E) Management Systems. A concise statement is required for every finding: Priority, Major, Minor, Risk of Nonconformance, Not Applicable and Conformance. Keep the following in mind when writing findings statements:
• Be brief. Clearly state how the facility’s program or practice met or did not meet the Audit criteria. This should be done in no more than two or three sentences.
• State clearly the basis of the Nonconformance, such as the specific EICC Audit Criteria requirement. Alternatively, if it is against a law or regulation, this should be specified in the “Legal Reference” line of the “Description of Supporting Evidence” field (e.g. Safety & Work Regulations 2007 Sec 2.3).
• Do not enter a finding statement that simply re-‐states the Audit criteria question. For example, if the Audit question is “Do workers have a copy of their signed labor contract?” do not write a finding statement that reads “Workers have a copy of their signed labor contract.”
• Do not re-‐state the details of your supporting evidence in the finding statement. This will make the report easier to read and eliminates duplication of effort.
• Use the term “Nonconformance” in relation to findings against the EICC Audit Criteria. • Use the term “Non-‐compliance” when describing findings against legal requirements.
• Do not offer advice or recommendations in the findings statements. Ensure that findings are simply a clear description of the conformance or Nonconformance that will enable the facility to understand what needs to be improved.
• Refrain from the use of abbreviations where possible. If the abbreviation is used frequently then provide explanation when first used in the document e.g. Personal Protective Equipment (PPE).
• Do not state personal opinion or inference. For example, do not make statement such as: “in the Auditors opinion the contents of the self-‐Audit report are fine” or “the facility’s communication process seems adequate.”
• Do NOT leave any sections in the report blank. A “Description of Supporting Evidence” must be provided for ALL findings. Finding statements are required unless an Audit criteria question is not applicable to the supplier or if the question was not covered in the Audit scope. In these two cases, select either “Not Applicable” or “Not Reviewed in this Audit” from the dropdown list.
• If an area is not evaluated, the Auditor should state why the area was not subject to any form of verification. For example; Due to time constraints, this area could not be subject to any form of evaluation.”
• Provide details or evidence of documents that were withheld or not produced by the facility. If items were withheld during the Audit it is essential that this issue be discussed during the closing meeting.
• For detailed reporting requirements please see section 26
9.3 Description of Supporting Evidence
For every finding, Major, Minor, Risk of Nonconformance or Conformance, full but concise information for three independent data points must be provided to substantiate it. This is necessary to facilitate the development of an improvement plan. Also, if another Auditor has to re-‐visit the facility they will be able to more readily trace the process accurately.
All findings of Conformance and Nonconformance must be supported by corroborating data, entered in Column “Description of Supporting Evidence” (corroborating data must be provided as described in Section 8.4.1).
Each supporting evidence cell includes the following headings: • Data point 1: • Data point 2: • Data point 3: • Legal references:
• Supporting evidence reference(s):
The following is general guidance for entering supporting evidence: • Indicate clearly the type of information on which the data point is based, such as from
"document review" or "management interview" or "worker interview", or "observation during the factory tour," ....
• Data points from the same source of information (e.g. worker interviews in the same work area) should be combined together as a single data point, referencing the number of workers interviewed.
• Three independent data points (type or source) are required to support a finding, except as noted in Section 8.4.1.
• Indicate clearly the title and date of all documents and records reviewed ▬ Ideally, include a quote from the document to prove relevance to the question and
conformance status • Do not use references which could identify people if they are not part of the management
team – you violate Audit confidentiality and could put these people at risk • If there is a legal noncompliance: a legal reference is needed – title of law, article, year of
issue and quote from law specific to Nonconformance (add to “Legal References” line in the “Description of Supporting Evidence” column)
9.4 General Report Writing and Quality Guidelines
Keep the following in mind when writing reports:
• Data points cannot include opinions or subjective statements and judgments -‐ only facts and objective information
• No filler words or phrases should be used (e.g. “It was noted that…”) • Avoid words such as “....” -‐ lists need to be complete • Avoid words that have no added value (e.g. furthermore, in addition to, ....)
• If acronyms or abbreviations used – ensure they are stated in full first
• Use present or current tense, not past tense as the data reflects what existed on the day of the Audit
• Do not assume that reader of report is familiar with a country so please state local word or term used (even in Chinese characters), English term and definition or explanation
• When a question refers to testing or control, then always state what tests were done, if the person/company was competent, licensed, authorized, what the results were, trends and what action result from these -‐ this applies to Audit questions, control questions, drill questions, testing questions
• When a question or response mentions training then always state what training, who was trained, if trainer was competent, what the results of the training were -‐ if the training was effective (can trainees explain and implement what they were trained on) how the Auditor verified this
• Finding summary should be a summary based on all data points provided, not only based on a single data point & not a reporting. Need appropriate finding summary, which responds to the Audit question specifically & comprehensively.
• Thoroughly read the Audit questions, code instructions in comment box in E col., rating instruction in comment box in D column and headline details of each section to get an overview understanding of each section before giving responses in F & G and the rating in D col. to ensure the information provided comprehensively responds to the Audit questions & consistency.
• Do not indicate the names of the brands or third party Audit anywhere in the Audit report. Just need to indicate as "external Audits“
Ensure a high standard of internal quality assurance is applied to all completed reports. This includes: • Correct spelling and grammar, • All sections completed, • All applicable Audit questions answered,
• Consistency of findings from section to section (e.g. do findings in Risk Assessment or Audits and Assessments align with the findings in Machine Safeguarding?), and
• No information is included in the report that can identify a customer (Refer to Section 24 – “Intellectual Property Protection Requirements for Auditors”). All this should be undertaken before submission to the APM.
The APM will check the report for completeness, remove any customer references, and send to the Audited facility as a draft. The Audit team must work with the Audited facility to correct any factual errors in the draft report. This must be done within five business days of the Audited facility receiving the draft report.
Note: Refer to Audit Process Flow in Section 23
A final report will be sent to the Auditee within 4 calendar weeks of the Closing Meeting of Audit and will serve as the basis for Auditee management to create improvement plans.
10. Auditee Corrective Action Plan (CAP) Management
Correction of Audit Nonconformances will be addressed directly between the Audited facility and each customer or the APM in the case of the APM managed CAP. It is the responsibility of the Auditee’s management to prepare a “Corrective Action Plan” (CAP) to the Audit Report within 14 days of Auditee’s receipt of the Final Validated Audit Report (VAR). If Priority Nonconformances were found during the Audit, a CAP addressing those issues must be completed and submitted within 7 days of the discovery and confirmation of the Priority Nonconformance. The Auditee will be given the CAP template by the APM when the Priority finding is identified. The purpose of the response is to define corrective actions for resolving any Nonconformances identified during the Audit. The plan should be sent to customers and the APM and should detail:
• Determination of root cause(s), • Description of the proposed corrective action to address root cause(s)
Note: If facility management determines that no action will be taken or is necessary in response to a Nonconformance, the plan must describe the basis for this determination and why no corrective action is required.)
• Application of preventive action to prevent future recurrence of the problem or related issue, • The owner responsible for completion of the corrective and preventive action,
• The date the action is expected to be completed (see appropriate timelines based on significance of findings, below), and
• Current status of the action items.
With the Validated Audit Report (VAR) a pre-‐populated CAP will be issued by the APM. The CAP received from the APM will contain the Nonconformances identified in the Validated Audit.
The Auditee MUST use this template to complete their Corrective Action Plan.
10.1 CAP Management options
Current two options are available to manage the Validated Audit CAP process:
1. The Auditee manages the CAP directly with the individually customers. This is outside the scope of the EICC. However a copy of the approved CAP MUST be sent to the VAP APM. It is possible in this situation to have several CAP depending on the customers.
2. The CAP can be managed through the VAP APM. This will be a centrally managed process with only one EICC Validated CAP. The communication on the CAP and its progress will be managed by the APM with all customers listed in the “Auditee Approved Recipient distribution list”. Please see chapter 10.3 for more detail on this process.
10.2 Implementing Immediate Containment Actions for Priority Nonconformances
• Upon receiving notification of any Priority Nonconformance(s) from the Audit team, the Auditee reviews the Nonconformance(s) and initiates containment immediately. Containment is the act, process, or means of immediately reducing a threat or lowering a risk of the situation identified in the Priority Nonconformance(s).
• Priority Nonconformances must be contained within 48 hours of discovery • The following steps are taken to implement immediate containment
1. Auditor highlights Priority Nonconformance(s) to Auditee 2. Auditee investigates and defines needed containment activities and documents within the
EICC CAP template 3. Auditee implements containment actions so that the risk of the issue is minimized until a
permanent and systems solution is in place
10.3 APM managed CAP process
10.3.1 Roles and Responsibilities
• Auditee: • Immediately contain Nonconformances • Create Corrective Action Plan(s) and submit to APM
• Implement corrective and preventive actions for Priority, Major and Minor Nonconformances and Risks of Nonconformance
• Provide monthly progress updates to APM
• Schedule a Validated Closure Audit (in collaboration with Authorized Recipients) within EICC time frames (note: one Validated Closure Audit is possible to captured Major, Minor and Risk of Nonconformance actions. A Validated Closure Audit for Priority Nonconformances is always scheduled separately and always on-‐site)
• VAP APM:
• Communicate Priority Nonconformances to the Auditee’s Authorized Recipients within 48 hours of discovery.
• Define the type of validation required to close a corrective action (remote or on-‐site) • Review and provide format, completeness and Code elements gap feedback on CAP • Validate monthly progress on CAP implementation • Communicate CAP status monthly to Authorized Recipients • Manages Validated Closure Audit Process
• Authorized Recipient:
• Receive monthly CAP status reports from APM • Follow up with Auditee in case of delays of implementation • (In collaboration with Auditee) schedule a Validated Closure Audit.
10.3.2 Corrective Action Plan (CAP) Content
The Auditee must create a formal Corrective Action Plan that describes how and when the facility will address each of the identified Nonconformances and Risks of Nonconformance.
• Following containment of Priority Nonconformances(s), the Auditee develops a CAP for each Priority, Major, Minor and Risk of Nonconformance finding using the EICC CAP template.
• The CAP MUST reflect timelines described in section 10.4 or the Auditee must provide justification when timelines cannot be met.
• The CAP is documented in the CAP Worksheet, which is located in “CAP print” folder tab in the Excel Audit Protocol. Additional instructions are in the “Instructions to Auditee” workbook tab. The CAP Worksheet is created in Excel 2007 (.xlsx). For users of older versions of Excel, the Microsoft Office Compatibility Pack can be downloaded for free: http://www.microsoft.com/downloads/details.aspx?FamilyId=941B3470-‐3AE9-‐4AEE-‐8F43-‐C6BB74CD1466&displaylang=en. The compatibility pack will allow the user to open, edit and save documents that are in Office 2007 (or newer).
• The Auditee must complete the light-‐blue shaded areas of the CAP template. The other areas of the CAP Worksheet are automatically populated as part of the Validated Audit Report generation process.
• All CAP activities and modifications are monitored, reviewed, agreed to and closed through the CAP Worksheet. The Auditee develops corrective actions (CA) and records them in the CAP Worksheet. APM will review each CAP to ensure that it contains required information, correct format and that corrective actions are appropriate, clearly defined and within the timeline.
• After the CAP is fully implemented, the Auditee must provide a final update in the CAP template indicating the finding was addressed, the completion date, and provide appropriate supporting evidence.
10.3.2.1 Corrective Action Plan (CAP) Step 1 – Root Cause Analysis
• The first step in the CAP process is to conduct a root cause analysis for each Nonconformance.
• “Root Cause Analysis” is a method used to get to the underlying cause(s) of a Nonconformance. It is used to correct or eliminate the cause, and prevent the problem from recurring. If a root cause analysis is not conducted, or conducted poorly, there is a risk that time and resources will be wasted addressing the symptoms of a problem, rather than addressing the real issue.
• The most common element of a root cause analysis includes asking “why a particular Nonconformance occurred?” and documenting the answer. Then for each answer, asking “why?” again and again, until the desired goal of finding the “root causes” is reached. Normal practice indicates that a root cause is identified after 5 Why questions.
• When considering “why” a particular problem occurred, it might be useful to consider the following potential elements to ensure comprehensive analysis:
1) Knowledge – did the problem occur due to lack of awareness or knowledge?
2) Assignment – did the problem occur because responsibility was not clearly assigned?
3) Tools – did the problem occur because appropriate tools are not available?
4) Training – did the problem occur due to lack of proper training?
5) Accountability – did the problem occur because little/no accountability e.g. in typical situation nothing happens when the task is not done
6) Resources – did the problem occur due to insufficient resources
• The CAP Worksheet provides space for three root causes per Nonconformance. Auditee may add or remove root cause entries as appropriate to their needs. However at least 1 root cause is required. No more than 5 root causes will be allowed.
• For each root cause a corresponding containment and corrective action are needed. Example: if a finding has 3 identified root causes then 3 containment actions and 3 corrective actions are needed in the CAP for the finding, each with timeline, …
• It is possible that several findings have the same root cause(s). In this case the finding with same root cause can refer to the “other” finding where the corrective and containment actions have been defined.
• The corrective action to a root cause is mostly a management systems (procedural change)
The items below need to be submitted for each root cause identified per finding!
• Describe action to be taken to immediately reduce threat/lower risk: Describe the temporary actions taken to minimize the risk of the Nonconformance. The description needs to include at least the following components:
- Actions taken - Communication to management, supervisors and workers on these actions - Inspection program of the actions to ensure they remain in place and are effective
until a permanent systems correction is implemented • Accountable Owner: person(s) responsible at the Auditee site to ensure overall
effective implementation of the Immediate Containment Actions
• Target Completion Date: Completion date of the initial implementation of all items listed under “Describe action to be taken to immediately reduce threat/lower risk”. This can be no longer than 3 weeks from receipt of final VAR
• Progress (on or off track): listed as - “on” if on time or fully implemented or - “off” when implementation is running late. If off then additional actions need to be
listed in remarks how implementation will be corrected to within the timeline “Target Completion Date”
• Actual close date: Actual date when all items listed under “Describe action to be taken to immediately reduce threat/lower risk” is successfully implemented. Proof in PDF or JPEG files need to be provide for APM decision.
10.3.2.3 Corrective Action Plan (CAP) Step 2 – Corrective Action
The items below need to be submitted for each root cause identified per finding!
• "Describe action plan -‐ it should contain details on”
- 1.Policy/procedure changes: Describe the details of the changes, which will be made to company policy/procedures (mention the current document reference number and issue date). The updated policy should contain at least:
1. All items as listed under “minimum requirements – document review” (see section 12 for the relevant Conformance Statement).
2. (Or refer to) the internal inspection/verification methods which will be used post implementation of the updated policy
- 2.Communications/training: Describe the details of the communications and training program to ensure all people active within the facility are updated and understand the updated policy and procedures. This communication and training needs to ensure all can effectively implement and adhere to the updated policy/procedure. This needs to include at least:
1. Communication detail and medium (meeting, bulletin board, mail, …) to 1. Management 2. Staff 3. Direct and indirect workers 4. Onsite contractors suppliers 5. Other affected or impacted groups
2. Training material 1. Management 2. Supervisors 3. Workers 4. Other affected or impacted groups 5. Induction or new employee training
- 3. Activity and impact measurements": Describe the indicators/measurements that will be used to monitor and ensure that the implementation of the updated policy/procedure and its communications and training is effective. Measurement
should be impact and activity based (e.g. number of trainings = activity, awareness or reduction in occurrence = impact) At least 3 activities and 3 impact indicators are required.
• Accountable Owner: person(s) responsible at the Auditee site to ensure overall effective implementation of the Corrective Actions
• Target Completion Date: Completion date of the implementation of each items listed under “Describe action plan -‐ it should contain details on”. This can exceeded the timing as indicated in section 10.4. If the Action exceeded this timing then a justification needs to be submitted to the APM for approval of exceeding this timeline
• Remote?: Means remote verification. Yes means closure can happen by submitting documents for closure review. No means the EICC VAP auditors have to return to the Auditee to verify closure. This will be determined by the APM. See definitions for remote and on site Validated Closure Audit
• Progress (on or off track): listed as - “On” if on time or fully implemented or - “Off” when implementation is running late. If off then additional actions need to be
listed in remarks how implementation will be corrected to within the timeline “Target Completion Date”
• Action Start Date: Proposed start date for each item listed under “Describe action plan -‐ it should contain details on”
• Actual Close Date: Actual dates for each item listed under “Describe action plan -‐ it should contain details on” are successfully implemented. Proof in PDF or JPEG files need to be provide for APM decision.
10.4 Timelines for Completion of Corrective Actions:
All Corrective Actions must be completed within the timeframes provided below. Any deviations from the prescribed timelines must be approved by the APM. • Containment action must be implemented immediately for any “Priority” Nonconformances,
including child labor, forced labor, and imminent danger to workers or imminent threats to the environment and surrounding community. The Audit team must encourage the facility to contain such issues during the Audit. Corrective and preventive actions (to fully correct the issue and prevent a recurrence of a similar issue) must be implemented within 30 days.
Note: Any Nonconformance which has immediate impact of life, limb, environment or facility, even not classified as “Priority” Nonconformance, should have immediate containment actions to minimize the risk, e.g. a locked emergency evacuation door should be immediately unlocked upon discovery.
• Major Nonconformances: the facility must correct, when feasible, all Major Nonconformances within 90 days of receiving the final Audit report.
• In situations where Auditee believes the Nonconformance will take significantly longer than 90 days to correct the Auditee must propose a detailed timeline with deliverables along the way (not all near the end). The timeline proposed must demonstrate urgency to resolve the Nonconformance that will be reviewed by the APM.
• Failure to correct a previously identified Major Nonconformance: the facility must take substantial action to correct such Major Nonconformances within 30 days of receiving the final Audit report
• Minor Nonconformances: the facility must correct all Minor Nonconformances within 270 days of receiving the final Audit report.
Finding Submit CAP Approved CAP Complete CAP
Priority(1) 1 week from discovery 10 calendar days from discovery
30 days from discovery
Major 2 weeks from receipt of final VAR
6 weeks from receipt of final VAR
90 days from receipt of final VAR
Minor 2 weeks from receipt of final VAR
6 weeks from receipt of final VAR
270 days from receipt of final VAR
Risk of Nonconformance
2 weeks from receipt of final VAR
6 weeks from receipt of final VAR
270 days from receipt of final VAR
(1) Priority Nonconformances must be contained within 48 hours of notification.
10.4.1 Process steps and Timing of APM managed CAP process
The following steps, timelines and process applies to the APM managed CAP process
10.4.1.1 Priority Nonconformance
Time Action Responsible 0 Days • Discovery of Priority Nonconformance
• Communicate and agree with Auditee • Communicate to APM • Communicate to Authorized Recipients
• Audit team • Audit team • Audit team • Auditee/APM
2 days • Priority Nonconformance action in place • Communicate containment action and proof of
implementation to Authorized Recipients/APM
• Auditee • Auditee
7 days • Full CAP on Priority Nonconformance(s) is submitted for review to APM
• Feedback on Priority Nonconformance CAP • Adjust Priority Nonconformance CAP if needed
• Auditee • APM • Auditee
10 days • Approved Priority Nonconformance CAP implementation
• Communicate Priority Nonconformance CAP to Authorized Recipients
• Auditee • Auditee/APM
17 days • Submit proof of Priority Nonconformance CAP
implementation progress to APM • Review of Priority Nonconformance CAP
implementation progress • Communicate Priority Nonconformance CAP
implementation Status to Authorized Recipients
• Auditee • APM • Auditee/APM
24 days • Submit proof of Priority Nonconformance CAP implementation progress to APM
• Review of Priority Nonconformance CAP implementation progress
• Communicate Priority Nonconformance CAP implementation Status to Authorized Recipients
• Auditee • APM • Auditee/APM
30 days • Validated Closure Audit of Priority Nonconformance(s)
• APM
10.4.1.2 Major, Minor and Risk of Nonconformance
Time Action Responsible 0 weeks • Receipt of final VAR and CAP template pre-‐
populated • APM
2 weeks • Submit completed CAP version 1 • Review and provide feedback on CAP version
1 within 48h or approve CAP • Communicate CAP status to Authorized
Recipients
• Auditee • APM • APM
4 weeks • Submit completed CAP version 2 • Review and provide feedback on CAP version
2 within 48h or approve CAP • Communicate CAP status to Authorized
Recipients
• Auditee • APM • APM
6 weeks • Submit completed CAP version 3 • Review and provide feedback on CAP version
3 within 48h or approve CAP version 3 • Communicate CAP status to Authorized
Recipients Note if version 3 not approved then process ends
• Auditee • APM • APM
1 month from CAP approval and every following month until CAP completed or month 11
• Provide monthly update of Nonconformance CAP implementation progress to APM
• Submit proof for each Nonconformance CAP implementation which has been completed
• Review of Nonconformance CAP implementation progress
• Communicate Nonconformance CAP implementation Status to Authorized
• Auditee • Auditee • APM • APM
Recipients CAP implementation completed or 12 months after close meeting
• Validated Closure Audit process management • APM
10.4.1.3 Escalation to Authorized Recipient
The Authorized Recipient will be informed by the APM as soon as there is a delay in submission of one week. The Authorized Recipient can follow up with Auditee and facilitate (if needed) timely submission of CAP or implementation updates. The “late” notification will be repeated to the Authorized Recipient until receipt of CAP or implementation update is received on a weekly basis.
The Authorized Recipient will be informed by the APM if the CAP implementation status varies by more than 20 percent versus agreed CAP implementation due date or EICC CAP timeline.
10.5 Approval of Corrective Actions
Approval must be obtained after the Corrective Action Plan (CAP) has been submitted to the APM and after individual corrective actions have been implemented.
• The Corrective Action Plan must be approved by the APM before any corrective actions are implemented.
• APM should review and approve the CAP for all Nonconformances within 3 days.
• All corrective actions must be reviewed and approved by the APM before they can be closed. The objective of obtaining APM approval is to ensure completeness of CAP, completeness of implementation, use of correct EICC format. It is not an approval or statement of conformance. Conformance can only be determined by the qualified third party Audit firm upon detailed review (remote or off site).
• Corrective actions cannot be approved until the Auditee provides a completed CAP and proof of implementation.
10.6 Monitoring Progress
• For CAPs with implementation periods greater than 30 days, Auditees must provide VAP APM with status updates at monthly intervals. It is the responsibility of the Auditee to submit this to the APM
• Once the Auditee believes the CAP has been fully implemented, the Auditee must provide a final status update indicating the Nonconformance has been addressed and provide the appropriate evidence supporting this position.
- The evidence must be provided in either PDF or JPEG format. Any other format will not be accepted. The evidence needs to have the correct references in the CAP template to allow easy navigation between CAP template and proof of implementation.
• If the Corrective Action has not been closed in the time specified in the CAP or the Corrective Action is inappropriate, the Auditee has to indicate in the CAP Worksheet status report a proposal to address the issue.
• Any changes to the approved CAP will have to be reviewed and approved by the VAP APM.
10.7 Closing Corrective Actions
• The VAP APM will review the information provided by the Auditee in support of the CAP implementation to verify closure of each Corrective Action.
• If the VAP APM requires additional information, the Auditee will make the immediately available.
• The supporting documents must provide relevant information as evidence of the actions listed in the CAP. Only PDF and JPEG files will be accepted.
• The APM determines the type of validation required for finding closure.
• Upon reviewing the information provided by the Auditee, the VAP APM will agree or disagree with the closure of the corrective actions implementation. It is not an approval or statement of conformance. Conformance can only be determined by the qualified third party Audit firm upon detailed review (remote or off site).
• The VAP APM will schedule a Validated Closure Audit for all Corrective Actions.
• The CAP is deemed closed upon verification by Validated Closure Audit of all individual Corrective Action(s) as listed in the CAP.
11. ELECTRONIC INDUSTRY CITIZENSHIP COALITION® CODE OF CONDUCT (Version 4.0 -‐ 2012)
��The Electronic Industry Citizenship Coalition® (EICC®) Code of Conduct establishes standards to ensure that working conditions in the electronics industry supply chain are safe, that workers are treated with respect and dignity, and that business operations are environmentally responsible and conducted ethically. Considered as part of the electronics industry for purposes of this Code are all organization that may design, market, manufacture or provide goods and services that are used to produce electronic goods. The Code may be voluntarily adopted by any business in the electronics sector and subsequently applied by that business to its supply chain and subcontractors, including providers of contract labor Considered as part of the electronics industry for purposes of this Code are all organizations that may design, market, manufacture or provide goods and services that are used to produce electronic goods. The Code may be voluntarily adopted by any business in the electronics sector and subsequently applied by that business to its supply chain and subcontractors, including providers of contract labor. To adopt the Code and become a participant (“Participant”), a business shall declare its support for the Code and actively pursue conformance to the Code and its standards in accordance with a management system as herein. Participants must regard the Code as a total supply chain initiative. At a minimum, Participants shall also require its next tier suppliers to acknowledge and implement the Code. Fundamental to adopting the Code is the understanding that a business, in all of its activities, must operate in full compliance with the laws, rules and regulations of the countries in which it operates.1 The Code encourages Participants to go beyond legal compliance, drawing upon internationally recognized standards, in order to advance social and environmental responsibility and business ethics. The EICC is committed to obtaining regular input from stakeholders in the continued development and implementation of the Code of Conduct. The Code is made up of five sections. Sections A, B, and C outline standards for Labor, Health and Safety, and the Environment, respectively. Section D adds standards relating to business ethics; Section E outlines the elements of an acceptable system to manage conformity to this Code.
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1The Code is not intended to create new and additional third party rights, including for workers
A. LABOR
Participants are committed to uphold the human rights of workers, and to treat them with dignity and respect as understood by the international community. This applies to all workers including temporary, migrant, student, contract, direct employees, and any other type of worker. The recognized standards, as set out in the annex, were used as references in preparing the Code and may be a useful source of additional information. The labor standards are:
1) Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labor, involuntary prison labor, slavery or trafficking of persons shall not to be used. This includes transporting, harboring, recruiting, transferring or receiving vulnerable persons by means of threat, force, coercion, abduction or fraud for the purpose of exploitation. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Workers must not be required to surrender any government-‐issued identification, passports, or work permits as a condition of employment. Excessive fees are unacceptable and all fees charged to workers must be disclosed.
2) Child Labor Avoidance Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the health or safety of young workers.
3) Working Hours Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off per seven-‐day week.
4) Wages and Benefits Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.
5) Humane Treatment There is to be no harsh and inhumane treatment including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.
6) Non-‐Discrimination Participants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation,
ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.
7) Freedom of Association Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. The rights of workers to associate freely, join or not join labor unions, seek representation, and join workers’ councils in accordance with local laws shall be respected. Workers shall be able to openly communicate and share grievances with management regarding working conditions and management practices without fear of reprisal, intimidation or harassment.
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��B. HEALTH and SAFETY
Participants recognize that in addition to minimizing the incidence of work-‐related injury and illness, a safe and healthy work environment enhances the quality of products and services, consistency of production and worker retention and morale. Participants also recognize that ongoing worker input and education is essential to identifying and solving health and safety issues in the workplace. Recognized management systems such as OHSAS 18001 and ILO Guidelines on Occupational Safety and Health were used as references in preparing the Code and may be a useful source of additional information. The health and safety standards are: 1) Occupational Safety
Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tagout), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-‐maintained, personal protective equipment. Workers shall not be disciplined for raising safety concerns.
2) Emergency Preparedness Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.
3) Occupational Injury and Illness Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness including provisions to: encourage worker reporting; classify and record injury and illness cases; provide necessary medical treatment; investigate cases and implement corrective actions to eliminate their causes; and facilitate return of workers to work.
4) Industrial Hygiene Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. Engineering or administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is to be protected by appropriate personal protective equipment programs.
5) Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.
6) Machine Safeguarding Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.
7) Sanitation, Food, and Housing Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the Participant or a labor agent are to be maintained to be clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, adequate heat and ventilation, and reasonable personal space along with reasonable entry and exit privileges.
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��C. ENVIRONMENTAL
Participants recognize that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public. Recognized management systems such as ISO 14001 and the Eco Management and Audit System (EMAS) were used as references in preparing the Code and may be a useful source of additional information. The environmental standards are: 1) Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.
2) Pollution Prevention and Resource Reduction Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-‐using materials.
3) Hazardous Substances Chemicals and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
4) Wastewater and Solid Waste Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be characterized, monitored, controlled and treated as required prior to discharge or disposal.
5) Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-‐products generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge.
6) Product Content Restrictions Participants are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances, including labeling for recycling and disposal.
���D. ETHICS
To meet social responsibilities and to achieve success in the marketplace, Participants and their agents are to uphold the highest standards of ethics including: 1) Business Integrity
The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement (covering promising, offering, giving or accepting any bribes). All business dealings should be transparently performed and accurately reflected on Participant’s business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-‐corruption laws.
2) No Improper Advantage Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.
3) Disclosure of Information Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.
4) Intellectual Property Intellectual property rights are to be respected; transfer of technology and know-‐how is to be done in a manner that protects intellectual property rights.
5) Fair Business, Advertising and Competition Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must be available.
6) Protection of Identity Programs that ensure the confidentiality and protection of supplier and employee whistleblower2 are to be maintained.
7) Responsible Sourcing of Minerals Participants shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Participants shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to customers upon customer request.
8) Privacy
Participants are to commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including suppliers, customers, consumers and employees. Participants are to comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared. 2 Whistleblower definition: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official body.
9) Non-‐Retaliation Participants should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.
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��E. MANAGEMENT SYSTEM
Participants shall adopt or establish a management system whose scope is related to the content of this Code. The management system shall be designed to ensure: (a) compliance with applicable laws, regulations and customer requirements related to the participant’s operations and products; (b) conformance with this Code; and (c) identification and mitigation of operational risks related to this Code. It should also facilitate continual improvement. The management system should contain the following elements: 1) Company Commitment
A corporate social and environmental responsibility policy statements affirming Participant’s commitment to compliance and continual improvement, endorsed by executive management.
2) Management Accountability and Responsibility The Participant clearly identifies company representative[s] responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.
3) Legal and Customer Requirements A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.
4) Risk Assessment and Risk Management A process to identify the environmental, health and safety3 and labor practice and ethics risks associated with Participant’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
5) Improvement Objectives Written performance objectives, targets and implementation plans to improve the Participant’s social and environmental performance, including a periodic assessment of Participant’s performance in achieving those objectives.
6) Training Programs for training managers and workers to implement Participant’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.
7) Communication
A process for communicating clear and accurate information about Participant’s policies, practices, expectations and performance to workers, suppliers and customers.
8) Worker Feedback and Participation Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement. 3 Areas to be included in a risk assessment for environmental health and safety are production areas, warehouse and storage facilities, plant/facilities support equipment, laboratories and test areas, sanitation facilities (bathrooms), kitchen/cafeteria and worker housing/dormitories.
9) ��Audits and Assessments Periodic self-‐evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.
10) Corrective Action Process A process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
11) Documentation and Records Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
12) Supplier Responsibility A process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.
��REFERENCES
The following standards were used in preparing this Code and may be a useful source of additional information. The following standards may or may not be endorsed by each Participant.
• Dodd-‐Frank Wall Street Reform and Consumer Protection Act: http://www.sec.gov/about/laws/wallstreetreform-‐cpa.pdf
• Eco Management & Audit System: www.quality.co.uk/emas.htm • Ethical Trading Initiative: www.ethicaltrade.org/ • ILO Code of Practice in Safety and Health:
www.ilo.org/public/english/protection/safework/cops/english/download/e000013.pdf • ILO International Labor Standards:
www.ilo.org/public/english/standards/norm/whatare/fundam/index.htm • ISO 14001: www.iso.org • National Fire Protection Agency: www.nfpa.org/catalog/home/AboutNFPA/index.asp • OECD Due Diligence Guidance:
http://www.oecd.org/document/36/0,3746,en_2649_34889_44307940_1_1_1_1,00.html • OECD Guidelines for Multinational Enterprises: www.oecd.org
• OHSAS 18001: www.bsi-‐global.com/index.xalter • Universal Declaration of Human Rights: www.un.org/Overview/rights.html • United Nations Convention Against Corruption:
www.unodc.org/unodc/en/crime_convention_corruption.html • United Nations Global Compact: www.unglobalcompact.org • SA 8000: www.cepaa.org/ • SAI: www.sa-‐intl.org
���������� �� DOCUMENT HISTORY
• Version 1.0 -‐ Released October 2004. • Version 1.1 -‐ Released May 2005. Converted document to EICC format, minor page layout revisions;
no content changes. • Version 2.0 -‐ Released October 2005 with revisions to multiple provisions. • Version 3.0 – Released June 2009 with revisions to multiple provisions. • Version 4.0 – Released April 2012 with revisions to multiple provisions.
The EICC Code of Conduct was initially developed by a number of companies engaged in the manufacture of electronics products between June and October 2004. Companies are invited and encouraged to adopt this Code. You may obtain additional information from www.eicc.info. ��
12. EICC Code Interpretation Guidance
This section details the Provision of the EICC code (v4.0 -‐ 2012). The provisions define the EICC requirements to which the Auditee needs to conform. The requirements are specified in a similar format as audit information techniques: site observation, document review, management knowledge and understanding and worker awareness and understanding. Note: All communications from Auditee to workers must be in a language easily understood by the worker. If this is not the case than the relevant aspect is a Major nonconformance. All conformance statements apply to all workers, including temporary, migrant, student and contract, direct and indirect employed workers that work in the factory/on production/in warehouse and any other type of worker/employee. Unless the conformance statement specifically states a narrower focus group, e.g. A5.4 Managers and supervisors are adequately trained on appropriate disciplinary measures/procedures, D6.2 A way to confidentially report suspected ethical misconduct is available to employees of suppliers and protects them from retaliation or other consequences
Note : If the Auditee facility or corporate policy or the Collective Bargaining Agreement are in place, comply with legal requirements but are more strict than either EiCC Code of Conduct or the legal/customer requirements, then if practice is in conformance with legal/customer/code requirements but not Auditee’s own policy or Collective Bargaining Agreement the conclusion in Nonconform
G. GENERAL CODE
G1 Electronic Industry Code of Conduct G1.1 Management demonstrates a good understanding of and commitment to the EICC Code of
Conduct/requirements, has integrated the EICC code/requirements into facility procedures and communicated this effectively to all levels of employees and workers.
Minimum requirements: • Site observation: EICC code (last version) or the Company/Facility code, which directly
references and/or incorporates the EICC Code, is displayed in workplace in local language or workers have easy access to it.
• Document review: Documented procedure(s) on implementation of EICC code are available and training materials are up to date for all staff and workers
• Management interview: Management understands the code and its provisions and has adjusted their management system to align with the EICC code. Training is delivered on EICC and its provision (Auditee procedures) at least for all new hires and on a regular basis
• Worker interview: Workers state that they have been trained at hire or within last year on EICC code and the relevant procedures of the EICC code section implementation
Rating: • Priority: Not applicable • Major: (default) Management does not understand the code AND has not implemented the
code by integrating the code provisions into its existing procedures and training • Minor: Management understand the code and has implemented the code provisions into its
existing procedures but not trained staff and workers on a regular basis • Not Applicable: Not applicable Remote verification: Yes
A. LABOR A1 Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labor; involuntary prison labor; slavery or trafficking of persons shall not to be used. This includes transporting, harboring, recruiting, transferring or receiving vulnerable persons by means of threat, force, coercion, abduction or fraud for the purpose of exploitation. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Workers must not be required to surrender any government-‐issued identification, passports, or work permits as a condition of employment. Excessive fees are unacceptable and all fees charged to workers must be disclosed.
A1.1 Any type of forced, prison, indentured, or bonded (including debt bondage) labor is not used
Minimum requirements: Site observation: There are no visible restrictions with regard to freedom of movement within the site or to leave the site. If workers reside on site then no visible restriction on freedom of movement are present. Document review: Clear policy or procedures are in place to prohibit forced labor, bonded or indentured labor. Hiring practices, and those of any labor agencies/recruiters, must prohibit forced or bonded labor. The Supplier should establish a written set of instructions for all subcontractors and labor recruiters that prohibit forced labor. The supplier should have a documented process to actively verify compliance with these requirements. All fees are disclosed to the workers and documentation on fee disclosure and actual fees for the workers at the Auditee is complete, available and compliant with the provisions of the EICC code. Management interview: Management can state that the facility does not keep workers' original ID or documents, no deposit or retain of salary is required, workers could quit their job upon legal notice period, workers are free to leave facility premises after work, what fees, if any, workers pay and how these are documented and conform with the provisions of the EICC code. Under no circumstances shall fees be Excessive fees. Worker interview: Interviewed workers state: When they start working in Auditee, can explain how they got this job, especially the steps the company took (advertisement, friend, relative, labor agency, broker), what fee if any they were required to pay, what deduction are made from monthly wages to repay a loan, when they can leave the job. If any fee was required, workers can confirm that they were informed about the fee(s) before any commitment was made. Rating:
Priority: Any form of forced, bonded or indentured labor is confirmed at the Auditee or was confirmed within the last 6 months Major:(default): No policies or procedures in place for direct or requirements to subcontractors and labor agents Minor: Documented policies and procedures are in place to prohibit forced, bonded or indentured labor including for subcontracting and labor agents, no documented process to actively verify compliance with these requirements Not Applicable: Not applicable
Remote verification: No
A1.2 Adequate and effective policy and procedures are established against slavery and human trafficking ensuring that any form of forced, bonded or involuntary prison labor is not used.
Minimum requirements: Site observation: Not Applicable Document review: Clear policy or procedures are in place on no slavery and anti human trafficking including training or communication of all employees and workers, suppliers and labor agents/contractors, monitoring of compliance with policy and correction if identified during monitoring. Reports of monitoring and corrective actions (if applicable) are available Management interview: Management can state states that the detail of the no slavery and anti trafficking policy/procedures, how they monitor adherence to the policy and what corrective action they have made if needed. Worker interview: Interviewed workers can state: training or communications on “No slavery and human trafficking” has occurred and can explain what no slavery and anti -‐ trafficking means. Rating: Priority: Not applicable Major:(default): No policy procedure, monitoring, training or communications or corrective actions are in place on no slavery or anti trafficking Minor: Policy and procedures are in place but one of the implementation components is missing (training or communications, monitoring, correction) Not Applicable: Not applicable Remote verification: No
A1.3 Workers are informed in writing and in their own language prior to employment (in case of migrant workers, before they leave their home country/region) of the key employment terms and conditions via employment letter/agreement/contract as required by law
Minimum requirements: Site observation: Not applicable Document review: Workers are informed prior to employment (in case of migrant workers, before they leave their home country/region) of the key employment terms and conditions either verbally or in writing via employment letter/agreement/contract as required by law in their local language. The minimum components of this information is: nature of work, working hours, wages, leave entitlements, benefits (housing, transportation, uniforms,...) , what components the worker will be charged for and the amount, other benefits provided (pension, insurances, ...), wage deductions. The conditions on employment for worker comply with the relevant ILO conventions and law. If labor agents/contractors or subcontractors/agents are used then agreements need to be in place detailing that these organizations need to comply with the requirements applicable to the worker in their operations. Management interview: Management can state which labor agents they use and what contractual requirements are in place to ensure compliance with this requirement. What the requirements are which have been implemented to conformance to the policy/procedures. Worker interview: Workers can state when they were informed about the terms and conditions of employment, how this was communicated and what the terms and conditions are, if the current terms and conditions are the same as when informed (if there is a difference what the difference is and why) Rating: Priority: Not Applicable Major: (default): No information about employment terms of conditions is communicated to workers (direct or via labor agents/contractors) or no contracts are in place with labor agents/contractor. Minor: Employment terms and conditions are communicated AND contracts are in place with labor agent/contractor but are incomplete Not Applicable: Contracts are not legally required.
Remote verification: Yes
A1.4 Upon hiring, the workers government issued identification and personal documentation originals are not withheld by employer/labor agent/contractor (if applicable) without formal consent.
Minimum requirements: Site observation: Not Applicable Document review: A policy or procedure is place stating no government issued identification or person documents originals are held unless at the workers’ request. Worker files contain no workers' personal documentation originals (e.g. passport; work visa/permit; citizenship, residence, identification, social security/insurance cards/documents; birth certificate; bank documents; ...). If government-‐issued identification, passports or work permits are held from the worker at their request. Procedures are in place for safe keeping of government-‐issued identification, passports or work permits with worker having access at all times at the discretion of the worker within 12 hours. There shall be no fee for the safe keeping of government-‐issued identification, passports or work permits. In some countries, local law places the responsibility of foreign workers' immigration status (legal/illegal) in the hands of the employer. This is done not to restrict the worker but to ensure that if the worker does terminate employment they go back to their country of origin as required by local law and not become illegal workers in the country. In all cases, this should be done with the full knowledge, permission and participation of the worker. Management interview: Management can state the detail of the policy on worker document keeping and if workers are kept what process is in place to ensure the voluntary nature of the document safe keeping and how workers are guaranteed access to their documents within 12 h Worker interview: Workers can show their personal documents or workers can state that no personal documents are kept or if some documents are kept which documents are kept, how they agreed for document safe keeping an how they can access their own documents within 12 h. What are the rules, policies and procedures for getting personal documents back? Rating: Priority: Not Applicable Major:(default): Personal documents are kept; personal files have original personal documents and no policy for document safekeeping and worker access to their documents Minor: A document safe keeping policy and procedures are in place but workers cannot access their documents in safe keeping within 12 h Not Applicable: Not Applicable
Remote verification: No
A1.5 Workers are free to leave their employment upon giving reasonable notice, with no penalty.
Minimum requirements: Site observation: Not Applicable Document review: Contracts, worker handbook or training materials state workers can resign within the local law without penalty (no threat of punishment, fines, violence, or withholding wages). This is applicable for direct and indirect employment workers. Inquire into the existence of labor contracts that a hiring agent may use to limit the workers’ ability to voluntarily terminate their employment. The policy and procedure state that when if employment has been terminated voluntarily or involuntarily, worker will be paid appropriate amounts for all hours worked. If indirect employed workers are used this requirements needs to be reflected in the agreement with the labor agents/contractor. Leave records reviewed shows conformance with law and procedure/policy Management interview: Management can state the detail of the "no penalty" details of worker voluntary employment termination. If labor agents/contractors are used what agreement requirements are in place to ensure conformance with the policy/procedure on "no penalty voluntary worker leave" Worker interview: Worker state that they can leave within the legal defined time frame when voluntary leaving employment with penalty (no threat of punishment, fines, violence, or withholding wages). Workers have been trained on the procedure and conditions of "no penalty voluntary employment termination". For indirect employed workers they should be able to state the same. Rating: Priority: Not Applicable Major:(default): No policy on "no penalty voluntary employment worker" termination, policy does comply with local law; workers are penalized for voluntary leave or are restricted from voluntary employment termination. Minor: Not Applicable Not Applicable: Not Applicable
Remote verification: No
A1.6 Workers are not required to pay fees, deposits or debt repayments for their employment
Minimum requirements: Site observation: Not Applicable Document review: Policy/procedure clearly state that workers are not required pay fees, deposits or incur debt as part of the employment (either as one-‐time or installment payments, collected directly or through wage deductions). Worker payroll and wage payment show conformance with this requirement. If any costs and fees to workers are deducted then these conform with legal requirements, actual incurred services (local taxes and insurance, and agreed-‐upon fees for meals, lodging, ...) or good practice personal assistance (e.g. personal loans with a cap of max 10 percent monthly wage repayment at national set interest rate or better for a maximum of 6 months). Under no circumstances shall fees be Excessive fees. Management interview: Management can state the detail of the policy/procedure that pay fees, deposits or incur debt as part of the employment (either as one-‐time or installment payments,
collected directly or through wage deductions) are required. Detail the deduction from workers and how this relates to services incurred or legal requirements (insurance). Worker interview: Workers can state that they are not required to pay off any indebtedness -‐ such as a deposit or employment fee -‐ to the facility or employment agency, any deduction are legal and for services incurred or that any personal loan scheme has repayment of less than 10 percent of wage per month and at national interest level or better. Rating: Priority: Not Applicable Major: A policy is in place but a debt, deposit or repayment (for personal loans higher than 10 percent per month) is required from workers Minor: (default): No policy or procedure in place and no repayment, fees, deposits or debt of any kind Not Applicable: Not Applicable
Remote verification: No
A1.7 There are no unreasonable restrictions on the movement of workers and their access to basic liberties
Minimum requirements: Site observation: If workers reside on site (dormitory), gates or access to dormitory is open or there are no restrictions through procedure or undue security guard restrictions. Workers move freely when needed to access basic liberties. There are no systems for restriction in place such as toilet passes. Document review: Policy/procedures on freedom of movement are in place. Workers should be free to leave the supplier location or dormitory when not engaged in work. Entry and leave records (if applicable) show no restriction in movement (e.g. toilets, drinking water, external medical facilities, factory/dormitory exit and entry). Management interview: Management can state how workers can move freely within the facility on basic liberties and move to and from workplace to/from dormitory when not engaged in work. Worker interview: Worker state that there are no restrictions on movement for basic liberties and to/from dormitory when not engaged in work. Access to such basic liberties should also not be limited to specific times of day. Rating: Priority: Not Applicable Major: Workers are restricted from movement through threat or penalty, even if a policy is in place Minor: (default): No policy or procedures are in place on freedom of movement but there are no restrictions on freedom of movement. If no coercive restrictions systems/procedures are used (e.g. toilet passes) Not Applicable: Not applicable Remote verification: No
A1.8 All relevant labor requirements of the EICC Code/requirements are clearly communicated to labor agents/contractors, and they are monitored/Audited to verify conformance.
Minimum requirements: Site observation: Not applicable Document review: Contract with labor agents/contractors contain language that require all relevant labor requirements of the EICC Code (covering at a minimum child labor prohibition, freely chosen employment, recruitment/service charges, wages, benefits, non discrimination, freedom of association) and comply with labor law in both home and sending country. A documented verification system for labor agents/contractors is in place. Audit reports and resulting corrective actions are available for review. Verification that labor agent/ contractor meets the requirements on freely chosen employment (same requirements as placed on facility plus local law in home and sending countries/regions) is verified through Audits Management interview: Management can state the detail of the program to communicate and verify conformance with the relevant EICC Code requirements are communicated and verified with their labor agents/contractors and what corrective actions are requested for labor agents/contractors not meeting the requirements. Worker interview: Workers employed through labor agents/contractors can state that their employments terms and conditions meets the EICC code requirements and that they have been informed/trained about EICC code requirements. Rating: Priority: Not Applicable Major:(default): No labor agent/contractor requirements process/communication in place or verification mechanism in place to verify conformance to the EICC code requirements Minor: Labor agent/contractor requirements process/communication in place and verification mechanism in place to verify conformance to the EICC code requirements, however EICC code requirements not complete or corrective actions not implemented/completed Not Applicable: No labor agent/contractor used Remote verification: No
A1.9 Recruitment practices and performance are disclosed to customers and other relevant parties
Minimum requirements: Performance on freely chosen employment, includes at a minimum demographics of labor and list of labor agents/ contractors with percentage of workforce, costs to workers (in total absolute numbers and per contract base) and labor agent/contractor fees) Site observation: Not applicable Document review: Proof of communication to customers and other relevant parties (web, mail, meeting or publication) on recruitment practices and performance (including freely chosen employment, e.g. demographics of labor and list of labor agents/ contractors with percentage of workforce, costs to workers (in total absolute numbers and per contract base) and labor agent/contractor fees) within the last 12 month is available for review. Management interview: Management can state the detail of the communication program to customers and other relevant parties on recruitment practices and performance.
Worker interview: Not applicable Rating: Priority: Not Applicable Major:(default): No communication program to customers in place Minor: Communication is available and annual but incomplete Not Applicable: Not applicable
Remote verification: No
A2) Child Labor Avoidance
Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the health or safety of young workers.
A2.1 Workers are not below the minimum age
Minimum requirements: Minimum age means the age of 15 or under the minimum age for employment in the country (in some countries (14, the age for completing compulsory education, the age of minimum vocational training), whichever is greatest. Site observation: No visible underage workers are on site Document review: A formal child labor prohibition policy is in place. Personnel file sample, worker roster shows all workers are above legal minimum working age or above company policy minimum age. Auditors need to ensure that sample covers all types of workers/employees. Management interview: Management can state the detail of minimum age policy Worker interview: Workers can state that they are over the minimum age and that they know of no one worker under the minimum age (law or company policy whichever is stricter) Rating: Priority: Confirmed underage workers are present at the facility or in last six months Major:(default): No policy or training on policy in place, no underage workers Minor: Workers are above minimum working age but below company policy minimum Not Applicable: Not applicable
Remote verification: No
A2.2 An adequate and effective policy and process is established to ensure that workers below the legal minimum working age are not hired both directly or via labor agencies / contractors.
Minimum requirements: Site observation: No visible underage workers are on site Document review: An adequate and effective policy and process, including communication/training on child labor prohibition policy, and recruitment and response procedures (e.g. legal proof of age documentation review, validation, filing; appropriately responding to discovery of child labor) to ensure that workers below the legal minimum working age are not hired both directly or via labor agencies / contractors. Reliable proof of age and retain a copy of the relevant document verifying age is on file. A process is in place to verify reliability of age documents (birth certificates, local records, passports, family book, school diplomas, ....). Procedure should include policies and programs that assist underage children found working in the facility. Underage workers should not be discharged or fined but moves them into proper apprenticeship positions, restricting their hours and type of work and accommodates educational needs, as required. Training materials/records on the policy to workers are in place. Management interview: Management can state the detail of minimum age policy, verification and documentation procedures and what is done when an underage worker is discovered. Worker interview: Workers state that they have been trained on child labor prohibition policy and how their age was verified during hire. Rating: Priority: Not Applicable Major: No formal policy and process in place, no age proof documentation. If A2.1 Priority then default Major Nonconformance for inadequate process. Minor: (default): Formal policy in place, process is incomplete or proof age documentation is missing Not Applicable: Not applicable
Remote verification: Yes
A2.3 Access to basic educational needs for workers below the age for compulsory education is applied
Minimum requirements: Site observation: Not Applicable Document review: Procedure is in place for educational needs of workers below the age for compulsory education until they reach the maximum age for compulsory education. This typically includes limited work hours; not working during school hours, and other methods to ensure a school-‐age worker can complete compulsory education. Personnel files for workers below the age for compulsory education that fall in this category reflect conformance with educational needs (at a minimum outline of education program and examples of education material) and hours worked. Auditee has requested and has on file the school hours and adjust work schedule for young worker to attend school. Management interview: Management can state the detail of the requirements and procedure for workers below the age for compulsory education
Worker interview: Workers below the age for compulsory education can state that their working conditions meet the legal requirements on compulsory education and working hours do not conflict with school hours Rating: Priority: Not Applicable Major: No policy and in place and young workers not allowed to follow compulsory education Minor: (default): No policy in place, workers comply with legal requirements on compulsory education Not Applicable: No underage workers on site; no legal requirement on compulsory education. Remote verification: Yes
A2.4 Workers under the age of 18 are not allowed to perform work that is likely to jeopardize the health or safety of these young workers
Minimum requirements: Site observation: No workers under 18 are performing jobs that are hazardous Document review: clear young worker policy is in place and implementation mechanisms are clearly defined and implemented (e.g. health checks if required by law, clear risk evaluation, restriction on hours worked and time of day worked and identification and assignment of young workers to non hazardous positions. The implementation mechanisms are reflected at a minimum in personnel files, medical files and work time records. Management interview: Management cans state clearly their young worker policy and explain the implementation mechanisms Worker interview: Under 18 workers can state that they are not performing hazardous work, that working hours (including over time) meet legal requirements and those compulsory health checks were performed as required. Rating: Priority: Not Applicable Major: (default): No policy and implementation mechanisms in place AND young workers job does not meet requirements Minor: Young worker working hours and job assignment meets requirements but policy or implementation mechanisms are missing or incomplete Not Applicable: No underage workers on site.
Remote verification: No
A2.5 Apprentice/intern/student worker employment policies and practices are in place
Minimum requirements: Apprenticeship is different from worker probation period. Apprentice/ intern/student worker programs are regulated by law in most countries, with specific limits on number of hours worked, duration of training period, and number of times the same worker can be classified as a trainee. In some cases, for the period of the apprentice/intern/student worker programs payment may legally be below minimum wage. The period where wages can be below minimum wage as per law should be limited and reasonable in duration or not longer than 6 months, whichever is stricter. Legitimate internship/student worker programs where a student gains work experience related to their major field of study are also acceptable. Site observation: Not Applicable Document review: If facility does not hire apprentices/interns/student workers then it should have a policy statement stating this. The policy should at least include: Auditee position on apprenticeships/interns/student workers, maximum duration of apprenticeship (not more than 6 months), promotion/hiring opportunities after successful apprenticeship, eligibility, recruitment, employment agreement, nature of work, working hours, wages and benefits. All of these comply with local legal requirements, ...). An outline of training program and copies of the training material are available at all times. Personnel files contain the apprenticeship contract, objectives and reference to the training material. Workers who are employed by the Auditee after a successful apprenticeship clearly have documented promotion and wage adjustment (if required by law or practice) in the personnel file Management interview: Management can state the detail of the apprenticeship policy and describe the recruitment, monitoring and promotion of apprentices. Worker interview: Workers can state if apprentices are hired by the facility. Workers who were apprentices can state the apprenticeship policy and process aligned with the document Auditee policy and process. Rating: Priority: Not Applicable Major: Work performed by apprentices is not related to a field of study or learning of a new vocation. Apprenticeship is longer than 6 months; no agreement among the school, factory and student/parent, apprentices is hired through a labor agent/contractor. If apprentices (under 18) work in hazardous conditions then report in A2.4 If working hour exceeds the limit required by the country laws/regulations then report in A2.4. Minor: (default): No policy in place and apprentices are on site or no policy on not hiring apprentices Not Applicable: A policy on apprenticeship is in place, no apprentices on site Remote verification: Yes
A3) Working Hours
Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off per seven-‐day week.
A3.1 Average hours worked in a workweek over the last 12 months does not exceed 60 hours or the legal limit (whichever is stricter).
Minimum requirements: Site observation: Not applicable Document review: Mandatory sample size of individual time records as well as summary reports, if available show the average number of hours worked -‐ including overtime -‐ per worker per week should not exceed 60 hours. 3 months will be evaluated with the last 12 months; these months should typical be peak, valley and average month. For each month the following is reported: average working hours per week (average working hours evaluation sample should be reflected of demographics of location, not focused on highest hours only), maximum working hours all workers exceeding 60 hours or legal limit whichever is stricter (number versus total) and maximum hours worked. Local laws must be adhered to in the appropriate breakdown of hours. Unless specified otherwise by local legal requirements, this provision does not apply to exempt workers, including those in executive, managerial, or professional positions. If 60 or legal requirements are exceeded, ensure this was not because of emergency or unusual situations. If a government waiver/permit or alternative working hour system is in place then it needs to comply with the EICC Waiver Policy (see section 18) Management interview: Management can state the maximum hours of work as a result of the procedure in place and manage and control working time, including over time Worker interview: Workers can state the hours worked for the months sampled, which concurs with the data from document review. Rating:
Less 5 percent of workers (total or by specific area or job function
Between 5 to 20 percent of workers (total or by specific area or job function
Over 20 percent of workers (total or by specific area or job function
More than 84 h/week Priority Priority Priority
Between 60 and 84 h/week Major Priority Priority
Exceeded legal working or over time limit by 20 or more percent Minor* Major Priority
Exceeded legal working or over time limit by less than 20 percent Minor* Minor* Major
• A tolerance of 1 percent of population is allowed, i.e. if less than 1 percent of workers is detected to do more than legal limit then this is conform
Remote verification: No
A3.2 Workers receive at least one (1) day off per every seven (7) days
Minimum requirements: Site observation: Not applicable Document review: Mandatory sample size of individual work records as well as summary reports, if available show the maximum consecutive days worked is equal to or less than 12 days with an average of 4 days of per every 28 days or legal limit whichever is stricter. 3 months will be evaluated with the last 12 months; these months should typical be peak, valley and average month. For each month the following is reported: average consecutive days worked (average consecutive days worked evaluation sample should be reflected of demographics of location, not focused on longest only), maximum consecutive days worked for all workers exceeding 12 or legal limit whichever is stricter (number versus total) and longest consecutive days worked. Local laws must be adhered to in the appropriate breakdown of days worked. If 12 consecutive days or legal requirements, whichever is stricter, are exceeded, ensure this was not because of emergency or unusual situations. Management interview: Management can state the detail of the manage and control working time, including days off policy/procedures Worker interview: Workers can state the consecutive days worked for the months sampled, which concurs with the data from document review. Rating: Priority: 5 percent or more of the population has worked 24 or more consecutive days Major:(default): 20 percent or more of workers (either overall or for a particular work area or job function) worked more than 12 consecutive days Minor: 5 to 20 percent of workers (either overall or for a particular work area or job function) worked more than 12 consecutive days Not Applicable: Not applicable Remote verification: No
A3.3 Adequate and effective policy and system/procedures are established to determine, record, manage and control working hours including overtime
Minimum requirements: Site observation: Not applicable Document review: A working hours policy and implementation mechanism is in place which effective to determine, record, manage and control working hours including overtime and days off. The implemented process should at a minimum ensure awareness of requirements of compliance with local and national laws and regulations regarding working hours and days off and EICC requirements, integration of these requirements, monitoring of actual performance and ensure conformance with requirements. If Nonconformance is detected corrective action should be implemented and documented and progress against the corrective action is documented. A system / process to provide advance warning as working hours nears the maximum hours is effectively in place. The policy and implementation mechanisms have been communicated (workers have been trained).
Note: if A3.1 or A3.2 is a Nonconformance then this question cannot be conform. Management interview: Management can state the detail of the tracking, implementation, monitoring and corrective action (if applicable) Worker interview: Workers can state the detail of the policy and when they were trained on the policy Rating: Priority: Not Applicable Major: 2 or more components (policy, tracking, implementation, monitoring and corrective action (if applicable)) are not in place Minor: (default): One of the components (policy, tracking, implementation, monitoring and corrective action (if applicable) is not in place Not Applicable: Not applicable Remote verification: No -‐ 6 months not enough time to fix problem and validate. Verification will be made at APM approved timeframe.
A3.4 Workers are allowed legally mandated breaks, holidays and vacation days to which they are legally entitled
Minimum requirements: Most countries require workers to be given a 20 or 30 minutes break every two or four hours, as well as a defined meal break. Compare the company's practices to local legal requirements. Site observation: Workers are observed to take mandatory breaks which includes at least one meal break per shift and in line with legal requirements Document review: Workers are provided with mandated meal and rest breaks, leave periods, holidays, and vacation days per local law requirement, which are detailed in the worker contract, work rules, employee handbook or other form of worker communication. The actual leaves and holidays are recorded in leave records, securely kept and are accurate. EICC does not accept a signed agreement with a worker that allows Auditee not to deduct the social insurance as conformance option to legal social insurance compliance. Management interview: Management can explain the holiday and break provisions for workers, which align with legal requirements and Auditee policy Worker interview: Workers can confirm their holiday and break. They can detail their last shift break and holiday.
Rating: Priority: Not Applicable Major:(default): No policy in place and mandatory breaks/holidays are not provided or guaranteed. Leave records are not kept or accurate. Minor: Holidays and mandatory breaks are provided as per legal requirements, no policy in place, or policy not communicated to workers Not Applicable: Not applicable
Remote verification: No
A3.5 Legal regular and overtime working hours and facility working hours are communicated to all workers
Minimum requirements: Site observation: Not Applicable Document review: Clear working hours and overtime communication/training material is available. The detail of the material aligns with Auditee policy and /or legal requirements. Tracking sheets on communication/training are kept. Management interview: Management can state what communication they provide on working hours and overtime and how often communication or training on this occurs. Worker interview: Workers can state what communication they have received on working hours and overtime, which aligns with the Auditee policy and/or legal requirements. Rating: Priority: Not applicable Major: Not applicable Minor: (default): No or inaccurate communication or training on working hours. No communications/training tracking records on working hours and overtime Not Applicable: Not applicable Remote verification: Yes
A3.6 Reliable time records of workers’ regular and overtime working hours on a daily, weekly and monthly basis are kept and available
Minimum requirements: Site observation: Not applicable Document review: Review the company's time records and system for recording time worked to determine that time is recorded accurately and completely. This includes all workers have a time record. Each time record is accurate and can be cross-‐referenced with leave records, production records, maintenance, procurement or other relevant records. Time recording devices are present and all are in working order. Time records need to include regular working time and overtime. Time records should be detailed to allow for daily, weekly and monthly working time and overtime analysis.
Management interview: Management can state how working hours are recorded and how accuracy and maintenance of time record devices are assured Worker interview: Workers can state how their working hours are recorded, how they can verify the accuracy, if time records are accurate and how they are adjusted if not accurate Rating: Priority: Not applicable Major: No time recording devices present, time recording devices not accurate or in good working order, time records not matching other relevant Auditee records (for more than 5 percent of population). Time records are not accurate adjusted after worker complaint Minor: (default): Time records not matching other relevant Auditee records (for less than 5 percent of population) Not Applicable: Not applicable Remote verification: Yes
A4) Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.
A4.1 Legal wages for regular and overtime hours are correctly calculated and paid to all workers
Minimum requirements: In case the country does not have a legal set minimum wage then the industry prevailing wage will apply as a standard (e.g. Malaysia). The industry benchmark and reference needs to be specified under legal references in this case Site observation: Not applicable Document review: Supplier correctly calculates wages, benefits, and overtime and maintains accurate pay records. Evaluate the company's pay system and records to determine if workers are paid at least the legal minimum wage applicable in the country of operation or the amount specified in worker contract. Document review needs to be for at least three months and for all workers in the statistical sample. For each of the months specify in report the minimum wage, and the average wage for obvious worker categories. Look for deductions from workers' pay that can reduce compensation to below minimum wage. Assess the impact of the production system on pay – verify that production targets don’t drag workers below the legal minimum. Review payroll records and look for the lowest compensation totals to determine all mandated pay and benefits are provided. Ensure overtime and other compensation and benefits are paid and are on top of minimum or contract wage for regular hours. “Pay equals time worked” applies; this means any
company required activity, such a briefings, trainings, daily overview meetings, shall be paid equal to the time of this mandatory attended activity. Management interview: Management can state how wages are calculated and what process is in place to correct wages if errors are reported Worker interview: Workers can state how their wages are calculated, that wages are correct and if errors have occurred these errors have been corrected at least at next pay roll or earlier Rating: Priority: 20 percent of sample or population is paid below minimum wage Major: (default): No policy in place, wage calculations have structural calculation error, between 5 to 20 percent of sample or population are paid below minimum wage, 5 percent or more are not paid benefits or correct overtime compensation Minor: No policy in place, calculations and payment are conform to legal requirements, contract or EICC requirements Not Applicable: Not applicable Remote verification: No
A4.2 Wage calculations are clearly communicated to workers using pay stub or similar
documentation
Minimum requirements: In most countries the law states the requirement of the employer to contribute a portion of worker's wages to national or private insurance schemes. These general consist of retirement, unemployment, accident, medical and possibly others. These need to be communicated to workers and reflected on worker wage receipts. Site observation: Not applicable Document review: Workers are provided with payroll receipts that clearly indicate compensation, including overtime hours and overtime compensation levels. Review evidence that workers are given information relating to wages in an understandable form. Workers are provided with training to fully comprehend how wages are calculated and what to expect when they receive payment. Management interview: Management can state how and when wages and wage calculations are communicated to workers Worker interview: Workers can state when they received a communication/training on wages and calculations and how wages are calculated Rating: Priority: Not applicable Major: Wages and compensation is not communicated to workers in the form of pay slips, pay roll receipt or equivalent. No training or explanation of wages are provided to workers Minor: (default): Communication and training is provided but more than 5 percent of the workers do not understand how wages are calculated Not Applicable: Not applicable Remote verification: Yes
A4.3 Social insurance scheme and other benefits as required by local law is provided to all workers
Minimum requirements: In most countries the law states the requirement of the employer to contribute to national or private insurance schemes. These general consist of retirement, unemployment, accident, medical and possibly others. Site observation: Not applicable Document review: Records of employer contributions to worker insurance schemes, e.g. unemployment, retirement/pension, health/medical, life, accident, disability, ... are available on a monthly basis that allows for analysis by individual worker, total per contribution type. Payment records for these contributions are available for at least 12 months and payments are made timely. Contributions are communicated to workers Management interview: Manage can state their legal contribution obligations and how these are implemented, monitored and paid Worker interview: Workers can state which employer contribution are legal required for them and how they are informed that employer has paid these as required by law Rating: Priority: More than 20 percent of sample or population do not have correct legally required employer contributions paid. Major: (default): 5 to 20 percent of sample or population do not have correct legally required employer contributions paid. Legally required contributions are not paid regularly or timely Minor: Legal employer contributions are paid timely but not communicated to workers. 5 percent or less of sample or population do not have correct legally required employer contributions paid Not Applicable: No legally required contributions Remote verification: No
A4.4 Payments to workers are not delayed or withheld and proof of wage payments to workers is maintained
Minimum requirements: Site observation: Not applicable Document review: Supplier pays wages directly to workers (or as legally designated to a third party) with no unauthorized deductions (including for disciplinary measures) in a timely manner. There should not be a delay of more than a day or two between the end of the pay period and payment made to workers. Verify for statistical sample and for a minimum of three months worker signatures on pay registers, bank transfer records, or other equivalent proof of payment, which includes date and amount due for each single worker Management interview: Management can state the process to ensure on time payment or emergency actions taken if there are delays beyond their control Worker interview: Workers can state when they are paid and that payment is comply as state on pay slip or equivalent
Rating: Priority: Payments have been delayed for more than 1 month Major: Payments are delayed less than one month and for more than 5 percent of sample or population Minor: (default): Payments have been delayed less than one month and less than 5 percent of sample or population Not Applicable: Not applicable Remote verification: No
A4.5 Wages are not deducted or reduced for disciplinary reasons
Minimum requirements: Wage is defined as compensation for actual work performed, including piece rate and productivity allocations. Bonus is defined as an extra compensation in addition of wages for special above normal expectation performance. Adhering to company rules, or performing duties as expected cannot constitute being rewarded through a bonus. A payment that applies equally to all workers such as “annual bonus” will be considered as part of wage, not bonus. Any deduction from wage as defined for disciplinary reasons will constitute a disciplinary deduction. Any deduction from wage equal to time not worked (e.g. showing up to work late, suspension without working) is not considered a disciplinary wage deduction. “Pay equals time worked” applies, this means that if a worker is late the impact on its wages can be no more than the time the worker was late. Site observation: Not applicable Document review: A clear policy statement of the prohibition of disciplinary wage deductions is part of the wages and compensation or equivalent policy. Disciplinary records, pay slips and payment records of wages or equivalent for statistical sample for at least 3 months do not show any form of disciplinary wage deduction Management interview: Management can clearly state that what disciplinary measures are applied and that these do not include Wage deductions Worker interview: Workers can state clearly that disciplinary measures do not include Wage deductions Rating: Priority: Not Applicable Major: (default): Wage deductions are employed by the Auditee as a standard disciplinary measure Minor: Wage deductions are not employed by the Auditee however no clear policy statement on this is in place Not Applicable: Not applicable Remote verification: No
A4.6 Deductions or withholdings are calculated correctly and submitted to the appropriate government agency within the time frame specified in the applicable local labor law
Minimum requirements: Withholdings for taxes and other government programs should be made promptly to the applicable agency Site observation: Not applicable Document review: For at least 3 months statistical sample of population documents should be available to demonstrate for each worker regulatory deduction, payment and communication to worker. Pay stub / process meets local legal regulatory deductions / rates. Management interview: Management can clearly state which deduction are legally applied to workers wages, how these are calculated and what system is in place to implement, monitor, communicate to worker and pay timely these deductions Worker interview: Workers can clearly state what deductions are made from their wages, if these are regulatory requirements and if they are calculated correctly. If an error is made these are corrected at least within the next pay roll cycle. Rating: Priority: Payment of government or regulatory deductions have not been made or paid on time for at least 3 months Major:(default): Payment of government or regulatory deductions are not calculated correctly or are not paid on time Minor: Payment of government or regulatory deductions are calculated correctly but errors are found in the application on a limited number of statistical sample (less than 5 percent) Not Applicable: No withholdings.
Remote verification: Yes
A5) Humane Treatment
There is to be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.
A5.1 No evidence of sexual harassment or abuse, corporal punishment, mental or physical coercion, verbal abuse or intimidation exists
Minimum requirements: Inhumane treatment includes sexual harassment; sexual abuse, corporal punishment, mental or physical coercion or verbal abuse, as well as withdrawal of basic physical comforts provided other workers. Site observation: No identification of possible instances of inhumane treatment. Document review: Grievance records do not show instances of inhumane treatment. If instances are found appropriate corrective actions are taken immediately and documented. Disciplinary records do not show inhumane disciplinary measures Management interview: Management can state their policy and implementation of prohibition of inhumane treatment and what actions they would take if any instances were reported Worker interview: Workers can state that no inhumane treatment has taken place. If any are reported ask how these were actioned and documented. Rating: Priority: One or more case of inhumane treatment are reported without action taken Major:(default): Less than 2 inhumane treatment cases are reported with actions still in progress Minor: Less than 2 inhumane treatment cases were reported with actions completed but no preventive actions on an ongoing basis Not Applicable: Not applicable
Remote verification: No
A5.2 Adequate and effective policies and procedures on decent/humane working conditions and fair treatment of workers are established and communicated to all workers
Minimum requirements: Inhumane treatment includes sexual harassment; sexual abuse, corporal punishment, mental or physical coercion or verbal abuse, as well as withdrawal of basic physical comforts provided other workers. Site observation: Not applicable Document review: The documents include humane disciplinary measures/procedures, grievance/complaint mechanisms and procedures for workers to report instances of harsh/inhumane treatment, procedures to investigate and address such complaints, including appropriate disciplinary actions against those that have the committed harsh/inhumane acts. Effective procedures to investigate reports and, if appropriate, to discipline those that commit acts of harsh or inhumane treatment against workers are in place. The company should have disciplinary policies in place prohibiting physical or sexual harassment and abuse. They should be clearly communicated to workers in worker training, handbooks, notice board postings or other means immediately accessible to all workers.
Management interview: Management can state the detail of the Auditee disciplinary action procedure Worker interview: Workers can state how disciplinary actions are taken, recorded, appealed. When how these actions and procedure/means were communicated/trained. Rating: Priority: Not Applicable Major: Disciplinary policy and disciplinary action training are not available Minor: (default): Disciplinary policy and disciplinary action records are available but communication or training not effective (less than 5 percent cannot explain disciplinary action procedure) Not Applicable: Not applicable
Remote verification: Yes
A5.3 Disciplinary actions are recorded, consistent with the procedures and reviewed by management
Minimum requirements: Inhumane treatment includes sexual harassment; sexual abuse, corporal punishment, mental or physical coercion or verbal abuse, as well as withdrawal of basic physical comforts provided other workers. Site observation: Not applicable Document review: The Company should keep clear records of all cases of disciplinary action. Auditor reviews company disciplinary action records. For statistical sample the disciplinary records for last 12 months shows disciplinary actions with signature or confirmation of worker. Disciplinary actions procedure is documented and conforms to legal requirements and does not contain inhumane practices. Management interview: Management can state how disciplinary actions are recorded and how appeals are handled Worker interview: Workers can state how disciplinary actions are recorded, if these are accurate and they have access to their own records to check accuracy Rating: Priority: Not Applicable Major: Disciplinary action records are not available Minor: (default): Disciplinary action records are available but workers do not confirm or sign the records/actions Not Applicable: Not applicable
Remote verification: Yes
A5.4 Managers and supervisors are adequately trained on appropriate disciplinary measures/procedures.
Minimum requirements: Site observation: Not applicable Document review: Managers and supervisors receive training or education on appropriate discipline. Copy of the communication and training materials on disciplinary practices to managers is available and consistent with the procedure. Training records are available for initial AND annual refresher training on appropriate discipline. Management interview: Managers AND supervisors can clearly state when they were last trained and explain consistently the detail of the disciplinary action procedure Worker interview: Not applicable Rating: Priority: Not Applicable Major: Managers and supervisors do not receive training on disciplinary action procedure(s) Minor: (default): Managers and supervisors receive training on disciplinary action procedure(s) but do not have annual refresher training Not Applicable: Not applicable Remote verification: Yes
A5.5 Workers are permitted time off when ill or for maternity
Minimum requirements: Workers receive a reasonable amount of time off for sickness or maternity without job loss or financial penalty when supported with a medical certificate. Site observation: Not applicable Document review: Formal policies and procedures for sick leave and maternity leave are in place and communicated to workers, supervisors and management. Formal communications of these procedures/policies is available (handbook, work rules,...). Leave records for 12 months are consistent with those medical certificates. Payroll records for these absence show that there was no financial penalty for maternity or sick leave. Management interview: Management can clearly state the medical leave policy details consistent with the written policy and legal requirements Worker interview: Workers can detail the medical leave policy and confirm that the implementation is conform to the written policy Rating: Priority: Workers are not allowed time of for illness or maternity with valid medical certificate Major: (default): Workers are not allowed to take full time off as per legal requirements with a valid medical certificate Minor: Not applicable Not Applicable: Not applicable Remote verification: No
A6) Non-‐Discrimination
Participants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.
A6.1 No evidence of discrimination based on grounds of race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status exists.
Minimum requirements: Prohibition of discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training Site observation: Facility observation does not uncover any discrimination situations Document review: Workers or potential workers are not subjected to medical tests that could be used in a discriminatory way. The job postings and advertisements do not discriminate. Facility makes decisions in hiring, employing, or terminating workers based solely on the candidate's ability to perform the job's requirements. Health tests, pregnancy testing, or contraception are not used as a condition of employment. (In some cases, local governments require health tests for foreign workers prior to issuance of work visas). Except for health and safety reasons, facility does not place any restrictions on female workers due to pregnancy. Hiring records, promotion records, pay roll, general training and disciplinary records for statistical sample are reviewed for consistency of policy. Management interview: Management can state how many reported case they have had on discrimination. If any case of discrimination is reported, they can state how it was effectively actioned Worker interview: Workers can state that the workplace is free of discrimination. If they report any case of discrimination, they can state how management has effectively actioned the reported case Rating: Priority: One or more case of discrimination are reported without action taken Major:(default): Less than 2 discrimination cases are reported with actions still in progress. Management discriminates in a structural way (medical testing,....) Minor: Less than 2 discrimination cases were reported with actions completed but no preventive actions on an ongoing basis Not Applicable: Not applicable Remote verification: No
A6.2 Adequate and effective policies that ban discrimination and harassment are in place.
Minimum requirements: Prohibition of discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training Site observation: Not applicable Document review: Policies that ban discrimination are established. Decisions in hiring, employing, or terminating workers are based solely on the candidate's ability to perform the job's requirements. Written job descriptions that focus solely on “occupational qualifications,” not personal characteristics are in place. Non-‐discrimination polices and procedures are communicated to workers, supervisors and manager. An initial training on non-‐discrimination and annual refresher training for supervisors and managers is in place. Training material and records are in place and consistent with legal requirements and written policy. Supplier periodically reviews hiring practices, compensation records, and benefits to determine that there is no prohibited discrimination. Hiring agents and supplier management are trained in non-‐discrimination and applicable non-‐discrimination laws Management interview: Management can state how they recruit, hire, promote and terminate workers consistent with the non-‐discrimination policy/requirements Worker interview: Workers can state when they were last trained on non-‐discrimination policy and procedures and describe the content consistent with the policy Rating: Priority: Not Applicable Major: No non-‐discrimination policy or policy communication/training in place Minor: (default): Non-‐discrimination policy in place but not communicated/trained on refreshed basis Not Applicable: Not applicable Remote verification: Yes
A7) Freedom of Association
Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. The rights of workers to associate freely, join or not join labor unions, seek representation, and join workers’ councils in accordance with local laws shall be respected. Workers shall be able to openly communicate and share grievances with management regarding working conditions and management practices without fear of reprisal, intimidation or harassment.
A7.1 Legal rights of workers for free association are respected
Minimum requirements: For purpose of this section Freedom of Association is expanded to include the protection of the right of employees to engage in non-‐disruptive social interactions in the workplace. e.g. allow employees to interact with each other in the workplace, and to speak freely. Site observation: No evidence present of Association "boycotting" Document review: Grievance records show that any allegation or reported case is actioned appropriately to uphold the spirit of Freedom of Association. Management interview: Management can state that Freedom of Association rights are respected. Worker interview: (includes worker representative or worker committee member, if present in Auditee): Workers can state that Freedom of Association rights are respected. Rating: Priority: Freedom of Association is structurally boycotted. Any grievance on Freedom of Association is not actioned. Major: (default): Freedom of Association is discouraged in Auditee communication Minor: Freedom of Association is respected but expanded definition of free non-‐disruptive interaction in the workplace is not allowed Not Applicable: Not applicable Remote verification: No
A7.2 Adequate and effective communication/training to workers on their legal rights related to
freedom of association is provided
Minimum requirements: For purpose of this section Freedom of Association is expanded to include the protection of the right of employees to engage in non-‐disruptive social interactions in the workplace. E.g. allow employees to interact with each other in the workplace, and to speak freely. Site observation: Not Applicable Document review: Written policies and procedures addressing freedom of association are in place. The country's freedom of association laws and how the Auditee complies with them is described in the policy. Training material meeting policy and legal requirements are in place. Training records reflect that workers, supervisors and managers are training of Freedom of Association with an annual refresher training. Management interview: Management can state when they were last trained on Freedom of Association, when workers were last trained, what the Freedom of Association training and refresher program is and can detail consistent the content with the Freedom of Association policy. Worker interview: (includes worker representative or worker committee member, if present in Auditee): Workers can state when they were last trained on Freedom of Association and can detail consistent the content with the Freedom of Association policy
Rating: Priority: Not Applicable Major: No policy or training program is in place on Freedom of Association. Minor: (default): training program and policy are in place but refresher training has not occurred in last 12 months Not Applicable: Not applicable Remote verification: Yes
A7.3 No evidence of unequal treatment between unionized or worker representatives and non-‐unionized workers exists
Minimum requirements: For purpose of this section Freedom of Association is expanded to include the protection of the right of employees to engage in non-‐disruptive social interactions in the workplace. E.g. allow employees to interact with each other in the workplace, and to speak freely. Site observation: No evidence present of Association "boycotting" Document review: For statistical sample of population pay roll, promotion, training, disciplinary, hiring and termination records do not indicate any form of discrimination towards worker representatives, union members or other forms of association. Determine if Auditee dismisses, disciplines, coerces or threatens workers because of their exercise of the right to freedom of association. Management interview: Management can state if a case Freedom of Association rights violation is reported how they resolved such situation successfully. Worker interview: (includes worker representative or worker committee member, if present in Auditee): Workers can state if a case Freedom of Association rights violation is reported, they can state have management resolved such situation successfully. Rating: Priority: Freedom of Association is structurally boycotted. Representatives are discriminated against with option for resolution Major: (default): Freedom of Association discrimination is reported and corrective action is not in place or implemented timely Minor: Freedom of Association discrimination is reported and corrective action is in place but no preventative measures are implemented Not Applicable: No union or worker representative Remote verification: No
A7.4 No evidence of control or attempt to control of labor organizations by any means (incentives or intimidation) exists.
Minimum requirements: For purpose of this section Freedom of Association is expanded to include the protection of the right of employees to engage in non-‐disruptive social interactions in the workplace. E.g. allow employees to interact with each other in the workplace, and to speak freely. Site observation: Not applicable Document review: Written policies and procedures addressing freedom of association include Auditee will not interfere and will not finance directly, indirectly or through benefit in kind any employee, organization or trade union. Verify committee or union meeting minutes for 12 month to determine source of funding and materials. This does not include to provision of meeting space, meeting materials such as note taking material. Any materials over a nominal value per year will be considered a benefit. Review pay roll for statistical sample to ensure that committee/union members are paid same as similar job functions. Management interview: Management can state what they contribute to committee or union meetings and how they ensure avoidance of influence or control Worker interview: (includes worker representative or worker committee member, if present in Auditee): Union/ committee members can state source of support and the amount contributed by the Auditee. This should be no more than a nominal value Rating: Priority: Not Applicable Major: Union/committee members are paid direct in wages or in kind for activities. No non-‐interference policy is in place Minor: (default): Policy is in place; Auditee contributes to committee/union an amount larger than nominal value per year Not Applicable: no labor organization in the facility. 3 data points are required to show "no labor organization". Remote verification: No
A7.5 Workers are informed when being employed if automatically enrolled in union or other forms of worker representation
Minimum requirements: For purpose of this section Freedom of Association is expanded to include the protection of the right of employees to engage in non-‐disruptive social interactions in the workplace. e.g. allow employees to interact with each other in the workplace, and to speak freely. Site observation: Not applicable Document review: A documented procedure and communication materials are available to inform workers of automatic enrolment into union or committee. Records for statistical sample over last 12 months are available to demonstrate workers acknowledgment of this enrolment. Management interview: Management can state if a union/committee is present if worker enroll automatically and if they are informed prior to enrolment. Worker interview: (includes worker representative or worker committee member, if present in
Auditee): Workers can state if a union/committee is present in Auditee and if they are member. If they are member were they enrolled automatically and informed PRIOR to automatic enrolment Rating: Priority: Not Applicable Major: Workers are not informed of enrolment and mandatory membership wage deduction or union/committee contribution Minor: (default): Workers are informed on union/committee contribution but not informed of enrolment Not Applicable: Workers do NOT automatically enroll in a union or other forms of employee organizations. (3 data points are required to show "workers are not enroll in the union automatically); no union or other forms of employee organization Remote verification: No
A7.6 Worker representatives are democratically elected
Minimum requirements: For purpose of this section Freedom of Association is expanded to include the protection of the right of employees to engage in non-‐disruptive social interactions in the workplace. e.g. allow employees to interact with each other in the workplace, and to speak freely. Site observation: Not applicable Document review: Written election governance procedures are in place containing free candidates nomination, free election campaigning, election voting and integrity, vote counting integrity and announcement of results. Records on last election are available and match the election governance procedures. Management interview: Management can state the union/committee election governance process and when the last election took place Worker interview: (includes worker representative or worker committee member, if present in Auditee): Workers can state how union/committee members are elected, when the last election was and how they voted for free candidates Rating: Priority: Not Applicable Major: Auditee management or equivalent appoints workers Minor: (default): Workers are elected but formal election governance procedures are missing or are not communicated to workers prior election Not Applicable: No employee representative in the facility. 3 data points are required to show "no representative". Remote verification: No
B. HEALTH & SAFETY B1) Occupational Safety
Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tag out), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well maintained, personal protective equipment. Workers shall not be disciplined for raising safety concerns.
B1.1 All required permits, licenses and test reports for occupational safety are in place and a process
is implemented to ensure permits and licenses are up to date at all times
Minimum requirements: Site observation: Not applicable Document review: All legally required occupational safety permits are in place, available for review and valid. All occupational safety licenses are in place and available for review. Occupational safety testing reports are in place, available for review and meeting the conditions of permits, licenses or legally or customer requirements. Testing is done at a frequency stated in permits, licenses or by customers and does not exceed a period of two year. A documented process is in place to ensure permits are renewed before current permits expire. Permit tracking is documented Management interview: Management can state which occupational safety permits are required, what testing is done and which process is in place to ensure permits are renewed before current permits expire. Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): Legally required permits, licenses or testing reports missing and no process in place Minor: Legally required permits, licenses or testing reports in place but no process in place to guarantee timely renewal Not Applicable: No permits or license required. No testing reports required Remote verification: Yes
B1.2 Worker exposure to potential safety hazards (e.g. electrical and other energy sources, fire, vehicles, and fall hazards) are controlled through proper design, engineering and administrative controls and safe work procedures
Minimum requirements: This is not risk assessment, for risk assessment see E4 Site observation: Review a sampling of the operations covered by the facility's safety programs to determine if the hazards are adequately controlled. If available, select the facility's highest ranked safety risks. Go out into the factory to look at the areas and operations with safety hazards. Engineering controls are used where appropriate? Buildings are structurally sound and conform to local building code requirements. Stairways and elevated work areas are provided with appropriate guardrails and handrails. Aisles, stairways, and work areas are free of tripping hazards (stored materials, electrical cords, ...). Precautions and controls of electrical hazards are in place. In areas where powered industrial vehicles are used, pedestrian walkways are clearly delineated and physically separated, where possible, from vehicle operation areas. Hazards are identified by appropriate signs, placards and labels in the local language of workers. Energized parts are protected from accidental contact by enclosures and barriers. Workers are provided with appropriate fall protection for work in elevated work areas (roof work, high lift fork trucks, towers, ...). Confined spaces are identified. Combustible storage is minimized and limited to areas with adequate fire detection and protection. Flammable and combustible materials are properly stored to prevent the accumulation of vapors. Ignition hazards (e.g. smoking, electrical sparks, open flames, ...) are eliminated in areas where combustible and flammable materials are stored or used or if there is a flammable atmosphere. Document review: Safe work practices are established and documented where engineering controls are not feasible or do not completely control the hazard. Confined spaces hazards are evaluated before workers are allowed to enter. A hot work permit system is in place for welding, cutting and brazing. A daily safety inspection is performed for all industrial powered vehicles. Electrical installations and wiring are regularly inspected and maintained to prevent electrical shock hazards (damaged cords and plugs, frayed wiring, missing protective barriers, ...). Lockout/tag out program is in place for work on equipment where stored energy (electrical, pneumatic, mechanical, …) or inadvertent start-‐up could injure workers. Management interview: Management can state which methods, controls and procedures they have in place to minimize worker exposure to occupational safety hazards (they can list specific controls for each occupational safety hazard) Worker interview: Workers can state/show that controls are in place to minimize their exposure to occupational safety hazards for their specific function Rating: Priority: Imminent risk of loss of facility, life or limb Major: (default): One or more occupational safety hazards do not have control measures to limit worker exposure Minor: Control to limit worker exposure to occupational safety hazards in place but not regularly monitored Not Applicable: Not Applicable Remote verification: No
B1.3 Appropriate Personal Protective Equipment (PPE) is consistently and correctly used where required to control safety hazards and worker exposure
Minimum requirements: Site observation: Observe workers in areas with PPE requirements. PPE should be signed and worn appropriate by all who work or reside in this area for longer periods of time (longer than exposure limit value) Document review: If PPE use is required, the Auditee has a process in place to ensure it is used. The program elements could include: signs and labels, worker training, regular enforcement by supervisors, work area inspections, PPE requisition and renewal procedures. PPE training materials and training records are available and demonstrate that all workers who require specific PPE have been training initially with regular refresher training Management interview: Management can state what PPE is required for which areas, what procedures they have in place (aligned with the document requirements) and when and how workers are trained. Worker interview: Workers can state what PPE is required in the areas they work in, how their PPE is obtained and ensured it is safe/valid and when and how they were trained in the appropriate use of the PPE. Rating: Priority: Not Applicable Major: PPE is not worn in required areas; no training is available to workers Minor: (default): PPE is worn in required areas, however no inspection program on safe/valid state of PPE or no refresher trainings. Not Applicable: No PPE is required. Remote verification: No
B2) Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.
B2.1 All required permits, licenses and testing reports for emergency preparedness are in place and a
process is implemented to ensure permits and licenses are up to date at all times
Minimum requirements: Site observation: Not applicable Document review: All legally required emergency preparedness permits are in place, available for review and valid. All emergency preparedness licenses are in place and available for review. Emergency
preparedness testing reports are in place, available for review and meeting the conditions of permits, licenses or legal and customer requirements. Testing is done at a frequency stated in permits, licenses or by customers and does not exceed a period of two year. A document process is in place to ensure permits are renewed before current permits expire. Permit tracking is documented Management interview: Management can state which emergency preparedness permits are required, what testing is done and which process is in place to ensure permits are renewed before current permits expire. Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): Legally required permits, licenses or testing reports missing and no process in place Minor: Legally required permits, licenses or testing reports in place but no process in place to guarantee timely renewal Not Applicable: No permits or license required. No testing reports required Remote verification: Yes
B2.2 Adequate and effective fire detection, alarm and suppression systems are in place.
Minimum requirements: Site observation: The Auditee has: automatic fire sprinklers (if required by law or insurance company), portable fire extinguishers, heat and smoke detection, and an alarm and notification system. Document review: Automatic fire sprinklers (if required by law or insurance company), portable fire extinguishers, heat and smoke detection, and an alarm and notification system are inspected for good state of operation on a regular basis, as required by law, insurance company, customers or common practice. This inspection frequency shall not be less than monthly. The inspection procedure, frequency and results are documented Management interview: Management can state which firefighting systems are in place, which alarm and notification system is in place and how often these systems are inspected. Worker interview: Workers can describe which firefighting equipment is in place Rating: Priority: No firefighting equipment, no heat and smoke detection, no alarm or notification system is in place. Note it may take longer than 30 days to correct this Priority Nonconformance Major: (default): Firefighting equipment is in place, heat and smoke detection, alarm or notification system is in place but not inspected regularly (at least monthly) Minor: Systems are in place and inspection procedure is documented and implemented but the result are not recorded Not Applicable: Not applicable Remote verification: No
B2.3 All likely types of emergencies that could affect the site are identified and assessed, and adequate and effective emergency preparedness and response programs (plans/procedures) are established.
Minimum requirements: Site observation: Adequate signage is observed with emergency number(s), emergency team and emergency plot plan Document review: Results of the facility's assessment and the response programs intended to address the identified risks are available for review and appropriate. Programs to address the identified risks are documented and updated when changes occur in the Auditee (people, place, situation) or at minimum every two years. Typical emergency programs include: fire; flood; windstorm; chemical spill; earthquake; bomb threat; and must include at minimum: fire, chemical spill (if chemicals used), strike, severe weather (rain, flood, typhoon, frost, snow, ...). Emergency reporting procedures are available and up to date. Business resumption procedures are available and adequate Management interview: Management can state how often they assess risk; which emergency situations have been identified and how the emergency plans function. If there was a loss of facility or severe damage how they implement business resumption plans Worker interview: Not applicable Rating: Priority: No risk assessment, no emergency response plan in place Major:(default): Emergency response plan is in place, not covering all minimum requirements or missing items identified in risk assessment. No updating of emergency plans when changes occur or at least every two years. Minor: Risk assessment and emergency response plans up to date and complete however no reporting procedure or business resumption plan in place. Not Applicable: Not applicable Remote verification: Yes
B2.4 Emergency exits, aisles and stairways are adequate in number and location, readily accessible, and
properly maintained
Minimum requirements: Site observation: An adequate number of exits from every area; that multiple exits from an area are separated from one another by distance and exit path; that exits and exit pathways are clear of obstructions; and exit doors are unlocked or locked with easily opened panic hardware, such as crash bars. Exits or exit signs can be seen from every point within the facility. Emergency lighting provided for exit pathways. Exit facilities are properly maintained. Document review: Inspection records for emergency support facilities (emergency lighting, emergency exit signs, evacuation paths, portable fire extinguishers, ...) are maintained and shows these are inspected as per local legal requirements, insurance requirements, local practice or NFPA standard whichever is stricter Management interview: Management can state which emergency support faculties are in place, how these are inspected and recorded Worker interview: Workers can describe the emergency support facilities,
Rating: Priority: No emergency support facilities present or in good operating condition throughout Auditee; 2 or more emergency exits are blocked Major: (default): 1 emergency exit blocked. Emergency support facilities generally in working conditions with at least 1 exception. Emergency support facilities not inspected as per local legal requirements, insurance requirements, local practice or NFPA standard whichever is stricter Minor: All emergency support facilities appropriate, good condition and inspected. Inspection records not maintained or incomplete Not Applicable: Not applicable Remote verification: Yes unless Priority
B2.5 All employees are provided with appropriate training/communication on fire and other emergencies, as well as the corresponding preparedness and response plans/procedures.
Minimum requirements: Site observation: Not applicable Document review: Outline of training program on risk assessment, emergency response and business resumption is available. Workers, supervisors and management are trained in the relevant aspects and training records are available for initial training and refresher training. Emergency response training refreshers happen at least annually. Training includes how to report an emergency. Management interview: Management can state how and when they were last trained on which aspects of risk assessment, emergency response and business resumption and how and when supervisor and workers are trained. Supervisors can state how and when they were last trained on which aspects of risk assessment and emergency response. Worker interview: Workers can state how and when they were last trained on which aspects of emergency response. This should at least include how to report an emergency, how to evacuate the building (including alternate evacuations routes), the meaning of any specific facility alarms or sirens, and where to re-‐group/assemble outside the building. Rating: Priority: Not Applicable Major: Management, supervisor or workers are not trained on emergency preparedness and response. Or training is incomplete Minor: (default): Training is adequate but there are no annual refresher trainings Not Applicable: Not applicable Remote verification: No
B2.6 Adequate and effective fire and other emergency evacuation and response drills are conducted with all employees, and records are maintained.
Minimum requirements: Site observation: Not applicable Document review: An adequate evacuation drill program for all workers in every area of the Auditee and for all work shifts on at least an annual basis (or more if legal requirements state so) is in place and implemented. If worker turnover is more than 5 percent, meaning when worker turn over exceeds 5 percent since last drill, a new drill is required. Drills should be documented, with lessons learned and corrective action plan to improve the emergency evacuation situation. Corrective action plans have been implemented or are on track. Records for last 3 years, including CAP and their status are available for review. Management interview: Management can state when the last drill was held and what corrective actions were taken. Management can also state when the previous drill was held and if all corrective actions from the drill have been completed. Worker interview: Workers can state when the last drill was they participate in Rating: Priority: No emergency evacuation drill held in last 2 or more years Major:(default): No emergency evacuation drill held in last year or drill was held but not for all areas and all shifts. Drill was held for all areas and all shifts; no corrective actions were determined or documented Minor: Corrective actions from last drilled are off track Not Applicable: Not applicable Remote verification: Yes
B2.7 Designated emergency response personnel are provided adequate and effective PPE and training on a
regular basis
Minimum requirements: Site observation: Emergency response PPE is available, adequate and in good condition. Emergency response PPE is clearly marked, visible and easily accessible. Document review: Workers involved in the control, cleanup and disposal of hazardous materials or other emergency response procedures e.g. fire fighting, receive regular training on emergency response plans and actions Emergency responders should receive training on: chemical hazards and precautions, spill containment and cleanup, fire hazards and response, proper handling and disposal of chemicals and contaminated absorbent materials, selection and use of protective equipment, other information as required by local regulations. Emergency responders are trained on an annual basis. Training material and training records are available for review and up to date Management interview: Management can state what training is required for emergency responders and when the last training as held Worker interview: Workers who are emergency responders can state if they are trained on an annual basis, when they were last trained and on which topic
Rating: Priority: PPE for response personnel not available; not in good condition / working order, sufficient, visible or easily accessible. Major: No or incomplete training of emergency responders, Minor: (default): Training appropriate but annual refresher training missing or training records incomplete Not Applicable: Not applicable Remote verification: Yes
B3) Occupational Injury and Illness
Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement corrective actions to eliminate their causes; and e) facilitate return of workers to work.
B3.1 All required permits, licenses and testing reports for occupational injury and illness are in place and a process is implemented to ensure permits and licenses are up to date at all times
Minimum requirements: Site observation: Not applicable Document review: All legally required occupational injury and illness permits are in place, available for review and valid. All occupational safety licenses are in place and available for review. Occupational injury and illness testing reports are in place, available for review and meeting the conditions of permits, licenses or legal and customer requirements. Testing is done at a frequency stated in permits, licenses or by customers and does not exceed a period of two year. A document process is in place to ensure permits are renewed before current permits expire. Permit tracking is documented Management interview: Manage can state which occupational injury and illness permits are required, what testing is done and which process is in place to ensure permits are renewed before current permits expire. Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): Legally required permits, licenses or testing reports missing and no process in place Minor: legally required permits, licenses or testing reports in place but no process in place to guarantee timely renewal Not Applicable: No permits or license required. No testing reports required Remote verification: Yes
B3.2 Investigations to determine root cause(s) and implement corrective/preventive actions for work-‐related injuries/illness in the past three years are performed and documented
Minimum requirements: Site observation: Not applicable Document review: Injury and illness statistics for last 3 years are available. Analysis of the statistics is performed on a regular basis, at least annually and corrective actions are taken, tracked and implemented. Accident investigation reports, including any resulting corrective actions and verification that corrective actions were implemented. Records for last 3 years are available. All reportable and non-‐reportable accidents are tracked; recorded, and investigated to minimize the potential for future occurrence. Documented procedures for accident investigations and analysis are available and adequate. Report the statistics for the last 3 years as part of data points Management interview: Management can state how accidents, they had in the last year, how the investigate accidents and minimize the risk of re-‐occurrence Worker interview: Worker can state if an investigation is performed after an accident and if changes to the job/work station/area are made. Rating: Priority: Not Applicable Major: (default): No accidents, injury and illness are tracked or incomplete for last 3 years. Accidents are tracked but no analysis, investigation or corrective actions. Minor: Accidents, injuries, illnesses tracked, analyzed and prevented but no form procedure or corrective action off track Not Applicable: No injuries, accidents or illnesses in the past 3 years. Remote verification: Yes
B3.3 A effective process and adequate first aiders to provide medical treatment for injured or ill workers is
in place
Minimum requirements: Site observation: First aiders are easily identifiable. An infirmary is available. Document review: Occupational health professionals or first aiders are trained from external agencies and valid certificates are available for review. If nurses or doctors are employed or doctor/nurse services are used a copy of their certificate is available. If the in-‐house infirmary or clinic needs a certificate or license by legal requirement then this is available and up to date. A documented response procedure is in place indicating severity of medical emergency and response (first aid, infirmary, local external hospital). In the absence of onsite professional care; the facility maintains a team of trained first aiders. Workers are then sent to off-‐site medical facilities for further treatment. Documented procedures for onsite emergency facility (infirmary, ...) are available and adequate. Copies of qualifications of personnel working within the onsite medical treatment facility are available and up to date. An operations log of onsite emergency medical facility is available and up to date (access might be restricted due to privacy laws). Government certifications, permits, inspections, approval for the onsite medical treatment facility is available and up to date. Management interview: Management can state what medical emergency response personnel and procedures are available on site and where closest nearby hospital is in case of severe emergency Worker interview: Worker can state the process if they get sick at the facility.
Rating: Priority: No medical emergency personnel or procedures Major: (default): First aid, infirmary or medical response procedures inadequate; Infirmary inadequate Minor: Not applicable Not Applicable: Not applicable Remote verification: Yes
B3.4 Adequate first aid kits to provide medical treatment for injured or ill workers are in place
Minimum requirements: Site observation: Appropriate and complete stocked and signed first aid boxes are available. First aid boxes are unlocked or if locked, first aider has key at all times Document review: First aid kits have contents list and procedure for first aid kit inspection (at least weekly) and restocking is in place. Inspection tracking document is available and up to date Management interview: Management can state how first aid kits are stocked and inspected Worker interview: Workers can state where nearest first aid box is in their section Rating: Priority: Not applicable Major: (default): First aid boxes inadequate Minor: First aid boxes adequate and stocked but contents list missing or inspection tracking records missing Not Applicable: Not applicable Remote verification: Yes
B3.5 Workers know what to do in the event they are injured or become ill on the job
Minimum requirements: Site observation: Not applicable Document review: A documented response procedure is in place indicating severity of medical emergency and response (first aid, infirmary, local external hospital). Training material to workers and training records on medical emergency response are available, adequate and up to date Management interview: Management can state what medical emergency training is provided to workers Worker interview: Workers can state who is the first aider in their section, where the infirmary is and when they can access it and what to do when the medical emergency is severe. Rating: Priority: Not applicable Major: (default): More than 20 percent of workers do not know what to do in the event of injury or illness or have not been trained Minor: Training on response to injury/illness is in place; less than 20 of workers is unclear on what to do Not Applicable: Not applicable
Remote verification: Yes
B4) Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. Engineering or administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is to be protected by appropriate personal protective equipment programs.
B4.1 All required permits, licenses and testing reports for Industrial hygiene are in place and a process is implemented to ensure permits and licenses are up to date at all times
Minimum requirements: Site observation: Not applicable Document review: All legally required industrial hygiene permits are in place, available for review and valid. All industrial hygiene licenses are in place and available for review. Industrial hygiene testing reports are in place, available for review and meeting the conditions of permits, licenses or legally or customer requirements. Testing is done at a frequency stated in permits, licenses or by customers and does not exceed a period of two year. A document process is in place to ensure permits are renewed before current permits expire. Permit tracking is documented Management interview: Management can state which industrial hygiene permits are required, what testing is done and which process is in place to ensure permits are renewed before current permits expire. Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): Legally required permits, licenses or testing reports missing and no process in place Minor: Legally required permits, licenses or testing reports in place but no process in place to guarantee timely renewal Not Applicable: No permits or license required. No testing reports required
Remote verification: Yes
B4.2 Appropriate controls for worker exposures to chemical, biological and physical agents are implemented
Minimum requirements: Site observation: Controls to reduce or eliminate worker exposure to chemical, biological and physical agents are in place and effective: Engineering controls (e.g. exhaust ventilation, enclosures, ...) designed to reduce worker exposures to chemical, biological and physical agents, administrative controls (limiting worker exposure time; job rotation) designed to reduce worker exposures, proper marking of all chemical, biological and physical agents. Document review: Industrial hygiene sampling records for the past three years, including sampling performed by government agencies as part of a regulatory inspection are available for review. Frequency of sampling is maximum one year unless risk assessment or regulatory requirements requires more frequent sampling. A documented program to identify, evaluate and control worker exposure to chemical, physical and biological agents including a risk assessment program and annual plan for the facility is in place and up to date Management interview: Management can state what Industrial hygiene risk assessment program is implemented, what over exposures there are and how these are controlled/minimized.
Worker interview: Workers can state what controls management has implement on their job/position/area to minimize the risk of industrial hygiene exposure Rating: Priority: No risk assessment or control measures are in place. Over exposures are evident Major:(default): Overexposures have been identified and risk assessment program is in place. Controls are inadequate Minor: Over exposure are controlled and minimized. Industrial hygiene monitoring program is adequate. Documentation and records are incomplete Not Applicable: no measured overexposures. Remote verification: No
B5) Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.
B5.1 All required permits, licenses and testing reports for ergonomics are in place and a process is implemented to ensure permits and licenses are up to date at all times
Minimum requirements: Site observation: Not applicable Document review: All legally required ergonomics permits are in place, available for review and valid. All ergonomics licenses are in place and available for review. Ergonomics testing reports are in place, available for review and meeting the conditions of permits, licenses or legally or customer requirements. Testing is done at a frequency stated in permits, licenses or by customers and does not exceed a period of two year. A document process is in place to ensure permits are renewed before current permits expire. Permit tracking is documented Management interview: Management can state which ergonomics permits are required, what testing is done and which process is in place to ensure permits are renewed before current permits expire. Worker interview: Not applicable Rating: Priority: Not Applicable Major:(default): Legally required permits, licenses or testing reports missing and no process in place Minor: Legally required permits, licenses or testing reports in place but no process in place to guarantee timely renewal Not Applicable: No permits or license required. No testing reports required Remote verification: Yes
B5.2 Worker exposure to the hazards of physically demanding work is identified, assessed and controlled adequately and effectively
Minimum requirements: Site observation: Controls to reduce or eliminate physical demanding work (e.g. heavy or repetitive lifting, prolonged standing, ...) are in place and effective: Engineering controls are designed to reduce physical demanding work; administrative controls (limiting worker exposure time; job rotation) are designed to reduce physical demanding work. Document review: For physical demanding work risk assessment records for the past three years are available for review. Frequency of assessment is maximum one year unless regulatory requirements require more frequent assessment. If there are no changes to the facility or work set up there is no need to reassess (this “no-‐change” should be documented). A documented program to identify, evaluate and control physical demanding work is in place and up to date. A training program with materials and training records is in place, adequate and up to date Management interview: Management can state how they analyze physical demanding work, if there are any risks identified and what controls they have put in place to minimize this risk. Management can also state how workers are trained on physical demanding work. Worker interview: Workers can state adequate efforts by the Auditee to control ergonomic hazards, including training (what and when last trained). Workers state if they are pain free or whether they are experiencing any physical pain now or in the past and what was or is being done to address / reduce it. Rating: Priority: No risk assessment or control measures are in place. High physical demanding work is evident Major: (default): Physical demanding work has been identified and risk assessment program is in place. Controls are inadequate Minor: Physical demanding work is controlled and minimized. Physical demanding work monitoring program is adequate. Documentation and records are incomplete Not Applicable: No physical demanding work Remote verification: No
B6) Machine Safeguarding
Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.
B6.1 All required permits, licenses and testing reports for machinery are in place and a process is implemented to ensure permits and licenses are up to date at all times
Minimum requirements: Site observation: Not applicable Document review: All legally required machine safety permits are in place, available for review and valid. All machine safety licenses are in place and available for review. Machine safety testing reports are in place, available for review and meeting the conditions of permits, licenses or legally or customer
requirements. Testing is done at a frequency stated in permits, licenses or by customers and does not exceed a period of two year. A document process is in place to ensure permits are renewed before current permits expire. Permit tracking is documented Management interview: Manage can state which machine safety permits are required, what testing is done and which process is in place to ensure permits are renewed before current permits expire. Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): Legally required permits, licenses or testing reports missing and no process in place Minor: Legally required permits, licenses or testing reports in place but no process in place to guarantee timely renewal Not Applicable: No permits or license required. No testing reports required Remote verification: Yes
B6.2 Workers operate machinery safely, including proper use of machine safeguards and emergency stop switches
Minimum requirements: Site observation: All machines have adequate safeguards, emergency stops and operators operate machine safely. Document review: Work instructions (if necessary or required) are available in worker language at machine. Management interview: Not applicable Worker interview: Workers demonstrate they understand the safe guards and use of emergency stops for their machine Rating: Priority: Worker operate machine unsafely with immediate risk of life or limb Major: Workers operate machine unsafely Minor: workers operate machine safely but work instructions (if required) not present in language of worker Not Applicable: No machine hazards Remote verification: Yes
B6.3 An adequate and effective machine-‐safeguarding program is implemented
Minimum requirements: Site observation: Machines have adequate safeguarding in good working condition and adequate emergency stops Document review: Auditee has a documented procedures on a machine-‐safeguarding program including machine risk assessment program (pre-‐purchase/pre-‐installation hazard review of all machinery and appropriate safeguarding is installed as needed to control the identified hazards), a method to identify
equipment needing safeguards, installation of safeguards, regular inspection and maintenance of machine and its safe guards and emergency stops. Machine and safe guard inspection and preventive maintenance records are available, adequate and up to date. Workers are trained on machine safety and the use of safeguards and emergency stops. Training materials and training records are available, adequate and up to date. Refresher training on machine safety is held annually. Management interview: Management can state what machine risk assessment and safeguarding program they have in place and how they ensure workers understand the safe use of the machine they operate. Worker interview: Workers can state how and when they have been trained last on the safety aspects of the machine they operate. Rating: Priority: Machines have clear hazards, no machine-‐safeguarding program is in place, workers operate machines unsafely Major: (default): workers operate machines unsafely; machine safe guarding program does not exist or is incomplete Minor: Workers operate machines safely. Machine safe guarding program is in place bit incomplete records or no annual refresher training Not Applicable: No machine hazards Remote verification: Yes
B7) Food, sanitation and housing
Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the Participant or a labor agent are to be maintained clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, and adequate heat and ventilation and reasonable personal space along with reasonable entry and exit privileges.
B7.1 All required health & safety licenses, permits, registrations and certificates related to food, sanitation and housing are in place and an adequate and effective process is established to ensure permits and licenses are up-‐to-‐date at all times
Minimum requirements: Site observation: Not applicable Document review: All legally required food, sanitation and housing permits are in place, available for review and valid. All food, sanitation and housing licenses are in place and available for review. Food, sanitation and housing testing reports are in place, available for review and meeting the conditions of permits, licenses or legally or customer requirements. Testing is done at a frequency stated in permits, licenses or by customers and does not exceed a period of two year. A document process is in place to ensure permits are renewed before current permits expire. Permit tracking is documented; canteen/kitchen workers have valid health certificates. If local regulations require food worker health inspections or other tests or certificates these are available and valid. Management interview: Management can state which occupational safety permits are required, what
testing is done and which process is in place to ensure permits are renewed before current permits expire. Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): Legally required permits, licenses or testing reports missing and no process in place; canteen/kitchen worker certificates are missing or expired Minor: Legally required permits, licenses or testing reports in place but no process in place to guarantee timely renewal Not Applicable: No permits or license required. No testing reports required Remote verification: Yes
B7.2 Dormitories are clean, safe and well maintained and meet international housing standards
Minimum requirements: Site observation: Dormitory and sanitary facilities (common areas, hallways, rest rooms, ...) are clean and properly maintained. An adequate number of exits from each floor with the exit doors accessible and unlocked are available. Doors may be locked only if panic hardware, such as crash bars, is used. Building is heated in the winter (if applicable). Windows provide light and ventilation. Adequate lighting (Lighting is adequate for reading, writing and other off-‐work activities) and safe and sufficient electricity sockets are provided. Lodging areas do not have cooking facilities unless separated. Adequate fire and heat detection, alarm and notification and fire suppression systems are in place. Adequate domestic waste disposal facilities and pest control measures in place. Adequate number of first aid boxes is available. Sufficient space is available for each worker and individual lockers for private secured storage are available. All facilities are separated by gender and adequate in number. For EICC guidance on workers’ accommodation processes and standards please see section 25 Document review: Drinking water testing reports are available for review and drinking water is tested regular basis (minimum bi monthly or what the regulatory requirement is). A cleaning and sanitation program is in place. Sanitation program tracking records are available and up to date. A pest control program is in place and pest control log is available for review and up to date. A preventive maintenance program (including emergency response supporting facilities) is in place with tracking records available and up to date. Management interview: Management can state how they ensure dormitory and sanitary facility standards and how they track the inspections and resulting actions. Worker interview: Workers can state that the dormitory facilities are adequate, clean and safe. Rating: Priority: Dormitory is unsafe with immediate risk of loss of facility, life or limb Major:(default): Dormitory and sanitary facility are unclean or do not minimum requirements with exception of documentation Minor: Dormitory and sanitary facility are safe, clean and adequate but procedures or records are missing or incomplete Not Applicable: No dormitory. Remote verification: No
B7.3 Canteens (cafeterias) are clean, well maintained, and managed in compliance with local health
regulations
Minimum requirements: Site observation: Canteen and kitchen is clean and well maintained. Food storage and preparation areas are clean. Food stored properly (not on the floor; refrigerated if necessary, raw and cooked food stored separately, ...). Exits must be adequate for the number of workers served. Food service workers wear masks, hairnets and gloves, as necessary to prevent food contamination. Food is used or disposed of before the marked expiration date. Canteens are provided with adequate hand washing facilities. Document review: Records of canteen and kitchen cleaning, disinfecting and/or pest control are available and up to date. If local regulations require facility health inspections or other tests or certificates these are available and valid. Safe food handling procedures and hygiene standards (in refrigeration, storage, and preparation areas) are in place and followed. Management interview: Management can state how the cafeteria safe standards are implemented and maintained Worker interview: Workers can state that cafeteria is clean and food preparation is hygienic. Rating: Priority: Canteen and kitchen is unsafe with immediate risk of loss of facility, life or limb Major: (default): Canteen and kitchen are unclean or do not meet minimum requirements with exception of documentation Minor: Canteen and kitchen are safe, clean and adequate but procedures or records are missing or incomplete Not Applicable: No cafeteria or food services. Remote verification: No
B7.4 Food service workers have undergone food safety training.
Minimum requirements: Site observation: Not applicable Document review: Training material and training records on safe food handling and storage are adequate, available and update. Refresher training happens at least annually. Management interview: Management can state how the cafeteria safe standards are implemented and maintained Worker interview: Workers can state that cafeteria is clean and food preparation is hygienic. Rating: Priority: Not applicable Major:(default): Training is missing or incomplete Minor: Annual refresher training is not performed Not Applicable: no cafeteria or food services. Remote verification: Yes
C. ENVIRONMENT
C1) Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.
C1.1 The facility has obtained all the legally required environmental permits, approvals, licenses and registrations.
Minimum requirements: Site observation: Not applicable Document review: All legally required environmental permits, approval and registrations are in place, available for review and valid. All environmental licenses are in place and available for review. A document process is in place to ensure permits are renewed before current permits expire. Permit tracking is documented Management interview: Management can state which environmental permits, approvals, registrations and licenses are required and which process is in place to ensure permits, approvals, registrations and licenses are renewed before current permits expire. Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): Legally required permits, approvals, registrations and licenses missing and no process in place to ensure permits are in place and renewed timely Minor: Legally required permits, approvals, registrations and licenses in place but no process in place to guarantee timely renewal Not Applicable: No permits, approvals, registrations or license required. Remote verification: Yes
C1.2 Reporting to environmental authorities as required by law is performed timely.
Minimum requirements: Site observation: Not applicable Document review: A documented process is in place to ensure reports are submitted before or on due date is in place. Report tracking is documented, adequate and available. All legally required environmental reports for last 3 years are available for review and meet legal requirements Management interview: Management can state which environmental reports are required, often and when and which process is in place to ensure reports are submitted before or on due date. Worker interview: Not applicable
Rating: Priority: Not Applicable Major: (default): Legally required reports missing, incomplete or no process in place to ensure legally required reports are submitted timely Minor: Legally required reports in place, process in place but reports submitted after due date to government body Not Applicable: No environmental reporting required. Remote verification: Yes
C2) Pollution Prevention and Resource Reduction
Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-‐using materials.
C2.1 Established adequate and effective programs, including targets, to: a) eliminate, reduce or control pollution (emissions, discharges, wastes) and b) conserve resources (energy, water, materials) in place.
Minimum requirements: Site observation: Recycle and re-‐use programs are visible. Emission points have control equipment (e.g. filters, scrubber, waste water treatment, ...) Document review: Written policies, processes, and requirements for environmental protection and pollution prevention/source reduction that is in accordance with laws, regulations, and standards are in place. Manufacturing and facility processes and equipment are provided with regular preventive maintenance to ensure ongoing efficient use of water and energy by preventing leaks, repairing damaged insulation, optimizing boiler and heater combustion, ... .A documented program is in place to reduce water and energy consumption, reducing hazardous material usage, reuse of production chemicals, reduction / reuse of packaging material or other site materials. The programs must be structured with roles and responsibilities, written procedures, targets, monitoring and reporting. If improvements are off track, corrective action plans need to be in place to bring improvement back on track. Regular reviews are conducted to identify improvement opportunities (at least once per year). It must include at least a target on water use and disposal, energy use, carbon emissions, use and disposal of chemicals, use and disposal of materials such as paper, packaging, ... Reporting must include the specific targets and the progress made at the time of Audit. Management interview: Management can state which reduction and pollution control programs they have, what the environmental annual targets are and which progress has been made. If progress is off track how they will correct to ensure progress is achieved in reporting period. Worker interview: Workers can state the environmental targets and progress Rating: Priority: No control or improvement programs in place. Environmental emissions are evident to cause imminent negative impact on community (gas releases, untreated waste water release, chemicals spill on hazardous substances on soil,..) Major: (default): No control or improvement plans in place, no imminent community hazard Minor: Control programs in place. Improvement plans in place, progress off track, no corrective action in
place to ensure target is met at end of reporting period Not Applicable: Not applicable Remote verification: Yes
C3) Hazardous Substances
Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
C3.1 Hazardous materials including wastes are properly categorized, labeled, handled, stored, transported and disposed using government-‐approved/licensed vendors as per local laws.
Minimum requirements: Site observation: Hazardous materials are categorized, handled, stored and transported within the facility adequately, e.g. segregation, secondary contained, ventilation, fire protection, appropriate storage materials, hazard signs and information (labels and MSDS), limited access, ... Document review: Copies of hazardous materials inventory, manifests and shipping papers are maintained on file for last 3 years or the time period stipulated by local laws legal requirements. Documented procedures for reception, storage, dispensing, use, return and disposal are available and adequate. Inspection records of hazardous materials and their points of storage and use are maintained and complete. If any area of improvement is noted a corrective action plan is in place, monitored and completed. If the corrective action plan is off track actions are taken to complete it within the assigned due date. Hazardous material information (labels and MSDS) is available at the points of use and storage in the language of the worker. Documents proving Auditee uses only vendors approved and licensed by the local regulatory authorities for transporting and disposing of hazardous waste. Copies of all hazardous waste vendor licenses/approvals are on file. A process to ensure the licenses are periodically reviewed and are current is in place. Copies of hazardous waste manifests/shipping papers are maintained on file for all waste shipments. The records are maintained for the time period stipulated by local laws. Management interview: Management can state which hazardous materials are used on site, what the legal and customer requirements are on the use and storage of hazard materials and what procedures are in place to manage and minimize the risk of the use of hazardous materials. Management can also state which authorized waste transporter and vendors are used and how manifest are kept. Worker interview: Workers who work with chemicals or are responsible for chemical storage, handling, use and disposal can describe what hazardous materials procedure are in place for their specific function Rating: Priority: Hazardous materials (including wastes) are used, handled, stored or disposed of which could result in imminent loss of facility, life or create sever bodily damage. Major: (default): Hazardous materials (including wastes) are used, handled, stored or disposed of in a systemic way but 2 or more minimum requirements are not implemented Minor: Hazardous materials (including wastes) are used, handled, stored or disposed of in a systemic way but the documentation is incomplete
Not Applicable: No hazardous materials (including wastes) used or stored on site. Remote verification: Yes
C3.2 Workers who work with hazardous substances are provided adequate and effective training.
Minimum requirements: Site observation: Not applicable Document review: Training material and training records are available, adequate and up to date on hazardous chemicals (including waste) use, handling, storage and disposal. Workers responsible for storage, clean up or dispose of chemical releases should receive specialized training. Management interview: Management can state which training are provided to workers on use and storage of hazardous chemicals when the last training was held. Specialized training is refreshed for workers responsible for storage, clean up and disposal of hazardous chemicals. Worker interview: Workers can describe where they can find material/chemical safety data sheets and how to read them, when they were last trained on use and storage of hazardous chemicals. Workers responsible for clean up or dispose of chemical releases should be able to describe the content of the specialized training and the PPE that is to be used. Rating: Priority: Not Applicable Major: No training provided on hazardous chemicals (including waste) use, handling, storage and disposal Minor: (default): Adequate training is provided but documentation is incomplete or annual specialized refresher is lacking Not Applicable: No hazardous chemicals (including waste) used, handled or stored on site or disposed. Remote verification: Yes
C3.3 Waste vendor(s) have been Audited to verify that waste is handled, stored and disposed of in accordance with local regulations, permit conditions and contract requirements
Minimum requirements: Site observation: Not applicable Document review: Assessments, visit minutes or Audit reports, with possible areas for improvement are available for each hazardous waste vendor used by the Auditee. The reports should not be older than 2 years. If corrective or improvement action are identified then these are tracked for implementation and are completed or on track. If corrective actions are of track then additional actions are identified to ensure corrective actions are completed by due date. The periodic Audit should evaluate whether the vendor (Hazardous waste handler AND transporter) is complying with: contract terms and conditions, the EICC provisions, and local legal requirements. The Audit should include an on-‐site visit by the supplier to verify compliance. Management interview: Management can state how many hazardous waste transporters and handlers are used, what process is used to verify on site these vendors and when the last Audit of waste handler
occurred Worker interview: Not applicable Rating: Priority: Not Applicable Major: No on site Audit/assessment of hazardous waste transporters and handlers is performed Minor: (default): On site Audit / assessment of hazardous waste transporters and handlers is performed but documentation is incomplete or corrective action are missing / off track Not Applicable: No hazardous chemical waste generated or stored on site. Remote verification: Yes
C4) Wastewater and Solid Waste
Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be characterized, monitored, controlled and treated as required prior to discharge or disposal.
C4.1 Solid waste is managed and disposed of in accordance with applicable legal requirements
Minimum requirements: Site observation: Wastes are categorized, handled, stored and transported within the facility adequately, e.g. segregation, secondary contained, ventilation, fire protection, appropriate storage materials, hazard signs and information (labels and MSDS), limited access, ... Document review: Copies of waste inventory, manifests and shipping papers are maintained on file for last 3 years or the time period stipulated by local laws legal requirements. Inspection records of waste and their points of storage are maintained and complete. If any area of improvement is noted a corrective action plan is in place, monitored and completed. If the corrective action plan is off track actions are taken to complete it within the assigned due date. Waste information (labels and MSDS) is available at the points of storage in the language of the worker. Documents proving Auditee uses only vendors approved and licensed by the local regulatory authorities for transporting and disposing of waste. Copies of all waste vendor licenses/approvals are on file. A process to ensure the licenses are periodically reviewed and are current is in place. Copies of waste manifests/shipping papers are maintained on file for all waste shipments. The records are maintained for the time period stipulated by local laws legal requirements. Management interview: Management can state which waste are stored on site, what the legal requirements are on the storage of waste and what procedures are in place to manage and minimize the risk of the storage of waste. Management can also state which authorized waste transporter and vendors are used and how manifest are kept. Worker interview: Workers who work with waste or are responsible for waste storage can describe what waste procedures are in place for their specific function. Ask the responsible person how they know that the facility is in compliance with applicable regulations.
Rating: Priority: Waste are stored in conditions which have imminent risk to facility, life, limb or could cause significant impact on the community Major: (default): Waste are stored and disposed of in a systemic, appropriate and legal way but 2 or more minimum requirements are not implemented Minor: Waste are stored and disposed of in a systemic, appropriate and legal but the documentation is incomplete Not Applicable: No solid was generated or stored on site. Remote verification: Yes
C4.2 Effluent discharges (industrial/process wastewater, sewage and storm water) meet the discharge
limits for regulated constituents.
Minimum requirements: Wastewater includes industrial wastewater, storm water and domestic waste water Site observation: Waste water is adequately transported, stored, treated (if required) and disposed of. Auditee treats industrial and/or sanitary wastewater onsite in accordance with local laws and permit requirements. Wastewater is discharged to a municipal treatment system or to surface water (if allowed by local laws and regulations) Document review: Monitoring and reporting records from the past 36 months are available for review, in line with legal requirements and complete. If Nonconformances have been noted in the past a root cause and corrective action to address the Nonconformance is in place. Wastewater treatment equipment is included in a routine preventive maintenance program, adequate documentation on program and tracking records are available. Documented procedures for waste water storage; treatment and discharge per local legislation are adequate, available and up to date. At least three test results 24h -‐ composite over three month showing compliance with the legal and permit requirements. These results cannot be older than 2 year. Training materials and training records for workers responsible for operating and maintaining wastewater treatment systems are available, adequate and up to date. Management interview: Management can state which waste water are generated on site, how these are treated, disposed of and what program is in place to monitor legal compliance. Management can state how workers involved in waste treatment are trained. Worker interview: Workers responsible for operating and maintaining wastewater treatment systems can state how and when they have been trained. They can accurate relate the content of the training Rating: Priority: Untreated wastewater is released which can cause an imminent risk to community Major: (default): Wastewater is untreated, or not complying with legal discharge requirement. Workers responsible for operating and maintaining wastewater treatment systems are untrained. Monitoring is not carried out on a regular basis. Minor: Waste water is in compliance with legal requirements, testing is not done a regular basis Not Applicable: No wastewater generated or stored on site -‐ site does not have legal requirements for storm water. Remote verification: Yes
C5) Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-‐products generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge.
C5.1 Air emissions meet the discharge limits for regulated constituents
Minimum requirements: Site observation: Auditee treats air emissions in accordance with local laws and permit requirements. Document review: Monitoring and reporting records from the past 36 months are available for review, in line with legal requirements and complete. If Nonconformances have been noted in the past a root cause and corrective action to address the Nonconformance is in place. Air emissions treatment equipment is included in a routine preventive maintenance program, adequate documentation on program and tracking records are available. At least three test results showing compliance with the legal and permit requirements are available. These results cannot be older than 2 year. Training materials and training records for workers responsible for operating and maintaining air emissions treatment systems are available, adequate and up to date. Management interview: Management can state which air emissions are generated on site, how these are treated and what program is in place to monitor legal compliance. Management can state how workers involved in air emission treatment are trained. Worker interview: Workers responsible for operating and maintaining air emission treatment systems can state how and when they have been trained. They can accurate relate the content of the training Rating: Priority: Untreated air emissions are released which can cause an imminent risk to community Major: (default): Air emissions are untreated, or not complying with legal discharge requirement. Workers responsible for operating and maintaining air emission treatment systems are untrained. Monitoring is not carried out on a regular basis Minor: Air emissions in compliance with legal requirements, testing is not done a regular basis Not Applicable: No air emissions -‐ site does not have legal requirements for air emissions. Remote verification: Yes
C5.2 Environmental noise levels are within regulatory limits
Minimum requirements: Site observation: No excessive boundary noise is observed Document review: Monitoring and reporting records from the past 36 months are available for review, in line with legal requirements and complete. If Nonconformances have been noted in the past a root cause and corrective action to address the Nonconformance is in place. At least three test results showing compliance with the legal and permit requirements are available. Management interview: Management can state which environmental noise complaints if any they have received and what program is in place to monitor legal compliance. Worker interview: Workers responsible for operating and maintaining air emission treatment systems can state how and when they have been trained. They can accurate relate the content of the training
Rating: Priority: Not applicable Major: (default): Environmental noise is not complying with legal requirement. Minor: Environmental noise is in compliance with legal requirements, testing is not done a regular basis Not Applicable: Site does not have legal requirements on environmental noise Remote verification: Yes
C6) Product Content Restrictions
Participants are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances, including labeling for recycling and disposal.
C6.1 An effective program is in place to meet legal and customer requirements for product content as a formal part of their procurement and manufacturing processes including effective processes, procedures and records are in place to measure or document the chemical composition of products.
Minimum requirements: Site observation: Not applicable Document review: Legal and customer product content requirements are managed through a formal program including how materials, packaging and components are procured. Testing procedures required for purchased materials and components to verify that they conform to customer and legal requirements are effectively implemented, monitored and tracked. Regular Audits and assessments of the procedures are performed to verify conformance. A formal process in place to address discovery of non-‐compliant materials or components and corrective action are tracked, implemented, on track or additional actions are taken to ensure completion at due date. The formal program needs to include: a documented review process for comparing customer requirements to own specifications and procedures to ensure they are in conformance with customer requirements, provide statements and/or certificates of conformance to its customers upon request, random analytical testing of products/components, and the data is available for customer review. Testing methods comply with applicable codes, regulations and customer requirements, documented requirements for compliance with the product content restrictions to its material /parts suppliers, obtains specifications, statements and/or certificates of conformance from its suppliers and these documents are available for customer review, requires analytical data from its material/parts suppliers, and the data is available for customer review. Monitoring & reporting records from the past 36 months pertaining to product content conformance to legislation, regulation and customer requirements are complete and available. Management interview: Management can state how they ensure conformance in product content with legal and customer requirements, including the detail of the formal program in place Worker interview: Not applicable Rating: Priority: No program is in place AND product has been subject to customer or regulatory action Major: No program is in place or formal program in place with 2 or more of the minimum requirements missing
Minor: (default): A formal program is in place but incomplete or documentation is incomplete/outdated Not Applicable: Site does not any legal requirements or customer demands on this issue. Remote verification: Yes
C6.2 Effective processes and procedures are in place to request and obtain relevant chemical composition information from their suppliers, including certificates and analytical reports
Minimum requirements: Site observation: Not applicable Document review: Regular Audits and assessments of the procedures are performed to verify conformance. Testing methods comply with applicable codes, regulations and customer requirements, documented requirements for compliance with the product content restrictions to its material /parts suppliers, statements and/or certificates of conformance from its suppliers and these documents are available for customer review, requires analytical data from its material/parts suppliers, and the data is available for customer review. Test data and certificates are available to demonstrate conformance. Results of product content Audits and inspections performed by the supplier, customers and regulatory agencies are available for review. Records are available showing that any identified nonconformities have been adequately addressed. As a minimum companies need to have a declaration whether their products contain any Substances of Very High Concern (REACH) and whether their products are ROHS compliant, Test data and certificates are available to demonstrate conformance. Results of product content Audits and inspections performed by the supplier, customers and regulatory agencies are available for review. Records are available showing that any identified nonconformities have been adequately addressed. Management interview: Management can state what product testing and documentation requirements are implemented to communicate and proof conformance with legal and customer product content requirements Worker interview: Not applicable Rating: Priority: Not Applicable Major: Test results, Audits reports or certificates are not available Minor: (default): Test results, Audits reports or certificates are available but incomplete or frequency is too low Not Applicable: Site does not have any legal requirements or customer demands on this issue. Remote verification: Yes
D. ETHICS
D1) Business Integrity
The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement (covering promising, offering, giving or accepting any bribes). All business dealings should be transparently performed and accurately reflected on Participant’s business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-‐corruption laws.
D1.1 Adequate and effective Code of Business Ethics or Standards of business conduct, endorsed by senior management is established
Minimum requirements: Code covers at minimum honesty, integrity, intellectual property protection, bribery, corruption, fraud, embezzlement, extortion; legal, ethical, fair business/marketing practices, reporting violations, whistleblower protection, kickbacks, bribes, embezzlement; unlawful payments, ... Site observation: Not applicable Document review: A formal policy on business ethics is communicated to workers, managers and supervisors, customers and suppliers. It should include procedures to investigate allegations of ethics misconduct and specific consequences for violations of the policy. The company's business ethics policies are incorporated in contracts with suppliers and on-‐site contractors. Management interview: Management can detail the content of the Ethics policy, how is communicated and how this is incorporated in contracts and how allegations are investigated Worker interview: Workers can state that there is a Ethics Policy/Code of Ethics Conduct Rating: Priority: Not Applicable Major: (default): No standard established, no implementation or 20 percent or more of workers are not aware that there is a Code Minor: Standards are established but not fully implemented or less than 20 percent of workers are not aware that there is a Code Not Applicable: Not applicable Remote verification: Yes
D1.2 All workers/employees are provided adequate and effective communication/training on the code of ethical conduct.
Minimum requirements: Site observation: Not applicable Document review: Regular business ethics training for workers and managers that covers all elements of its policy (the refresher training is at least annual). Training materials and training records are available, adequate and up to date. Management interview: Management can state when the last training for management and workers was held Worker interview: Workers can state when they were last trained and accurate state the content of the Ethics Policy Rating: Priority: Not Applicable Major: Training of management, supervisors and workers on ethics policy is not implemented or 20 percent or more of workers, supervisors or managers cannot remember when they were last trained Minor: (default): Training of management, supervisors and workers on ethics policy is implemented but the refresher training is not done or documentation is incomplete or less than 20 percent of workers, supervisors or managers cannot remember when they were last trained Not Applicable: Not applicable Remote verification: No
D1.3 Effective procedures to monitor ethics performance is in place
Minimum requirements: Site observation: Not applicable Document review: A formal performance management system with indicators and regular (at least quarterly) updates is in place, appropriate, available and complete. The indicators show a positive trend towards higher ethics performance or at least status quo. If a negative trend is detected, implementation plans are available and on track, if off track additional action items are added to ensure completion on due date. Management interview: Management can describe how to track, review and implement correction on their ethics performance. Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): No ethics performance program in place Minor: Ethics performance program in place but incomplete, inappropriate, negative ethics trend or corrective action implementation is off track Not Applicable: Not applicable Remote verification: No
D1.4 Business ethics/integrity procedures are communicated effectively to all subcontractors, suppliers, business partners and relevant parties
Minimum requirements: Site observation: Not applicable Document review: Business ethics communication/training for all subcontractors, suppliers, business partners and other relevant parties is in place that covers all elements of its policy. Communications/training materials and communications/training records are available, adequate and up to date. Management interview: Management can state when the last communication/training for subcontractors, suppliers, business partners and other relevant parties was held Worker interview: Not applicable Rating: Priority: Not Applicable Major: Training of subcontractors, suppliers, business partners and other relevant parties on ethics policy is not implemented Minor: (default): Training of subcontractors, suppliers, business partners and other relevant parties on ethics policy is implemented but documentation is incomplete Not Applicable: Not applicable Remote verification: No
D1.5 An effective risk assessment process to determine vulnerabilities and prioritize corruption risks taking
into account business circumstances (country of operations, stakeholders, ...) is established
Minimum requirements: Risk assessment covers at minimum honesty, integrity, intellectual property protection, bribery, corruption, fraud, embezzlement, extortion; legal, ethical, fair business/marketing practices, reporting violations, whistleblower protection, kickbacks, bribes, embezzlement; unlawful payments, ... Site observation: Not applicable Document review: A formal risk assessment on ethics procedure is implemented. The risk assessment is at least annual. The risk assessment on ethics takes into account the specific characteristics of business, community, culture, legal environment and country/region specific issues. Identified risks have action plans to minimize the risk. The actions are tracked and implemented or on track. If they are off track then additional actions are taken to ensure implementation by the due date. Management is trained in the ethics risk assessment and action plan procedure. Training materials and training records are available, adequate and up to date Management interview: Management can state when the last risk assessment on ethics was and which were the highest risks established an which actions were taken to reduce these risks Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): No ethics risk assessment in place, or actions plan to minimize the ethics risks Minor: Ethics risk assessment procedure, risk assessment, action plan in place. Training was not completed, actions are off track, risk assessment is older than 1 year
Not Applicable: Not applicable Remote verification: No
D1.6 Employees who refuse to participate in bribery or facilitation payments are supported by the business
and will not suffer demotion, penalty or other adverse consequences even if this action may result in the enterprise losing business.
Minimum requirements: Site observation: Not applicable Document review: A formal procedure is available to protect workers/employees from refusing to do anything in Nonconformance with the ethics policy and communicate/volunteer their decision. For statistical sample of population personnel files, leave records, disclosure records confirm no negative consequence for any worker/employee refusing to do anything in Nonconformance with the ethics policy and communicate/volunteer their decision Management interview: Management can state the detail of how employees/workers are protected from refusing to do anything in Nonconformance with the ethics policy and communicate/volunteer their decision Worker interview: workers can state that they have refused to do what is non conform to the ethics policy without retribution, Rating: Priority: Workers/employees are forced to violate the ethics policy under threat of negative consequences Major: (default): No policy or procedure in place to protect workers from refusing to do anything in Nonconformance with the ethics policy and communicate/volunteer their decision Minor: Policy or procedure in place to protect workers from refusing to do anything in Nonconformance with the ethics policy and communicate/volunteer their decision but documentation cannot demonstrate implementation Not Applicable: Not applicable Remote verification: No
D1.7 Records of employees declaring any personal interest or conflict of interests that may influence their
judgment are kept and available
Minimum requirements: Site observation: Not applicable Document review: A formal procedure is available promoting workers/employees to declare conflicts of interest, how these declarations are recorded and how workers/employees are protected from retribution. For statistical sample of population select personnel files, leave records, disclosure records to confirm no negative consequence to any worker/employee who declared a conflict of interest Management interview: Management can state the detail of how employees/workers are encourage to declare conflict of interest, how this is recorded and what actions are taken to protect the worker/employee and do the business taking into account the conflict of interest. Worker interview: workers can state that they have declared a conflict of interest and it was recorded in their personnel file
Rating: Priority: Conflict of interest is used to promote business interests Major: (default): No policy or procedure in place promoting workers/employees to declare conflicts of interest, how these declarations are recorded and how workers/employees are protected from retribution Minor: Policy or procedure in place promoting workers/employees to declare conflicts of interest, how these declarations are recorded and how workers/employees are protected from retribution but documentation cannot demonstrate implementation Not Applicable: Not applicable Remote verification: No
D2) No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.
D2.1 Effective and written policy that ensures gifts to or from suppliers and customers is not excessive in cost and frequency and hospitality, expenses or promises as such that may compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with, or direct business to, any person, or to influence the course of the business or governmental decision-‐making process is established.
Minimum requirements: If labor agents are used then these procedures need to be implemented at labor agent level. Indirect workers should know Auditee and labor agent procedures on gifts. Site observation: Not applicable Document review: A formal procedure that ensures gifts to or from suppliers and customers is not excessive in cost and frequency and includes a regularly monitoring of its business to ensure it workers or agents do not make or accept improper offers of payments or gifts. Training material for management, supervisors and workers and training records are available, adequate and up to date. Annual refresher training is held for all managers, supervisors and workers Management interview: Management can state the policy on gifts, its maximum value and frequency and how workers and supervisors are trained. Supervisors can state when they were last trained and the content of the gift policy Worker interview: Workers can state when they were last trained and the content of the gift policy Rating: Priority: Not Applicable Major: (default): No procedures established or implemented or training Minor: Procedures established and implemented, Training has been initially done but no annual refresher training Not Applicable: Not applicable Remote verification: Yes
D2.2 Effective procedures for addressing its workers or agents suspected of making or accepting improper offers of payments or gifts and attempted bribery in all forms, the appropriate investigation and subsequent sanctions are applied are in place
Minimum requirements: Site observation: Not applicable Document review: Formal procedures for investigating and addressing allegations of improper business conduct by workers, managers or person's/Auditee 's agents are in place. Records of such cases are available; clearly show investigation methods, objective data and testimony, decision and actions in line with disciplinary procedure if individual has not followed ethics policy and for Auditee in preventive action. Management interview: Management can state how it would investigate allegation of bribery, and depending on the result what action would follow Worker interview: Not applicable Rating: Priority: Not Applicable Major: No investigation procedure for allegation of bribery is in place, procedure is in place but does not align with appropriate consequences (disciplinary procedure,...) Minor: (default): Investigation procedure for allegation of bribery is in place but actions incomplete for Auditee or person/agent Not Applicable: Not applicable Remote verification: Yes
D3) Disclosure of Information
Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain is unacceptable.
D3.1 Business activities are reported in accordance with local laws and regulations
Minimum requirements: Site observation: Not applicable Document review: Good accounting policies, procedures, and record keeping verified through an annual periodic third party financial Audits to confirm that accounts are in order. A system of internal controls to ensure the accuracy of information is in place. Government reporting as per legal requirements is done timely and reports are complete. Financial and annual reports about its business operations in accordance with applicable legal requirements and good industry practice are available. Management interview: Management can state which reports they provide government agencies at what time and which third party financial Audit firms was who performed the annual financial Audit Worker interview: Not applicable
Rating: Priority: Not Applicable Major: (default): No systems in place to verify accuracy of information, no annual third party financial report, no required government reporting Minor: System are in place but incomplete, annual financial Audit report not by independent and qualified third party or government reporting late Not Applicable: Not applicable Remote verification: Yes
D3.2 No evidence of record falsification or misrepresentation
Minimum requirements: Site observation: Not applicable Document review: Inspection/assessment/Audit procedure is in place to ensure records are not falsified and accurate. Unintentional errors are out of scope for this question. Procedures exist to prevent and investigate misrepresentation by workers, managers and their agents. Auditors will cross check a number of different business records to ensure records align and are accurate Management interview: Management can state which safe guards they have in place to ensure misrepresentation by workers, managers and their agents is prevented, what inspection/verification is has to ensure records are not falsified and accurate Worker interview: Not applicable Rating: Priority: Evidence of misrepresentation or falsification of records is confirmed, Auditee does not acknowledge or is unwilling to take action Major: (default): Evidence of misrepresentation or falsification of records is confirmed, Auditee is willing to take action Minor: Not applicable Not Applicable: Not applicable Remote verification: Yes
D4) Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know-‐how is to be done in a manner that protects intellectual property rights.
D4.1 Effective procedures to ensure the protection of intellectual property (their own and that of their customers) are established
Minimum requirements: Site observation: Not applicable Document review: Formal procedures to ensure non-‐disclosure and protection of information about its customers, channel partners, suppliers, workers, and other business partners in accordance with applicable laws and regulations are in place. A program and/or procedures used to review intellectual property ownership and ensure protection of intellectual property is in place. Confidentiality and
nondisclosure agreements are in place, on file and available for review. Training material and training records on intellectual property and its protection is available, adequate and update. Managers receive annual refresher training on Intellectual property and its protection Management interview: Management can state what procedures they have to identify, protect intellectual property, which protection agreements (NDA, confidentiality,...) are in place and how training is carried to ensure effective implementation of procedures Worker interview: Workers can clearly state what Intellectual property is and what measures are in place within their job/function/responsibility to protect it. Rating: Priority: Not Applicable Major: (default): No procedure, agreements or training on intellectual property protection Minor: procedures, agreements and training are in place but agreements are incomplete or no annual refreshers training Not Applicable: Not applicable Remote verification: Yes
D5) Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must be available.
D5.1 An effective program to ensure advertising statements are not false or misleading and meet fair business and advertising legal requirements is in place
Minimum requirements: Includes all kinds of advertizing and company communications (job, product, company/facility promotion (booklet/flyer), commercial advertizing, website, ...) Site observation: If advertizing (job or other is posted) then these are accurate Document review: Public information must not make false or misleading statements about the Auditee's products, services, opportunities, position, .... Company information must meet legal requirements. Formal program to ensure public Auditee statements are not false or misleading and they meet fair business and advertising legal requirements. Management interview: Management can state what procedures and checks are in place to ensure public information is accurate and not misleading Worker interview: Not applicable Rating: Priority: Advertizing is confirmed misleading and Auditee does not want to retract advertizing Major: Advertizing is confirmed misleading and Auditee will retract advertizing, no procedures in place to ensure advertizing is not misleading Minor: (default): Procedures are in place but not well understood by those involved or procedures are incomplete Not Applicable: Not applicable
Remote verification: Yes
D5.2 Effective and written policy prohibiting collusion is established and communicated to workers, employees and business partners
Minimum requirements: Site observation: Not applicable Document review: Safeguards are in place to prevent collusion with other companies on product pricing or other factors that could reduce competition. A formal policy prohibiting collusion that also includes the consequences for managers, employees and business partners or any of their agents. A formal investigation procedure for any allegations of collusion is in place, which includes monitoring procedures related to fair competition. Training is provided to workers, employees, managers and business partner on collusion and managers receive and annual refresher training. Training material and training records are available, adequate and up to date. General public record search by Auditors is performed to learn if the Courts have found the Auditee colluding in some way. Management interview: Management can state when they were training on prohibition of collusion/fair business and accurately detail the content of the prohibition of collusion/fair business policy as well as how and when workers, employees and business partners are trained on this policy Worker interview: Workers can state when they were training on prohibition of collusion/fair business and accurately detail the content of the prohibition of collusion/fair business policy Rating: Priority: Court has confirmed collusion and Auditee has not taken any further internal action Major: (default): Policy or procedures or training is not in place or incomplete Minor: Policy and procedures are in place and complete but annual refresher training for management has not occurred Not Applicable: Not applicable Remote verification: Yes
D5.3 A formal and effective process to protect customer information is established
Minimum requirements: Site observation: Not applicable Document review: A formal policy and program is in place to protect the information the Auditee receives from its customers as part of the contracting process. Such information would include: names and contact information for key customer personnel; contract pricing and volumes; names of sub-‐contractors and materials/components suppliers, ... This includes at a minimum a non-‐disclosure agreement (separate or part of employment contract) for workers and employee. Managers and supervisors are trained on the information protection procedures. Training material and training records are available, adequate and up to date. Management interview: Management can state which measures are in place to protect customer information and how these measures are communicated/trained within the organization Worker interview: Workers can state that they have signed NDA language and were informed how to protect customer information
Rating: Priority: Not Applicable Major: No NDA language for workers or employees, no customer information protection procedures Minor: (default): NDA and customer information protection procedures in place but incomplete or training is not provided Not Applicable: Not applicable Remote verification: Yes
D6) Protection of Identity
Programs that ensure the confidentiality and protection of supplier and employee whistleblowers are to be maintained.
D6.1 A way to confidentially report suspected ethical misconduct is available to workers and protects them from retaliation or other consequences
Minimum requirements: Whistleblower: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official body. Site observation: Confidential reporting channels are clearly communicated and visible (grievance box, hotline, hotmail, third party line, ....) Document review: Clear communications channels so that workers at the Auditee operations are comfortable reporting violations or issues of concern and so that reporting is encouraged. An established process for workers to anonymously report suspected violations of business conduct standards in order to prevent possible retaliation. Detailed procedures are in place to protect whistleblower identity as part of the allegation investigation process. Training material and training records are available, adequate and up to date. Annual refresher training is provided to all. Workers are provided with written information on how to report ethical or legal concerns. Management interview: Management can clearly state which confidential and anonymous reporting mechanisms are in place, how these are monitored and actioned with integrity and how the procedures are training including refresher training Worker interview: Workers can state how they can confidentially and anonymously report ethical misconduct and how management has assured them of non-‐retaliation Rating: Priority: Confirmed whistleblower has been retaliated against, Auditee actively investigates anonymous whistleblower Major: (default): No confidential and anonymous reporting mechanisms, no procedure to safeguard against whistleblower retaliation, no training in place Minor: Procedures are in place but not complete. Confidential and anonymous reporting mechanisms in place, training in place but no annual refresher Not Applicable: Not applicable
Remote verification: Yes
D6.2 A way to confidentially report suspected ethical misconduct is available to employees of suppliers and protects them from retaliation or other consequences
Minimum requirements: Whistleblower: Any person who makes a disclosure about improper conduct by an employee or officer of a company, or by a public official or official body. Site observation: Not applicable Document review: Clear communications channels so that employees at suppliers are comfortable reporting violations or issues of concern and so that reporting is encouraged. An established process for employees at suppliers to anonymously report suspected violations of business conduct standards in order to prevent possible retaliation. Detailed procedures are in place to protect whistleblower identity as part of the allegation investigation process. Communications to suppliers are available, adequate and up to date. Annual refresher communication is provided to suppliers. Implementation of communication to employees of suppliers is verified, available and adequate. Management interview: Management can clearly state which confidential and anonymous reporting mechanisms are in place, how these are monitored and actioned with integrity and how the procedures are training including refresher training Worker interview: Not applicable Rating: Priority: Confirmed whistleblower has been retaliated against, Auditee actively investigates anonymous whistleblower Major: (default): No confidential and anonymous reporting mechanisms, no procedure to safeguard against whistleblower retaliation, no communication in place, no supplier implementation verification. Minor: Procedures are in place but not complete. Confidential and anonymous reporting mechanisms in place, communication in place but no annual refresher Not Applicable: Not applicable Remote verification: Yes
D7) Responsible Sourcing of Minerals
Participants shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Participants shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to customers upon customer request.
D7.1 A policy to reasonably assure that purchasing of the 3TG minerals does not directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries with an effective procedures to establish and monitor responsible sourcing of minerals and capable of making the due-‐diligence measures available upon request from customers.
Minimum requirements: 3TG minerals= Tantalum, Tin, Tungsten and Gold Site observation: Not applicable Document review: Clear policy or procedure is in place to avoid knowingly purchasing 3TG minerals that directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries. A management system exists to support the policy/procedures and is capable of demonstrating procurement practices in line with the EICC Code of Conduct’s expectation on responsible sourcing of minerals. The supplier should have a documented process to actively verify compliance with these requirements. Management interview: Management can state that the facility has a policy against knowingly purchasing 3TG minerals that directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries. Worker interview: Interviewed employees (in procurement or sourcing) state that knowingly purchasing 3TG minerals that directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries, is a violation of company policy. Rating: Priority: Confirmed purchasing of minerals from conflict sources in the Democratic Republic of Congo or surrounding countries and no documented action taken by supplier to address the issue. Major: (default): No Clear policy or procedure is in place to avoid knowingly purchasing 3TG minerals that directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries. Minor: Clear documented policy or procedure is in place to avoid knowingly purchasing 3TG minerals that directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries, but no process to actively verify compliance with these requirements or no evidence exists that the management system used to establish and monitor responsible sourcing of minerals, is capable of making the due-‐diligence measures available upon request from customers. Not Applicable: No Tin, Tungsten, Tantalum and Gold (3TG) mineral material or containing components Remote verification: Yes
D8) Privacy
We are committed to protecting the reasonable privacy expectations of personal information of everyone we do business with, including suppliers, customers, consumers and employees. Comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
D8.1 A formal and effective process to protect privacy is established
Minimum requirements: Site observation: Not applicable Document review: A formal policy and program is in place to protect privacy: Personal information of everyone we do business with, including suppliers, customers, consumers and employees. The program complies with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared. Workers and employees are trained on the information protection procedures. Training material and training records are available, adequate and up to date. Management interview: Management can state which measures are in place to protect privacy and how these measures are communicated/trained within the organization Worker interview: Workers can state that they understand how their personal information is protected and when they last received training Rating: Priority: Legal or customer identified Privacy requirements were identified and notified to Auditee, Auditee did not make corrective action Major: No privacy protection procedures, no training, protection procedures do not comply with legal and customer requirements Minor: (default): Privacy protection procedures in place but incomplete or training is not provided or workers do not clearly understand how their information is protected Not Applicable: Not applicable Remote verification: Yes
D9) Non-‐Retaliation
Participants should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.
D9.1 Effective procedures to ensure non retaliation are established and communicated
Minimum requirements: Retaliation = to repay like for like (in kind). There are three essential elements of retaliation: 1) protected activity (e.g. opposition to discrimination, opposition to non ethical behavior, or participation in a grievance process), 2) adverse action by Auditee or its agents., 3) causal connection between the protected activity and the adverse action.
Site observation: Not applicable Document review: Clear communications to workers/employees is available stating non-‐retaliation. Detailed procedures are in place to investigate possible retaliation allegations. Training material and training records are available, adequate and up to date. Annual refresher training is provided to all. Management interview: Management can clearly state how retaliation is prevented and monitored and how the procedures are communicated and training including refresher training is deployed
Worker interview: Workers can state how management has assured them of non-‐retaliation and they are unaware of any retaliation case Rating: Priority: Auditee actively retaliates (even to one substantiated case) Major: (default): No procedure to safeguard against retaliation, no training in place Minor: Procedures are in place but not complete or training in place but no annual refresher Not Applicable: Not applicable Remote verification: Yes
E. MANAGEMENT SYSTEM
E1) Company Commitment
Corporate social and environmental responsibility policy statements affirming Participant’s commitment to compliance and continual improvement, endorsed by executive management.
E1.1 Adequate and effective policies/codes that are endorsed by executive management, covering: A) Labor B) Health & Safety C) Environment and D) Ethics.
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Not applicable Document review: Statement signed/endorsed by the highest level manager at the facility or company with a stated commitment to regulatory compliance and other requirements and commitment to continuous improvement. The policy statement is appropriate for the nature and scope of the facility’s operations. Note executive endorsement can be silent when policy is publicly displayed (e.g. intra or internet site) Management interview: Management can state and understand the detail of the policy Worker interview: Workers can state and understand the detail of the policy Rating: Priority: Not Applicable Major: (default): 2 or more components are missing, does not contain commitment to continuous improvement and legal compliance Minor: No endorsement of senior management, 1 component missing Not Applicable: Not applicable Remote verification: Yes
E2) Management Accountability and Responsibility
The Participant clearly identifies company representative[s] responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.
E2.1 Responsibilities and authorities are adequately and effectively defined and assigned for all employees/workers (senior managers to workers) for implementation of management systems, and for compliance with laws, regulations and codes pertaining to: A) Labor B) Health & Safety C) Environment and D) Ethics.
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Not applicable Document review: A management representative(s) has been assigned responsibility for implementing programs to ensure compliance with laws and regulations and the requirements of the EICC, the management representative is authorized to implement programs, procedures and corrective actions as needed for regulatory compliance and EICC conformance, the responsibilities and authority of the management representative are documented in position plans, job descriptions and/or the facility's management system documentation, documented procedures for responsibility assignment in normal and emergency situations at all levels of the organization, raining materials and training records on responsibilities are available, adequate and up to date. Management interview: Management can state the responsibilities and authorities of each level within the organization and how these are documented and communicated Worker interview: Workers can state their responsibilities against each of the components Rating: Priority: Not Applicable Major: (default): 2 or more components are missing, no identified management representative authorized to implement the management system of a component Minor: Any item of guidance missing Not Applicable: Not applicable Remote verification: Yes
E2.2 An adequate and effective management review and continuous improvement process for A) Labor, B) Health & Safety, C) Environment and D) Ethics performance and management systems is established
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Not applicable Document review: A document describing the management system review process, including the
agenda and review frequency. Minutes, presentation materials, or other records of management review meetings are available, clearly stating date, who was present (including senior manager), progress towards meeting objectives; results of Audits; completion of corrective actions; risks/issues; company Policy; and other information needed to determine the effectiveness of the management system and identify improvement opportunities, which result in a formal improvement action plan. Frequency is not less frequently than annual. Management interview: Management can state the management system review process, when the last meeting was held and hat action results from the review Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): 2 or more components are missing, senior management does not assess annually Minor: 1 component missing Not Applicable: Not applicable Remote verification: Yes
E3) Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.
E3.1 An adequate and effective compliance process to monitor, identify, understand and ensure compliance with applicable laws and regulations and customer requirements pertaining to: A) Labor B) Health & Safety C) Environment and D) Ethics is established
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Not applicable Document review: A formal procedure to identify, track, assess, integrate, implement and maintain a current understanding of applicable legal and customer requirements. This includes at a minimum: review of new laws/regulations on at least a quarterly basis, maintains a document summarizing the applicable laws and regulations and the key customer requirements that impact the operations and updated at least on a quarterly basis, new/changed operations are reviewed for applicable regulatory and customer requirements prior to start-‐up. Management interview: Management can state the process to monitor, review, integrate and implement legal and customer requirements. The responsible is knowledgeable about the requirements Worker interview: Not applicable
Rating: Priority: Not Applicable Major: (default): 2 or more components are missing Minor: Any item of guidance missing Not Applicable: Not applicable Remote verification: Yes
E4) Risk Assessment and Risk Management
Process to identify the labor practice and ethics risks associated with Participant’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
E4.1 An adequate and effective risk management process to identify, assess, and minimize/mitigate/control its risks in the areas of: A) Labor B) Health & Safety C) Environment and D) Ethics is in place
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Control measures are in place for identified risks Document review: A formal risk assessment process is in place to identify the most significant risks. Any identified risk has an action plan to minimize such risk and procedural controls and/or improvement objective. The risk assessment covers every site operation/process and physical location, procedural controls are documented and managers and workers with responsibility for implementing the procedures have been appropriately trained, where controls are not yet in place, the facility has established an implementation plan with owners and due dates to implement the necessary controls, the effectiveness of controls is evaluated on a regular basis and corrective action take where improvement is needed. Training materials and training records are available, adequate and up to date. A risk assessment is carried out on an annual basis. Management interview: Management can state the risk assessment process, when the last risk assessment was carried out and what controls and corrective actions have been/are being taken. Worker interview: Not applicable Rating: Priority: Imminent and significant impact are confirmed on facility, life, limb or community without action Major: (default): 2 or more components are missing, no risk process adequate for the scope and nature of the operations and no controls in place
Minor: 1 component missing, risk process adequate for the scope and nature of the operations AND risk assessment performed but no adequate controls in place Not Applicable: Not applicable Remote verification: Yes
E5) Improvement Objectives
Written performance objectives, targets and implementation plans to improve the Participant’s social performance, including a periodic assessment of Participant’s performance in achieving those objectives.
E5.1 An adequate and effective performance management process for A) Labor, B) Health & Safety, C) Environment, and D) Ethics, including setting performance (improvement) objectives and targets, developing and implementing improvement plans, regularly reviewing progress toward achieving targets, and making appropriate adjustments if needed is in place
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Not applicable Document review: A formal objective setting process within indicators/ objectives/target including: consideration of risk assessment results, legal and regulatory requirements, customer requirements and company standards/requirements. The process should also include a specific frequency for objective setting (e.g. annual); assignment of owners; implementation plans; completion dates; and communication of objectives to workers (as appropriate). The process indicates how frequently progress in meeting objectives is reviewed. The objectives and targets are clearly designed to achieve continual improvement. Reporting on this question will include the detail of the current targets, last review meeting and current progress against the targets Management interview: Managements can clearly state the objectives/targets process, the current objectives/targets, and last review and current progress Worker interview: Workers can clearly state the objectives/targets relevant to them per component Rating: Priority: Not Applicable Major: (default): 2 or more components are missing, no targets established or no review takes place on progress Minor: 1 component missing, targets are established but no review takes place and/or no corrective actions taken if progress is off track Not Applicable: Not applicable Remote verification: Yes
E6) Training
Programs for training managers and workers to implement Participant’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.
E6.1 An adequate and effective training process is established for all employees/workers on all policy/procedures/job related aspects and performance targets related to A) Labor, B) Health & Safety, C) Environment, and D) Ethics
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Not applicable Document review: A formal training program for all employees is in place on policy/procedures/job related aspects and performance targets. Managers are retrained periodically (at least annually). Training materials and training records are available, complete, adequate and up to date; training includes a test of material learned. Test results are available for all training for the statistical sample of population. Training programs meet local legal requirements. A training calendar for each worker/employee group is available and communicated. Attendance records, including names and signatures of attendees (for class room training, on-‐line training will have electronic records). Management interview: Management can state it communicates/trains for all employees/workers on all policy/procedures/job related aspects and performance targets Worker interview: Workers can state accurately the content of the policy/procedures/job related aspects and performance targets relative to them Rating: Priority: Not Applicable Major: (default): 2 or more components are missing, no training takes place Minor: 1 component missing, no refresher or update training takes place Not Applicable: Not applicable Remote verification: Yes
E7) Communication
Process for communicating clear and accurate information about Participant’s policies, practices, expectations and performance to workers, suppliers and customers.
E7.1 An adequate and effective worker/employee, supplier and customer communication/reporting process about A) Labor, B) Health & Safety, C) Environment, and D) Ethics policies, practices and performance is established
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Not applicable Document review: A formal communication program to workers/employees, suppliers and customer is in place which includes: correspondence to supplier/customer management; contract terms and conditions requiring suppliers to conform to the EICC and comply with all applicable EHS regulatory requirements; presentations to suppliers; supplier training and information on the company extranet. Management interview: Management can state what, how and how frequent they communicate with workers, customers and suppliers Worker interview: Workers can state when the last communications was, what is communicated to them and that the communication is effective Rating: Priority: Not Applicable Major: (default): 2 or more components are missing, 2 or more focus areas are missing in the communications (policy, performance, practice, expectations) Minor: 1 component missing, 1 focus area are missing in the communications (policy, performance, practice, expectations) Not Applicable: Not applicable Remote verification: Yes
E8) Worker Feedback and Participation
Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.
E8.1 An adequate and effective worker grievance/complaint process whereby workers can confidentially communicate work-‐related grievances or complaints without fear of reprisal or intimidation is established
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Grievance and complaint channels are clearly communicate and visible (grievance box, hotline, hotmail, third party line, ....) Document review: An established process for workers to anonymously report grievances and complaints without fear of reprisal. Detailed procedures are in place to protect. Training material and training records are available, adequate and up to date. Annual refresher training is provided to all. Workers are provided with written information on how to report grievances and complaints Management interview: Management can clearly state which grievance and complaint mechanism are in place, how these are monitored and actioned with integrity and how the procedures are training including refresher training and what mechanisms management employs to seek worker feedback. Worker interview: Workers can state what grievance and complaint mechanisms is available to them and that they can use it without fear of reprisal Rating: Priority: Auditee actively retaliates (even to one substantiated case) Major: (default): 2 or more components are missing, Minor: 1 component missing Not Applicable: Not applicable Remote verification: No
E8.2 An adequate and effective worker consultation/participation process whereby management solicits and encourages worker feedback and participation for improvement via various channels is in place
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question For each component: Site observation: Feedback channels are clearly communicated and visible (suggestion box, hotline, hotmail, third party line, ....) Document review: A formal program to obtain worker feedback such as: worker surveys, suggestions boxes, worker focus groups, joint worker-‐management committees, worker/union representatives, complaint procedures and process improvement teams. The feedback is analyzed and actins are taken to improve the situation. Action plans are available, implemented or on track. Management interview: Management can clearly state what mechanisms management employs to seek worker feedback, when the last feedback was held and what the information is obtained and what
actions it took as a result of the feedback. Worker interview: Workers can clearly state how management seeks feedback and when he last feedback session was Rating: Priority: Not Applicable Major: No feedback mechanism(s) in place Minor: (default): any item of guidance missing Not Applicable: no worker communication. Remote verification: No
E9) Audits and Assessments
Periodic self-‐evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.
E9.1 An adequate and effective Audit process to periodically assess conformance with the EICC Code including compliance with applicable laws and regulations pertaining to: A) Labor B) Health & Safety C) Environment and D) Ethics.
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Not applicable Document review: A formal Audit program is in place which includes at least the following: regular self-‐Audits (at least annually) in order to assess conformance to: applicable regulatory requirements, the requirements of EICC, customer contractual requirements related to SER, own policies, standards and management system, other requirements to which the facility subscribes and the Audit program covers all areas of the facility, observation of processes, physical conditions and work practices; review of documents and records; interviews with individuals responsible for SER. Audit findings are reviewed by senior management. Management interview: Management can state which Audit program is in place, what the last Audit was and its findings Worker interview: Not applicable Rating: Priority: Not Applicable Major: (default): no Audits carried out, 2 or more components are missing, scope does not include regulatory compliance Minor: 1 component missing, scope includes regulatory compliance but not customer requirements
Not Applicable: Not applicable Remote verification: Yes
E10) Corrective Action Process
Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
E10.1 Has established an adequate and effective corrective actions process to rectify and close non-‐conformances with the EICC Code including legal non-‐compliances identified via internal or external Audits, assessments, inspections, investigations and reviews, covering A) Labor B) Health & Safety C) Environment and D) Ethics.
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System) For each component: Site observation: Not applicable Document review: A formal corrective action program and process is in place which contains the following: corrective action reports/plans and tracking tables, including specific corrective actions, owners and due dates are established to address all Audit issues. When a corrective action is off track additional actions to get the item back on schedule, root cause analysis of the finding to ensure the system gap is addressed, completion of action items is verified by the management representative, a demonstrated link between the CAP and the performance management objectives and targets. Management interview: Management can state the CAP program and which action are currently being implemented Worker interview: Not applicable Rating: Priority: Not Applicable Major: 2 or more components are missing, no tests at end of training and no feedback mechanism on effectiveness of procedures Minor: (default): Any item of guidance missing (focus on program/process in place, issues corrected or on track, correction is preventative to avoid future re-‐occurrence) Not Applicable: No Audit or evaluation performed Remote verification: Yes
E10.2 Violations have been corrected or are on track for correction, where monetary penalties were assessed, or where formal corrective actions were mandated by the issuing government agency for A) Labor B) Health & Safety C) Environment D) Ethics.
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics For each component: Site observation: Not applicable Document review: Copies of any regulatory citations/violation notices received in the past three years, including any communications with the agencies are available for review. If a citation was received, documentation to verify that the issues have been addressed/closed out is available for review and corrective and preventive actions to all similar situations throughout the facility. If closure was not verified by an independent third party or the original government agency Auditor must verify closure. General public record search by Auditors is performed to learn if the regulatory authorities have imposed corrective action or penalties in last 3 years for each component. Management interview: Management can state which government inspection they have received in last 3 years, if these resulted in a corrective action or monetary penalty and if so if these have been corrected or are on track to being corrected Worker interview: Not applicable Rating: Priority: Not Applicable Major:(default): 1 or more unaddressed regulatory actions or penalties. Minor: Regulatory actions or penalties are addressed but off track and not corrective actions are taken to get them back on track Not Applicable: has NOT been subject to any labor regulatory actions in the past 3 years. 3 data points are required to show there was no case in the past 3 years. Remote verification: No
E11) Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
E11.1 Adequate and effective documentation and records for A) Labor, B)Health & Safety, C)Environment, and D)Ethics management systems are maintained and appropriate levels of access to ensure privacy are implemented.
Minimum requirements: Components: Labor, Health& Safety, Environmental and Ethics If a component has a valid certification then this is considered conformance for that component on this question (i.e. if a valid third party ISO 14001 certificate is in place the Auditor will not verify the Environmental Management System)
For each component: Site observation: Documents are securely stored with authorized access only Document review: A documentation system which satisfies both regulatory (including record retention laws) and customer requirements and includes a documentation and recordkeeping procedure for at a minimum the following documents and records: records of wages paid and hours worked, verification of worker age, financial Audit reports, nondisclosure agreements, contract terms and conditions, self-‐Audit reports, regulatory compliance evaluations, risk assessments, work practices and procedures, performance in meeting objectives and targets, reports of inspections by regulatory agencies, incident investigations, worker complaints, training records, management System Review minutes and action items and corrective action records. A listing/table of documents and records required by local regulations and customer requirements is available, adequate and up to date Management interview: Management can state their documentation and record keeping procedures including how privacy is insured and how long records are maintained Worker interview: Not applicable Rating: Priority: Documents are fraudulent. Major: (default): 2 or more components are missing, does not meet regulatory requirements Minor: 1 component missing, meets regulatory requirement but not customer requirements Not Applicable: Not applicable Remote verification: No
E12) Supplier Responsibility
Process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.
E12.1 The EICC Code requirements have been communicated to the next tier suppliers
Minimum requirements: Site observation: Not Applicable Document review: Documented procedure on implementation of EICC code for suppliers AND formal communication with its suppliers on the code and its requirements or inserted the requirements of the code and its provisions into the contract it has with suppliers. This includes: * Supplier program (identification of major suppliers, definition of what is major) * Communications program to major suppliers (meetings, email, ...) * Enforcement language: contract, purchase order, ... Management interview: Management can describe the communication mechanism to supplier on the EICC code, the intent, philosophy and requirements and its provisions. Worker interview: If workers of suppliers are on-‐site: workers can explain the content of the code. Rating: Priority: Not Applicable Major: (default): There is no EICC supplier implementation procedure and there are no documented communication vehicles with suppliers
Minor: EICC supplier implementation procedures exist but 20 percent or more of suppliers have not been communicated to Not Applicable: no suppliers to facility. Remote verification: Yes
E12.2 An effective process to ensure that the next tier suppliers implement the Code is implemented
Minimum requirements: Site observation: Not Applicable Document review: EICC code implementation questionnaires, Audits or visit reports are available. Actions plans are in place with its suppliers on improvement actions related to the EICC code and its provisions. This includes the following: * If an SAQ is used then information needs to be validated through a verification visit with documented minutes of situation versus SAQ or/and an Audit to verify SAQ information * An Audit (CMA or VAP), an AMA (if done by third party qualified Audit firm is acceptable) * A corrective action plan following improvement areas identified in SAQ /Audit * A verification mechanism that CAP is implemented Management interview: Management can describe what evaluation method they use to enforce the requirements of the code AND how many Audits/evaluations were conducted/received in the last year. Worker interview: Not Applicable Rating: Priority: Not Applicable Major: (default): No Audits/evaluations or CAP are in place for the majority of suppliers Minor: Audits/evaluations are done within last 2 years for less than 80 percent of supplier AND with CAPs in place Not Applicable: no suppliers to facility. Remote verification: Yes
13. Audit Preparation for Auditees
The Electronic Industry Code of Conduct (EICC) was introduced for ICT industry suppliers in 2004. These expectations are driven by the Corporate Responsibility (CR) objectives of coalition member companies and include specific requirements in areas associated with human rights and labor practices, occupational health and safety, the environment, and business ethics.
The program has evolved in response to increasing customer, investor, employee and public expectations that EICC member companies verify that their suppliers' operations are conducted in a socially and environmentally responsible manner consistent with EICC requirements. The EICC Validated Audit Program (VAP) is part of that verification process.
13.1 The EICC Validated Audit Program (VAP)
The goal of the Audit program is to work in partnership with suppliers to foster CR performance improvement and build CR capability within the supply base.
The Audit provides EICC member companies with an evaluation of a supplier's labor, ethics, occupational health and safety, and environmental practices relative to the requirements set out in the EICC Audit criteria and identifies supplier CR practices that may require improvement in order to meet those requirements
13.2 EICC Validated Audit Program Criteria
The EICC Audit criteria are based on the Electronic Industry Code of Conduct and local legal requirements, and set the basic CR performance expectations for suppliers.
The Audit criteria cover five main areas: • Labor • Health & Safety • Environment • Ethics • Management Systems for Labor, Ethics, Health & Safety and Environment
13.3 Audit Overview
The Audit is performed at the facility by specially trained, independent and qualified third-‐party Auditors, and includes the following elements:
• Preparation for the Audit (at Audit firm offices with minimal interaction with the Auditee) • Perimeter survey (off site – no interaction with the Auditee) • Opening meeting
Self-Assessment Corrective and
Preventive Action Audit
Continuous Improvement
• Facility evaluation Ø Facility tour and inspection Ø Documentation reviews Ø Gathering information from management and worker
• Daily wrap-‐up meetings • Closing meeting • Validated Audit Report (VAR) • Corrective action (not part of the Validated Audit but part of the Continuous Improvement
process – details can be found in the Corrective Action Preparation for Auditees) • Follow-‐up verification (not part of the Validated Audit but part of the Continuous Improvement
process – details can be found in the Corrective Action Preparation for Auditees)
13.3.1 What to expect in an Validated Audit (VA)
The Validated Audit (VA) will be approximately a two or three day event. However, the number of Audit days and Audit team members will depend on the size of the facility, the complexity of the operations and the number of workers as well as whether the Audit is an initial Audit or a follow-‐up verification Audit. The specific Validated Audit duration and number of Auditors will be determined jointly between the VAP Program manager and qualified Audit firm at the time the Audit is scheduled. This is done using leading practice algorithm to ensure consistency of the VA between Auditees
The purpose of the on-‐site evaluation (the Validated Audit) is to gather objective evidence to confirm that supplier CR programs and practices are fully defined, implemented and effective.
The VA includes observations from area inspections, reviews of programs, procedures, and policies, and gathering information from management and worker.
• Facility walkthroughs and gathering information from workers and management are intended to provide insight into CR policies, practices, and implementation of procedures, awareness of roles and responsibilities, and management involvement.
• Documentation and records review provides information on how well CR management systems are defined, implemented and sustained, and their effectiveness.
An observer may accompany the Audit team from an EICC or member company (and/or the VAP Program Manager). The purpose of the observer is to evaluate the performance of the Auditors and the effectiveness of the Audit process. The observer will not actively participate in the Audit and is excludes from attending gathering information from workers. The observer’s (with the exception of the VAP Program Manager who will accompany the Auditors everywhere) site access should be limited to common areas, such as dormitories, canteens, facilities areas, and manufacturing areas that produce products for only their company.
13.3.2 Preparation for the Audit The preparation phase is a critical phase in the overall Validated Audit. During the preparation the phase the assigned Audit team will:
• Review all Validated Audit process documents (EICC Code, Audit Protocol, Audit Manual)
• Review self-‐assessment and Auditee-‐provided documents (including the Self Assessment Questionnaire SAQ and the facility profile)
• Review information on Auditee’s website (if available)
• Ensure the relevant reference standards such as applicable laws are reviewed and available
• Contact the Auditee on Audit logistics and timing (arrival time on site, agenda during the Audit, scheduled end of day and departure from site after the close meeting)
All of this preparation will take place at the Audit firm offices
The VAP Program Manager will provide you with the necessary documentation and guidance on the Validated Audit.
In addition the VAP Program Manager will provide the Auditee with the Validated Audit dates in advance and will also contact the Auditee two day before the Validated Audit to ensure the process is clear and the documents to be reviewed (see list in this document – chapter 6) are ready and available when the Auditors arrive on site.
The VAP Program Manager is available via email and phone for additional guidance and to answer questions if required.
13.3.3 Perimeter survey Before arriving on site the Auditor(s) may perform a perimeter survey, which consists of getting to know the Auditee in the context of the local community.
Overall objective should be to identify a variety of data points that help provide local context to the production site’s operation and to prepare questions for further investigation once on site.
This consists of looking at infrastructure such as transportation, emergency services such as fire department, .... and also getting community information on the Auditee.
The perimeter survey usually lasts between 30 and 60 minutes and can usefully feed and supplement the onsite Audit information to provide context and triangulation of information.
During the perimeter survey there will be no interaction with the Auditee
13.3.4 Opening Meeting
When arriving on site the Auditor(s) will present identification of who they are and will start the on site Audit process. The Auditor(s) will bring with them all Audit tools and equipment necessary for the Audit. The Auditee will ensure all documents detailed by the Auditor as described in chapter 6 are available.
Auditor(s) will arrange their own transportation, accommodation and food for the Audit.
All EICC CR Validated Audits begin with an opening meeting. The purpose of the meeting is for the Audit team to meet with the Auditee management and other personnel involved in the Audit. The opening meeting will be conducted through a formal EICC-‐ presentation and standard
The Lead Auditor will provide a brief review of the Audit agenda, Audit process and scope, and answer any questions the Auditee may have. The Auditee should include a brief summary of business and operational issues and other information that helps the Audit team understand
• The business climate for the organization; • Major changes since the last Audit (if applicable); • CR program organization; • Assignment of responsibilities; • CR goals and performance; • Other information of potential interest to the Auditors and attendees.
13.3.5 Audit scope The Audit team will need to visit:
• Production areas • Facilities areas (equipment rooms, wastewater treatment, ....) • Office areas • Material, chemical and waste storage areas • Distribution Centers / shipping and receiving • Canteens and kitchens
• Dormitories
13.3.6 Gathering information from Auditee management and workers Gathering information from management and worker are a critical component of the facility evaluation. Listening to and understanding workers and staff provide another perspective on work practices and conditions. Throughout the validated Audit, the Auditors will interact with workers to gather information both formally and informally. When formally interacting with workers the Auditors will select worker from various areas of the facility, from different work shifts, and with varying responsibilities. The number of workers selected for a formal gathering of information session will depend on facility size. Interviews can last from 20 minutes or more, depending on whether they are individual or group interviews, or the nature of the subject discussed. The number of workers/staff the Auditors will interact with is based on global leading practice and is implemented through a standard algorithm.
Worker interviews are private meetings between the Auditor and worker or group of workers. Supplier management may not be present during interviews in order to ensure worker privacy and confidentiality. Gathering information from managers, other staff members and workers provide the Audit team with an understanding of how CR programs were developed and implemented. Typical the Audit team will interact with:
• Site manager(s) • Production manager(s) • Maintenance staff • Environment manager(s) • Health & Safety manager(s) • Quality manager(s) • Human Resources manager(s) • Onsite services staff such as canteen, dormitory supervisors, security staff • Finance manager / payroll manager • Procurement manager / supply chain manager • Onsite medical staff (as appropriate) • Other personnel (as appropriate)
13.3.7 Facility Walk through The purpose of the facility walkthrough is for the Audit team to observe physical conditions and current practices in all areas of the facility. This observation helps determine whether activities are conducted in a manner consistent with the policy, stated practices and applicable legal requirements.
The Auditor should be free to review all physical areas of the facility and should set the pace and direction of the tour rather than being guided by management.
During the tour, it is advised that the Auditor review most specifically: • Work environment (space, temperature…), • Work position (ergonomics…), • Fire equipment and emergency equipment, • Machine protection and maintenance, • Emergency procedures, • Personal protective equipment, • First aid equipment • Hazardous substances storage and handling, • Waste management • Toilets and sanitation, • Canteen hygiene and safety when applicable, • Dormitory hygiene and safety when applicable • Unreasonable restriction on workers’ freedom of movement or rights,
• Quality, production and time records • Posting of relevant codes and any worker information relating to their rights
• Workers’ notice boards and information relating to Union or workers committee meetings
• Any records displayed during the tour that might show a discrepancy between operational activities and the protection of human rights
In some cases however, for safety, security or commercial confidentiality reasons, the site management may have policies that prevent visitors from walking unaccompanied through the production site. In such cases, Auditors should follow the Auditee policies, unless the management is willing to offer an exception.
It is the responsibility of the Auditee to inform the Auditors of the safety rules and requirements (such personal protective equipment – PPE in specific facility areas) and provide the Auditors with the necessary PPE, if required.
Auditors should obtain permission to take photos in the facility. If the management does not give such permission, Auditors will mention it in the report together with any reasons given. Photos should not contain product, product information or other proprietary info
The Auditors should never disrupt the production flow as part of the facility walk through.
13.3.8 Document Reviews: As part of the validated Audit, the Auditors will review relevant records. For example, payroll records will be reviewed to evaluate working hours, wages and benefits. The number of records reviewed for a certain type of document, such as payroll records, will be based on the number of workers/staff the Auditors will interact with to gather information
In addition to personnel records, the Audit team will also review EHS management system documentation, such as procedures, permits, objectives and targets, prior Audit reports, ....
As a minimum, three months’ worth of records should be reviewed for each sample. Time periods of divergent working conditions should be included (e.g.: the low season of operation, the peak season of operation, periods of special holidays or leave time, as well as the most current work period). In all cases, 12 consecutive months of documentation should be available on site, including payroll, time records, safety trainings, machinery maintenance, fire equipment and hazardous materials.
The list of documents which Auditors will review and which should be available at the start of the on site Audit process is given in chapter 13.3.12.
As part of the documentation review, the Auditors may need to record some of the information in order to complete their evaluation. The Auditors will not include any confidential information, such as personal identifiers; will be included in the Audit report. In addition, the EICC VAP program manager will screen all Validated Audit Reports (VAR) to ensure that any potentially confidential information is removed prior to releasing the reports to the Audit Buyers.
13.3.9 Daily Wrap-‐up Meeting The Audit team will meet at the end of each Audit day with the Auditee management to discuss the day’s findings, provide the opportunity for the Auditee to present additional evidence and discuss issues where additional information may be needed to complete the evaluation.
The Audit team will also recap and agree the agenda for the remainder of onsite Audit portion with the Auditee management and clarify any further needs to ensure the Audit is performed as effective and efficiently as possible.
13.3.10 Closing Meeting The Closing Meeting is held at the end of the last day of the Audit. The same group of Auditee personnel that participated in the Opening Meeting and others who would benefit from hearing from the Audit team should attend the Closing Meeting.
The Audit team will present an overview of the team’s findings and ensure the Auditee fully understands them. The Auditee will also be given the opportunity to ask questions and provide additional evidence or clarification. The goal is to reach agreement on the major findings.
The Auditors will review the findings of the validated Audit from all activities conducted, including document review, observation, and gathering information from management, staff and workers.
Audit team will review the evidence gathered during the Audit and evaluate the compliance status of the facility in each area of the Audit. If additional information or evidence is required, it must be requested at this stage. The process of compiling and crosschecking evidence gathered and the subsequent decision-‐making is a pre-‐requisite to the preparation of the closing meeting – this referred to as triangulation of data.
The aim of having a classification of Nonconformance is to define the severity of the issue and ensure a more accurate representation of findings by differentiating between isolated, non-‐systemic findings and those, which are recurrent or systemic. This gives more opportunity to the Auditee to explain its difficulties and deeper analysis to principal.
Each Nonconformance will be classified by the Audit team as: ü Priority Nonconformance ü Major Nonconformance ü Risk of Nonconformance ü Minor Nonconformance
The following definition apply:
ü Priority Nonconformance: is a Major non-‐conformance with significant and immediate impact. These are predefined such as the presence of child labor in a facility. If a Priority Nonconformance is found, the Auditor must report this immediately to facility management and to the APM. Other Priority Nonconformance include: forced labor, health and safety issues that can cause immediate danger to life or serious injury, and environmental issues that can result in serious and immediate harm to the community. All of these have been marked in the working tabs with a light red color in the question field
ü Major Nonconformance: is seen a significant failure in the management system – one that affects the ability of the system to produce the desired results. It may also be caused by
failure to implement an established process or procedure or if the process or procedure is totally ineffective. For example, the failure of an organization to verify its compliance to applicable laws and regulations is a Major Nonconformance.
ü Minor Nonconformance: A minor Nonconformance by itself doesn’t indicate a systemic problem with the management system. It is typically an isolated or random incident. Examples are: an internal Audit with an overdue corrective action request pending, or a procedure that has not been revised to reflect a change in regulations.
ü Risk of Nonconformance: An observation is used in several situations: ▬ When there is insufficient evidence to conclusively determine conformance or
Nonconformance. An example of this would be when worker interview information contradicts program documentation and records, but you cannot determine if the records have been falsified or the workers have been coached to answer in a certain way.
▬ When evaluating working hours, an insufficient number of workers in a sample are found to exceed the EICC 60-‐hour working hours limit or the applicable legal limit.
▬ If the condition or practice is in conformance with the requirement, but in your judgment, it could deteriorate to a Nonconformance without some additional action or effort on the part of facility management.
ü N/A: The question is not applicable to the entire facility Audited and to each specific part of the facility. N/A responses should be minimized and replaced by as many observations as possible.
The closing meeting will be conducted through a formal EICC-‐ presentation and standard.
If an area could be triangulated and verified prior to the close meeting then this will be specifically stated in the close meeting as exception management. Further analysis on this topic will be done prior to release of the draft report and the Audit firm will informed the Auditee of the conclusion (via mail AND phone call). Exception management of VA questions should be minimized and should not occur in most Audits.
13.3.11 The Validated Audit Report (VAR) A formal final Validated Audit Report (VAR) will be available to the Auditee and Audit buyers 30 calendar days after the Audit.
The VAR provides information for the Auditee's management team to improve their CR programs and performance. VA findings identify both deficiencies and good practices, and are based on objective evidence obtained during the VA, relative to:
• Intent (whether all Audit criteria have been addressed),
• Implementation (how well the practice meets the defined criteria) or
• Effectiveness (whether the policies and practices deliver the intended results).
The APM will perform a comprehensive review of the draft VAR for accuracy, completeness and other EICC report quality criteria.
The following timeline applies the process from the close meeting until the release of the VAR:
ü Auditee QA feedback on Priority/Major Nonconformance Report received (+7 days from close meeting)
ü Draft VAR to VAP Program Manager (+14 days from close meeting)
ü QA feedback to Audit firm (+19 days from close meeting)
ü Final draft VAR received (+23 days from close meeting)
ü Final VAR review (+25 days from close meeting)
ü Final VAR in PDF released (+28 days from close meeting)
If the Auditee disagree with one or more of the conclusions after the QA review then the Auditee has the opportunity to include a comment stating the specific disagreement in the VAR before it gets released
13.3.11.1 Priority Nonconformance A Priority issue is a Major Nonconformance with significant and immediate impact. These are predefined such as the presence of child labor in a facility. If a Priority Nonconformance is found, the Auditor must report this immediately to facility management and to the APM. Other Priority Nonconformances include: forced labor, health and safety issues that can cause immediate danger to life or serious injury, and environmental issues that can result in serious and immediate harm to the community. All of these have been marked in the working tabs with a light red color in the question field
When the Audit team identifies and confirms a Priority Nonconformance the Audit process will include an immediate meeting with the Auditee management to inform and discuss the Priority Issue finding.
The following timeline will apply upon discovery of a Priority Nonconformance: ü 0 Hours – Nonconformance identified and communicated to Auditee management
during onsite VA, Auditee immediately removes the threat (issue which has caused the Priority issue – e.g. remove the child of the work floor in case of child labor)
ü 12 Hours -‐ Lead Auditor and APM reports issue to Authorized Recipient Management
ü 24 Hours -‐ Authorized Recipient(s) contact(s) Auditee ü 48 Hours -‐ Containment in place, Auditee puts in place temporary measures to
ensure Priority Issue does not re-‐occur
Post Validated Audit ü 7 Days -‐ Corrective Action Plan (CAP) submitted to VAP Program Manager,
Auditee begins implementation of CAP ü 17 Days -‐ Authorized Recipient(s) approve(s) Corrective Action Plan overall CAP
and Auditee adjusts implementation of CAP if necessary ü 30 Days -‐ Recommended Outside Deadline for closure of Priority
Nonconformances, this includes a follow up Audit on the Priority Nonconformance.
13.3.12 How to Prepare for a Validated Audit as Auditee
Validated Audits are a joint effort between the Auditee and the Audit team, and adequate preparation by both is essential to gaining maximum value. Therefore, the process works best when all parties are well prepared and work together with the same goals in mind.
The Auditee's management representative is responsible for the Auditee's Audit preparation. He or she is the key contact and partner with the Lead Auditor and is also the person who will approve and release the Validated Audit Report (VAR).
The Auditee's specific preparation activities include:
ü Confirm the Audit dates and Audit duration with the Audit Firm.
ü Establish, together with the Lead Auditor, the detailed on-‐site Audit agenda.
ü Provide information on travel logistics: preferred hotels and airports, travel restrictions and any special considerations.
ü Participate in pre-‐Audit documentation review
▬ Review information about the EICC
▬ Complete the EICC Self-‐Assessment Questionnaire (SAQ)
ü Locate all of the requested manuals, records and documentation. Make certain they are available and up to date on the day of the Audit (see list of documents in chapter 6).
ü Ensure that relevant information is available for the Auditors when they arrive:
▬ Names, phone numbers and locations of the Audited facility's key people
▬ Maps of the site and surrounding area
ü Ensure that Auditors have access to the facilities (i.e., dormitories, canteens, manufacturing, assembly and chemical storage)
ü Ensure staff members are available that have a thorough knowledge of the facility’s EHS, Labor, and Ethics policies, procedures, work instructions and records.
▬ Make appointments with individuals that the Lead Auditor has requested for gathering information from workers/staff sessions
ü Appoint responsible members of the staff to interface with and accompany the Auditors.
ü Invite appropriate staff members to the opening and closing meetings and daily wrap-‐ups.
ü Brief management and staff on the Audit process so they can effectively participate.
ü Provide the Auditors with meeting room(s), preferably with access to a telephone/internet line, and copy machine.
ü Arrange for management hosts, as required by the schedule.
13.3.13 Documents and Records for submission and review
The following tables list the records and documents that the Audit Team needs to perform a thorough CR Audit. Be aware that these are minimum lists and do not cover all the documents that may be required. The Audit team may request other related documents and records for review either before or during the on site Audit.
• The items in the first table should be sent to the Audit firm at the time the Audit is scheduled.
• The second lists the documents and records that should be made available for the Auditors when they arrive on site.
Documents and records to be made available to Auditors on site (at the start of the Audit)
Audit Section Provision General / G1 General facility information
¨ Facility lay out and drawings ¨ Description of process and buildings within facility ¨ Changes at facility in last 12 months
¨ Overview of production/services of last 12 months, volume, new equipment, new licenses
¨ Communication to workers of EICC provisions
¨ Communication with suppliers regarding EICC conformance
¨ Contract requirements with suppliers regarding EICC conformance
¨ Proof of verification suppliers’ implementation of EICC code requirements
Audit Section Labor Provisions
A1 Freely Chosen Employment
¨ Contracts with labor agencies, labor brokers, labor service providers, .... ¨ Example of a worker (labor) contract
¨ Process and procedures for evaluating worker exposure to the hazards of manual handling, repetitive tasks, awkward postures, etc.
B7 Dormitory and Canteen
¨ Canteen operation license and food handler health check records ¨ Records of evacuation drills held in dormitory
Audit Section Environment Provisions
C1 Environmental Permits and Reporting
¨ Copies of permits for the facility’s operations and records of inspections or citations
¨ Official exemptions from permit requirements, issued by government agencies
¨ Records of monitoring, inspections and maintenance required by environmental permits
¨ Environmental release registers (volume of water, air, waste) for last 2 years
¨ Pollution prevention and reduction plans and results ¨ GHG initiatives and results ¨ Water conservation initiatives
C2 Pollution Prevention and Source Reduction
¨ Programs and procedures for recycling, reuse and resource conservation
¨ Monitoring results for amounts of wastes reused and recycled
¨ Monitoring reports for water and electricity
C3 Hazardous Substances
¨ Inventories of chemicals and other hazardous materials
¨ Spill control plan and procedures ¨ MSDS’s for all hazardous materials on site
¨ Hazardous substance licenses/registrations ¨ Tank integrity inspection and test reports
C4 Wastewater and Solid Waste
¨ List of solid wastes (hazardous and non-‐hazardous) generated on site ¨ Consignment notes / disposal records (manifests, receipts, invoices)
¨ Waste vendor licenses,
¨ Waste vendor audit reports
¨ Waste permits or registrations and monitoring / inspection reports
¨ Waste water treatment plant maintenance records and as-‐built drawings
¨ Water quality analyses from water supply or groundwater monitoring wells
C5 Air Emissions
¨ Air monitoring reports
¨ Air emission permit and reports submitted to regulatory agencies
¨ Air pollution abatement equipment maintenance records
C6 Product Content Restrictions
¨ Procurement and manufacturing specifications describing how the facility meets legal and customer product content restrictions
¨ Records of communication of RoHS and other customer product content restrictions to suppliers
¨ Analytical test results Audit Section Ethics Provisions
D1 Business integrity
¨ Business conduct guidelines / Code of Ethics ¨ Distribution or training process on Code of Ethics to employees
¨ Policy on company donations and sponsorships
¨ Policy on ethics, anti corruption and bribery ¨ Procedure for ethics breach investigation ¨ Business registration
D2 Improper Advantage
¨ Policy that ensures gifts to or from suppliers and customers is not excessive in cost and frequency and hospitality, expenses or promises
¨ Training material for management, supervisors and workers and training records
¨ Effective procedures for addressing its workers or agents suspected of making or accepting improper offers of payments or gifts and attempted bribery in all forms
¨ Investigation procedures and subsequent sanctions are applied are in place
¨ Disciplinary procedures/policy ¨ Disciplinary records
D3 Disclosure of Information
¨ Non-‐disclosure agreement template/form
¨ Non-‐disclosure agreements with suppliers and customers
¨ Non-‐disclosure agreements with service providers
D4 Intellectual Property
¨ Intellectual property review and protection policies D6 Protection of Identity
¨ Information provided to workers and external stakeholders on how to confidentially report business ethics issues of concern
¨ Policy/procedure on “whistle blowing” ¨ Procedure for confidential investigation and resulting actions on a
“whistle blow”
¨ Statistics on “whistle blowing for last 12 months)
D7 Community Engagement
¨ Charitable programs
¨ Volunteer programs
Audit Section
Management System Provisions (Note: a copy of the facility’s management system Description/Manual could address a number of the following information requests)
D0 Management System Certification
¨ Management system certification (e.g. SA8000, ISO 14001, OHSAS 18001, ….)
D1 Company/facility’s Policy or commitment statement
¨ Labor, Employment, Ethics, Health & Safety and Environment Policy
¨ Corporate Social Responsibility Policy ¨ Company/facility’s Business Ethics or Code of Business Conduct policy
or manual
D2 Management Accountability for labor and ethics
¨ Organizational chart ¨ Roles and responsibilities for the management system representative,
managers with human resources, ethics, labor, health & safety and environment responsibility
¨ Records of management system reviews
D3 Tracking and monitoring of applicable Social and Environmental Responsibility (SER) laws and regulations and customer requirements
¨ Copy of customer requirements (e.g., EICC)
¨ Tracking system for monitoring of Social and Environmental Responsibility (SER) laws, regulations, and implementation or distribution logs.
¨ Copy of applicable laws D4 SER Risk Assessment and Risk Management
¨ Procedure to identify, evaluate and rank SER risks ¨ Listing of identified SER risks for the facility and risk assessment
review records
¨ Action plans addressing highest identified SER risks ¨ Business continuity plans
D5 SER performance objectives and implementation plans and Measures
¨ Current year performance objectives and targets, including results of periodic reviews of the implementation and status of meeting the objectives
¨ Current improvement initiatives and progress status
D6 SER training programs
¨ Description of SER trainings provided ¨ Records of SER trainings, ....
D7 SER communication programs
¨ Factory SER rules (for example, Employee Handbook)
¨ Process for communicating company SER performance and expectations to workers, suppliers and customers
¨ Bulletin boards, newsletters, intranet sites for communication with
workers and managers
D8 Worker Feedback and Participation
¨ Worker survey/complaint forms
¨ Description of formal ways for workers to participate in program development and implementation (for example, committees, task forces, ....)
¨ Worker surveys, complaints, and feedback provided by management
D9 SER Audits and assessments
¨ Audit process and procedure ¨ Copies of SER Audits carried out in last 24 months
D10 SER Corrective Action Process
¨ Corrective Action management procedure
¨ Copies of corrective action plans of SER Audits carried out in last 24 months and current status against these corrective action plans
¨ Records of Nonconformance tracking, closure, status and management reviews
¨ Legal compliance records of citations, penalties for violations of labor / ethics laws and regulations
¨ Legal compliance records of EHS citations or penalties received in the past 3 years
D11 SER Documentation and Records
¨ Records retention policy and procedures
14. Management System Introduction
14.1 Purpose
The purpose of this section is to enable individuals within the electronics industry supply chain who have Corporate Responsibility (CR) functions to better understand the structure and content of management system (MS) requirements within the Electronic Industry Citizenship Coalition (EICC) Code of Conduct (Section E) and other CR-‐related supplier codes of conduct, and assist them in: • Implementing the MS requirements of applicable supplier codes of conduct; • Auditing their operations to applicable MS aspects of supplier codes of conduct; and • Periodically reviewing the status of their Labor, Ethics and EHS MS(s).
14.2 Introduction to the Management System
A CR Management System consists of the organizational structure, procedures and practices the company uses to achieve the goals of its Labor, Ethics, Environment, and Health & Safety Policies. It should be a fully integrated part of the company’s overall system for business management.
The concept underlying a CR MS is the same as any other defined business management system: well-‐defined management processes linked together enable an organization to implement its policies and reach its performance goals. While the components of such systems are sometimes presented in different ways, probably the best and most well-‐known model is “Plan-‐Do-‐Check-‐Act” or PDCA.
The PDCA cycle of continual improvement is the foundation for ISO 9001 (quality management systems), ISO 14001 (environmental management systems), OHSAS 18001 (health and safety management systems) and other internationally recognized management system standards. MS requirements within most supplier codes of conduct, including the EICC, parallel these standards, and like them, promote continual improvement -‐-‐ based on the premise that the organization will periodically review and update
the management system, identifying opportunities for improvement. Improvements in the Management System help facilitate a higher level of CR performance.
The MS is intended to be integrated with other requirements, processes and systems used to manage the business. That is, nothing in the CR MS should be “stand-‐alone” or implemented separately from the existing business processes. While we often refer to the CR MS as an entity in and of itself, in fact it is more like a filter or lens by which to focus in an organized way on the management activities that are related to CR aspects, hazards or risks.
In addition to its use as a means of implementing CR policies, another important application of a CR MS is its use as a framework for Auditing. Simply reviewing implementation of specific CR programs, plans or requirements may not be sufficient to provide an organization with assurance that performance not only meets, but will continue to meet legal, company and customer requirements. To be effective, Audits need to be conducted within the management system framework, enabling the Auditor and the organization to identify the systemic or ‘root’ cause of program or performance deficiencies so that corrective or preventive action is truly effective.
14.3 Understanding the EICC Management System Requirements
The EICC’s Management System requirements are defined in Section D of the code. It describes the core elements and requirements of a Corporate Responsibility management system and their interaction.
As in most supplier codes of conduct, the purpose of Section D of the EICC is to establish requirements for supplier operations to:
• Implement and maintain their Labor, Ethics, Environment, and Health & Safety (CR) Policies, • Identify and address the CR aspects and hazards of their operations, • Manage compliance with regulatory and customer CR requirements, and • Achieve continual improvement.
Most MS requirements are organized in a PDCA format, with the following five main elements: policies, planning, implementation and operation, checking and corrective action, and management review.
14.3.1 Policies The supplier’s CR policies, signed by a senior executive, serve as the foundation for management commitment.
14.3.2 Planning Planning consists of identifying and assessing CR aspects and hazards; identifying applicable legal and other requirements; and establishing priorities, improvement objectives and plans to manage the identified aspects and hazards.
14.3.3 Implementation and Operation Implementation and operation covers management responsibilities for establishing organizational structures and providing the resources necessary to establish and execute the MS; providing CR information and training to managers and employees as needed to understand company policies and fulfill their CR responsibilities; assisting the public, customers and other stakeholders in understanding and supporting the company’s CR commitment; documenting programs and procedures to enable consistency and to help ensure compliance with legal
requirements and company standards; and identifying and controlling the activities associated with the operation’s CR aspects and hazards.
14.3.4 Checking and Corrective Action Checking and corrective action consists of monitoring and inspecting the operation’s activities; reviewing the implementation of programs and plans to achieve CR objectives; ensuring conformance to the EICC and/or other supplier codes, customer and legal requirements; identifying non-‐conformances in the system (practices or conditions that don’t conform to the defined requirements) and implementing corrective & preventive actions; and periodically Auditing the status of the CR Management System.
14.3.5 Management Review The operation’s top-‐level management regularly reviews the CR management system to ensure its continuing suitability, adequacy and effectiveness. Results of the review are used to make improvements to the management system.
While the CR MS is presented here as a cycle, there are actually more interconnections among the elements of the system. For example, continual improvement is not limited to the Management Review element -‐-‐ it is also evident in the organization’s response to its monitoring, verification and Auditing activities, and in planning and managing change.
Figure 3: The EICC Management System Requirements
EICC MS requirements for supplier operations are described in Section E of the Electronic Industry Citizenship Coalition (EICC) Code of Conduct, as follows:
E.1 Company Commitment (Policies)
E.2 Management Accountability and Responsibility
E.3 Legal and Customer Requirements
E4 Risk Assessment and Risk Management
E.5 Performance Objectives with Plans and Measures
E.6 Training
E.7 Communication
E.8 Worker Feedback and Participation
E.9 Audits and Assessments
E.10 Corrective Action Process
E.11 Documentation and Records
E.12 Supplier Responsibility
14.4 Making the System Work
14.4.1 Following the Aspects & Hazards through the System Effective implementation of the CR MS begins with a thorough identification of the operation’s labor, ethics, environment, and health & safety aspects and hazards. This forms the basis for carrying out the rest of the elements of the management system.
• Labor aspects are the economic and social effects of the operation’s human resources management practices on workers.
• Ethics aspects are the interactions of the operation’s business practices with business partners (suppliers and customers), business competitors, and the community.
• Environmental aspects are the interactions of the operation’s activities, products and services with the environment.
• Health and safety hazards are the interactions of the operation’s activities, products and services with employees in their work activities and other people in supplier workplaces.
Once the aspects and hazards are known, processes for evaluating their significance/Priority and identifying applicable legal and other requirements are then implemented. For supplier operations, “other requirements” may include voluntary (non-‐legal) supplier codes of conduct like the Electronic Industry Citizenship Coalition Code of Conduct and/or specific customer requirements (e.g. product content). Other requirements may also include commitments the supplier has made internally or to other stakeholders, for example, national voluntary resource conservation programs or local employee commute programs.
The supplier then decides upon improvement goals based on the established priorities, business
and other relevant considerations, and the existence of applicable company-‐wide goals. The following management processes apply for those aspects, hazards or elements of the management system identified as needing improvement:
• Establishment of objectives and associated targets
• Establishment of implementation plans
• Monitoring of progress towards the objectives
For all aspects and hazards subject to legal or other requirements or otherwise determined to be significant, the following management processes are implemented to control their impacts/risks: • Assignment of responsibilities • Competency and training • Operational controls (procedures, practices, engineering, structures, equipment) • Emergency preparedness and response • Monitoring of performance or activity • Periodic evaluations to verify compliance to legal and other requirements
• Identifying management system non-‐conformances and instituting corrective/preventive action
There are a number of management processes supporting the whole system, regardless of the specific aspects or hazards being managed. These include: • Communicating relevant information, both internally and externally • Documentation, document control and recordkeeping
• Managing suppliers/contractors who have potential CR impacts on the operation
And overall, the whole system is evaluated and reviewed through the following processes: • Management system Auditing
• Management review
15. Small and Medium Sized Enterprises 15.1. Introduction:
The level of expectation on documentation, procedures and records is different in a small and medium sized enterprise than it is in a larger organization.
The definition of small and medium sized enterprise within EICC VAP is 500 people (direct and indirect employed labor) or lower for the entire enterprise (including all facilities in case there are several facilities).
15.2. Small and medium sized enterprise cultures:
A primary difference between large and small companies is management's role and involvement. Typically, top management of a small firm:
• Has greater interest and control of the firm through an ownership position. • Is more involved with daily operations in all areas. • Knows all employees and their strengths and weaknesses. • Understands, and can often perform, all activities or processes. • Knows the customer's representatives and understands customer needs and quirks.
• Is knowledgeable about the relative strengths and weaknesses of the firm's products/services as well as its competitors.
• Is reflected as the firm's alter ego.
Resources, especially personnel, generally are not as available in smaller organizations. Also, overlapping responsibilities or assignments are uncommon because each person has defined activity areas or turf.
Smaller firms maintain a more limited scope in terms of products or services, processes, customer base, geographic market and technology. Exceptions to this tendency include large scope/small organizations such as trading companies and independent manufacturers' representatives.
Small firm culture is more informal, although not necessarily more relaxed. This translates into fewer written directions and records. People unfamiliar with small company culture often mistake informality for indifference. Nothing could be more erroneous. A small company owner casually requesting a subordinate to perform an activity may convey unmentioned dire effects for nonperformance exceeding those of a registered demand.
15.3. Management systems in small and medium sized enterprises
Properly applied, management systems’ descriptive approach is ideally suited for small organizations' unique aspects. However, proper implementation can only occur when a company considers not only the standard's concepts, guidance and specific requirements but how all persons and activities within the organization interact. Aligning management systems concepts to small companies' cultures begins by embracing the definition of “quality”: "totality of characteristics of an entity that bear on its ability to satisfy stated or implied needs." In other words, quality includes everybody and everything that affects satisfactory performance or outcomes. Small organizations' operations aptly meet this description because a miscue anywhere quickly and directly affects most or all employees.
A “documented procedure” means the procedure has to be established, documented, implemented and maintained. Documentation may differ from one organization to another due to:
• Size of organization and type of activities; • Complexity of processes and their interactions, and • Competence of personnel.
Small organizations' top management must deal continually with contracts, customers, operations, EICC requirements. If this is the case then:
• Documentation can be established through simple flowcharts, checklists, graphics, … • A management system documentation shall include: o Documented statements of a policy and objectives; o Documented procedures for the following five activities:
§ Control of records § Internal and external Audits § Control of Nonconformances § Corrective action § Preventive action
o Documents needed by the organization to ensure the effective planning, operation and control of its processes, and
o Records required to demonstrate conformance through objective evidence: data supporting the existence or variety of something and may be obtained through observation, measurement, test, or other mean.
For non documented procedures the Auditor has to verify through interview and existing documentation that the procedure is consistently and repeatably implemented and understood by those involved in implementation in the same manner.
16. Working Hours Guidance 16.1 EICC Code Provision:
Working Hours: Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off per seven-‐day week.
16.2 Definitions
16.2.1 Emergency or unusual situations: are unpredictable events that require overtime in excess of legal or EICC limits. Such events cannot be planned for or foreseen. Examples of such situations include: • Equipment breakdown, power failure or other emergency resulting in prolonged
shutdown of a production line. • Unforeseen raw material or component shortages or quality issues that shut down
production. Excessive overtime is then needed in both situations to recoup lost production time and meet customer commitments.
In all of these cases evidence of FEWER hours worked before a period of excessive production in Emergency or unusual situation is present and documented.
Situations that are NOT “emergency” or “unusual” include:
• Peak season production demands and new product ramps. Both of these are predictable and proper planning can minimize overtime requirements.
• Contract change orders that significantly increase order volumes or shorten delivery timelines. This should be negotiated in good faith between the client the location and should never exceed the capacity of the location at a rate of 60 hours per week or the legal maximum work hour requirement for the location.
16.2.2. Working Hours or Hours of Work: refers to the period of time that an individual spends performing paid occupational labor. This means the actual hours of paid “work” by an employee.
What is included in Working Hours is defined in national labor law. Some countries define break time as paid working time, some countries do not. National labor legislation should be checked to clarify the definition of what is included in Working Hours. It is possible that short breaks before and after meals are defined as paid and therefore are working time while lunch or dinner may not. If what is included in Working Hours is not defined in the national labor legislation then EICC accepts that breaks where workers are free (to have lunch/dinner, refreshment, rest, ....) and do not involve company imposed activities such as training, admin duties… are non-‐working time.
16.2.3 Overtime Hours: are paid work hours that are in addition to the standard number of work hours per day or week specified by local or country law.
Some laws define overtime as any time beyond the standard number of work hours per day, while others consider overtime to be only the number of work hours that exceed the standard number of work hours per week. Workers must be paid at a premium for overtime work.
16.2.4 Time Off: Days on which workers are not required to work.
Local or country law typically requires at least one day off per seven-‐day week, as does the EICC Code. Country and local law also stipulate the number of legal holidays to which workers are entitled. Depending on local law or company policy if company policy grants more than the legal required minimum, workers may also be entitled to time off for sickness, vacation, maternity/paternity, family emergencies and other specific situations. Time off may be paid or unpaid, depending on the type of time off, local law and company policy.
16.2.5 Direct employees: are those workers working in various sections who are directly involved in the production process; typically considered to be production line workers.
16.2.6 Indirect employees: are those employees not directly involved in the production process, such as employees working in warehouse, canteen, housekeeping (cleaners), production offices, security.
16.2.7 Office staff: are those employees working in the office such as human resources, accounting, research & development and .... The jobs of these office staff are particular and flexible.
16.3 Examples of Actual or Potential Nonconformance
16.3.1 Working Hours:
• Total hours worked exceed local or national standards, or 60 hours per week, whichever is stricter.
• Excessive working hours due to inconsistency or manipulation of documents related to working hours
16.3.2 Overtime Policies:
• Women or juvenile workers work night shift or overtime when it is prohibited by the applicable labor laws.
• Workers are not informed of overtime 24 hours in advance.
• Workers receive fines, penalties or retribution for refusing overtime. For example, refusal to work overtime results in no future offers of overtime.
• Negative incentives for employees to work overtime
16.3.3 Rest Days/Breaks:
• Amount of rest period given during a work day or during shifts does not comply with local law
• Workers do not average 4 days of rest in a cycle of four work weeks.
• Company policy states that workers have Sundays (or seventh day) off but time records reflect that some workers work all seven days.
• Vacation or personal leave is not allowed in compliance with national laws and regulations.
• Workers are not given legally required holidays.
16.3.4 Recordkeeping:
• A facility does not have a mechanism for employees to control their time records nor are the records available for workers to review.
• Works hours listed on employee pay slips do not match company payroll/timekeeping records.
• Maintaining multiple time-‐keeping systems and/or false records for any fraudulent reason, such as to falsely demonstrate working hours.
• Time records and payroll records are incomplete, inaccurate or manipulated.
• Attendance system cannot retrieve time records or accurate working hours cannot be verified within the system
16.4 Auditor Guidance
The purpose of the Audit is to: • Measure and compare worker standard and overtime hours against the local legal
requirements and the EICC Audit criteria
• Evaluate facility management’s understanding of the legal and EICC requirements for working hours
• Verify the validity of any government-‐issued waivers (such as Comprehensive Working Hours System), and
• Ensure that working hours are accurately recorded and that there is no records falsification
16.4.1 Management Interviews:
Interviews with management are necessary to understand how the facility manages working hours in the facility. However management interviews alone do not provide sufficient information or objectivity to conclude that the facility conforms to the EICC working hours.
• Ask management how they manage working hours to conform to the EICC limit of 60 hours per week and any applicable legal limits.
• Ask management to explain their timekeeping system, including how work hours are recorded and communicated to workers.
• Ask management if workers can freely decline overtime work, and under what circumstances.
• Ask managers how they inform workers of required overtime; how they recruit voluntary overtime work; and if there are any penalties for refusing overtime.
• Ask management about how they plan production/working hours
• Ask management what they do when worker’s hours approach the maximum overtime
• Ask management what they do if worker’s hours exceed maximum overtime.
• Ask management where do they track customer requests for upside work, work during peak times and how do they analyze and respond to that
16.4.2 Gathering information from workers:
The main purpose of gathering information from workers is to verify information provided by management, including ensuring that working hours are not excessive, overtime in the facility is voluntary and paid appropriately.
Suggested worker interview questions: • Has management made you aware of the facility policies and procedures and the
legal requirements for normal working hours, overtime and days off? • How is your attendance at work recorded? • How are your working hours being recorded? Who does the recording?
• How do you review these hours to assure that they are accurate? If you believe that your hours are inaccurate, what are you supposed to do? Have you ever followed these steps? What happened?
• Do you have to punch more than one time card? If so, why?
• Do you ever work when your timecard is not recorded? What happens during that time? How do you receive compensation or payment for that time? How do you feel about this practice?
• What breaks are you supposed to be given and for how long is each? (Morning -‐ first part of work time; lunch -‐ mid-‐work time; afternoon/evening -‐ later part of work time)
• How often do you get these breaks and how long do you normally take?
• Are you asked to attend any work-‐related meetings or trainings for which you are not paid?
• What days of the week are you scheduled to work? • What days of the week do you usually work? • What times do you start and stop work on a regular workday? • What times do you start and stop work on an extra workday? • What are your usual overtime hours? Are they recorded accurately on your pay
slip? • What are your peak months and what overtime do you work during these peak
months? • Under what circumstances is the overtime work considered optional? Under what
conditions is it considered mandatory?
• How do you feel about working the overtime that you do? What are the reasons that you have for working overtime?
• Do you think you work too many hours or would you like to work more?
• What will happen if you do not work the overtime? How would this be different if the overtime was considered optional versus mandatory?
• How many extra days in a week or a month do you usually have to work? Please explain why you have to work these extra hours.
16.4.3 Record Review:
Prior to reviewing or analyzing records, Auditors must:
• Determine type and frequency of payroll activities. Note: if cash payments are made to workers, increase the interview sample size significantly to validate payments.
• Determine if time clocks are locked and if employees punch cards. Compare # and names of employees working to those on time cards. Is all necessary information on timecards?
• Compare and evaluate information on time cards, payroll sheets, computer records (if any), pay stubs, piecework tickets or records and any other sources of payroll activity or journal entries. Is all appropriate information on stubs and other documents? This also applies to information generated by individual stations on unit production systems.
• Are all required documents indicating workers status current, complete, on-‐file and available?
Recommended Auditor Record review activities: • Review records for all employees who have been selected for individual interviews.
The remaining records to be reviewed per the sample size described in Section 8.6 of this Manual.
• The sample of workers to be interviewed and therefore the records to be reviewed should be from different work stations and employee levels within the facility Review, for selected employees, a full 12 months wage records in conjunction with time card and pay records. The records and documents reviewed should include at least one: 1) high production month (peak season), 2) low production month (low season) and 3) average production month
• Summarize and record the details for all records analyzed in order to ascertain the standard work week, overtime hours and holiday/weekend work
• Focus on operators, for the purpose of wage and working hours review. This definition excludes managers and supervisors, but includes production personnel and service workers
• Record details of the standard workweek and overtime practices in the Audit report, including the differences between normal and peak seasons.
• Verify alignment of information from worker interviews, worker pay slips and payroll records.
• If there are any Nonconformances, further analysis may be performed to ascertain the full situation
• Carry out the hours of work review in conjunction with the wage and benefit review
• Where overtime hours exceed national law but are within any waivers obtained, it is particularly important to review a full 12-‐month cycle
• Ensure breaks, holidays and rest periods are in accordance with local law and EICC requirements
Auditors can look at the following documents to verify working hours. Auditors can adapt and/or expand the list depending on the production facility and other local conditions.
• Facility policy related to working hours, rest & breaks, overtime and special provisions for sensitive workers
• Work schedule • Public holiday notices • Attendance records • Monthly overtime summary report • Timecard, Payroll, Pay-‐slip, Bonus structures & policies • Production plan and customer order records • Output reports, QC reports (or daily productivity records) • Overtime request from Production and overtime approval forms • Overtime refusal records • Accident reports & records • Maintenance reports & records • Driver’s recording records • Security guard reports & records • Disciplinary records
• Suggestion/ complaint letters
16.4.5 Visual Inspection: Visual observation of the facility, including production areas, clinic rooms, dormitories, canteens and cafeterias (if applicable), provides another basis for Auditors to make informed judgments about compliance relating to working hours. Also a visual inspection can confirm compliance with requirements for informing workers about the working hours, overtime schedules and the like:
• Closely examine practices in the facility work area. Are there cases where workers who are ostensibly being paid on an hourly basis, counting pieces or collecting tickets? Are there tickets or tick sheets at employee work stations?
• Are time-‐keeping devices (e.g., time clocks) being correctly used? • Are people punching out and then returning to work?
• When surveillance is required, observation of facility entrances or docks just before or just after working hours will sometimes reveal home work arriving or departing and may possibly reveal people engaging in cash transactions. Returning unexpectedly to a time clock shortly after closing time may reveal employees working off the clock.
• If the employees have to submit the approved leave application to Security upon leaving during working hours
• If the employees have to record the timing for toilet or leave the production line
16.5 Evaluation of Conformance:
Auditors will use the following guidance and examples to help determine facility conformance with the Audit criteria.
In evaluating conformance, Auditors must consider both the number/percentage of workers that exceed the Audit criteria or legal requirements as well as the degree or severity of the Nonconformance.
16.5.1 One Day Off per Week
• Workers must receive one day off per seven day week. In practice this means that workers can work a maximum of 12 consecutive days, followed by two consecutive days off, and
• There must be no less than 4 days of rest in any 28 day period.
• Consideration must be given to both how many workers are not receiving one day off per week and whether this is an infrequent or routine occurrence. ▬ Specific thresholds are described in 16.5.3.2 below.
16.5.2 Working Hours
Working hours must be analyzed over a period of the previous 12 months for at least the number of worker records equal to the square root of the total population. In this 12-‐month period, one peak season month, one low season month and one normal production month need to be analyzed in detail.
Include in your evaluation any time spend on work-‐related activities, such as meetings, trainings and work area cleaning that are performed outside of normal working hours. This is considered overtime and must be included in total working hours for the purpose of determining conformance with the Audit criteria. Information about such unpaid overtime situations is typically obtained via worker interviews.
All unusual or exceptional circumstances (as defined in 16.2.1) should be removed from the working hour calculation.
Working hours should be calculated per section (department, unit, ....) and for the total facility (excluding office staff).
The determination of conformance with the EICC working hours limit is done by calculating weekly working hours. Therefore, for the months reviewed (peak, low and average), calculate the hours worked for each week in each month. This will result in a minimum of 12 weekly working hours calculations for each of the workers selected for review.
For determining conformance with legal requirements for overtime, calculate total overtime for each worker for each of the three months selected, either by the week or by the month, depending on how the legal requirement is defined.
Determination of conformance is based on both the extent and severity of the situation. That is, both the number and percentage of workers who exceed the limit and the degree of the exceedance. The reason for this is the need for a reasonable degree of statistical significance. Specific Nonconformance thresholds are described in Section 16.5.3.1 below.
16.5.3 Findings Ratings
16.5.3.1 Working hours
Less 5 percent of workers (total or by specific area or job function
Between 5 to 20 percent of
workers (total or by specific area or job function
Over 20 percent of workers (total or by specific area or job function
More than 84 h/week Priority Priority Priority
Between 60 and 84 h/week Major Priority Priority
Exceeded legal working or over time limit by 20 or
more percent Minor* Major Priority
Exceeded legal working or over time limit by less than
20 percent Minor* Minor* Major
* A tolerance of 1 percent of population is allowed, i.e. if less than 1 percent of workers is detected to do more than legal limit then this is conform
16.5.3.2 Days off
• Priority: 5 percent or more of the population has worked 24 or more consecutive
days • Major: 20 percent or more of workers (either overall or for a particular work area
or job function) worked more than 12 consecutive days • Minor: 5 to 20 percent of workers (either overall or for a particular work area or
job function) worked more than 12 consecutive days
17. Conflict of Interest Policy
The Auditor shall only perform the Validated Audit in relation to the specific Audit instructions provided to it by the APM. Any requests by an Auditee to perform Audits outside of the scope of those specific instructions must be directed to the Buyer.
The Auditor shall not use the result (or the likely result) of any Validated Audit to solicit or engage in any additional consultancy work with an Auditee or its Authorized Recipients.
The Auditor shall not accept any Audits where there may be a possibility of a Conflict of Interest, which might prevent the Auditor from properly performing its duties within the standards of the EICC and standards defined in this Operations Manual.
Standard practice is exclusion for 3 years on same or related issue. This means that if a Validated Audit is performed no other related services can be offered such as certification or consultancy for a period of three years. If certification or consultancy is performed to the Auditee then the Auditor is excluded from performing a Validated Audit.
For large organizations, it is possible for two separate and independent entities within the organization to perform such services. In this case a letter from the country manager or corporate legal counsel is required to ensure that there is no conflict of interest between the Validated Audit and other services performed. The letter shall specifically state the persons involved in previous services and the persons assigned in the Validated Audit and the clear proof that these belong to separate and independent entities within the organization.
18. Waivers of Applicable Law
18.1 Definitions
18.1.1 Waiver: A legal waiver is a written relinquishment of a local authority for a legal entity to comply with a specific requirement of applicable law.
Waivers can only be issued by local authorities if the issuing office has the legal jurisdiction to do so; that is, if it is a competent body. Waivers can be temporary or permanent in nature and are most likely bound by conditions applicable solely to the recipient of the waiver.
18.1.2 Competent body: The institution, organization or office which carries the formal acquired rights to decide on an issue.
In the case of issuing waivers or derogations, this is the office specified by the constitution of the country. In most cases this is the national, federal or state ministry, government body or inspectorate.
Local (municipal, provincial) governments are typically not competent bodies.
18.2 Policy
EICC does not accept waivers or derogations of applicable law unless issued by the competent body, or if the competent body has formally granted specific powers to the local government agency.
When the authority of the local government is in question, the user of the waiver/derogation has the burden of proof to provide formal, documented confirmation from the national or federal judicial body.
18.3 Examples of Good Management Practice:
• Confirmation of local waiver applicability is provided through publication of 1) the waiver, or 2) the power of authority of the waiver/derogation issuer in the national/federal judicial publication.
• The user of a waiver has a formal letter from the national judicial body or competent body stating its waiver is applicable as issued by a local authority.
19 VAP Audit Observer Guidance and feedback
19.1 Overview
The purpose of the VAP (Validated Shared Audit Program) is to evaluate the performance of the EICC members’ supply chain partners against the provisions of the EICC code. Competent Audit firms and Auditors are used in the evaluation process.
To ensure maximum quality and integrity of the process as well as in the spirit of continuous improvement feedback on the performance of the selected Audit firms and Auditors is required.
The role of the VAP Audit “Observer” is to observe a VAP Audit at a supplier facility and to provide feedback (via a survey) on the Audit process and the Audit team members.
The VAP APM will observe the process as well as a shadow Audit. This is a different process and explained by a different guidance document. This document only applies to customer VAP Audit Observers
19.2 Observer Role
The Audit Observer is an employee of one of the EICC member companies and a customer of the facility, which is Audited.
The Observer will not observe worker interviews, nor be made aware of who is being interviewed.
The Observer will only follow the Auditors to facility areas applicable to their company’s business with the supplier (for example, only manufacturing lines that support products for the customer’s company) and common areas.
Only one Observer may participate per facility Audit, unless the Auditee (supplier) approves of multiple Observers attending.
The Observer will need to spend an adequate amount of time with each member of the Audit team to be able to provide a valid assessment of Auditor skills and performance.
The Observer uses the attachments to evaluate: 1. The Audit process and how the Audit team implemented it, as well as how well the Audit team
communicated with facility management. 2. Specific Auditor performance feedback
Specifically, the Observer process survey covers the following areas:
1. Administrative Oversight a. Assess Audit balance of compliance versus management system review b. Assess appropriateness of Audit resourcing and planning c. Compare visual perception of the site (as observed) to the Audit team’s major findings
2. Audit Team Oversight a. Assess that the Audit team follows the Audit process b. Assess that the Audit team followed the Audit documents/criteria c. Assess that the Audit team understands the process and criteria, and can communicate these
details to the facility management and workers
d. Assess the Audit team’s flexibility of the facility’s procedures/methods relative to complying with Audit requirements/criteria
e. Assess the Audit team’s cooperation and professionalism f. Assess the Audit teams capability to assess facility conformance, without getting into trivial
detail g. Assess the Audit team’s ability to review and explain findings appropriately, and allow for
appropriate feedback.
19.3 Specific guidance for the VAP Audit Observer:
• Only 1 external observer (external = customer or HQ/regional office of the Auditee) and only 1 internal observer (internal = Auditee (site) observer are allowed per Audit.
• The observer can be someone from the headquarters (HQ) or regional office of the Auditee. In this case the HQ or regional office observer cannot attend the gathering information from workers or attend the interviews with members of management.
• The Auditee (site) may appoint an observer to follow the entire process. In this case the Auditee (site) observer cannot attend the gathering information from workers or attend the interviews with members of management.
• Ensure he/she is introduced at the beginning of the Audit process to all parties as the observer with relevant details including – Name, company – Function
• The observer will only visit facilities that supplies his/her company
• The Audit team will not share and will keep confidential worker information from the Observer
• On-‐site activities: – Only visit common areas (e.g. canteen, dormitories, faculties areas, pollution control, ....) and
production areas specific to the observer company – Will not interfere or advise the Audit firm on content and logistics of the VAP Audit – Will not advise, guide or interfere with the management of facility – Will be introduced by the Audit company as the Observer on every interaction with staff of the
Audited facility – Will not participate in any worker interactions (informal, formal or group) – Should attend all key on-‐site Audit process steps (especially opening and /closing meeting)
20. EICC Code Good Practices Implementation examples G. GENERAL CODE
G1 Electronic Industry Code of Conduct
G1.1 Management demonstrates a good understanding of and commitment to the EICC Code of Conduct/requirements, has integrated the EICC code/requirements into facility procedures and communicated this effectively to all levels of employees and workers. Good practices: • Site observation: Education/explanation of the EICC code (last version) is displayed in the
work place • Document review: communication and training materials on EICC code to staff and workers
are reworked annually and refresher trainings are provided annually • Management interview: Management can explain the EICC code, its philosophy,
implementation and Audit process. Management can effectively communicate what EICC is • Worker interview: Workers can explain the EICC code and Audit process.
D. LABOR A1 Freely Chosen Employment
Forced, bonded (including debt bondage) or indentured labor; involuntary prison labor; slavery or trafficking of persons shall not to be used. This includes transporting, harboring, recruiting, transferring or receiving vulnerable persons by means of threat, force, coercion, abduction or fraud for the purpose of exploitation. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Workers must not be required to surrender any government-‐issued identification, passports, or work permits as a condition of employment. Excessive fees are unacceptable and all fees charged to workers must be disclosed.
A1.1 Any type of forced, prison, indentured, or bonded (including debt bondage) labor is not used
Good practices: Site observation: Document review: Management interview: Worker interview:
A1.2 Adequate and effective policy and procedures are established against slavery and human trafficking ensuring that any form of forced, bonded or involuntary prison labor is not used.
Good practices: Site observation: Document review: Management interview: Worker interview:
A1.3 Workers are informed in writing and in their own language prior to employment (in case of migrant workers, before they leave their home country/region) of the key employment terms and conditions via employment letter/agreement/contract as required by law
Good practices: Site observation: Document review: Management interview: Worker interview:
A1.4 Upon hiring, the workers government issued identification and personal documentation originals are not withheld by employer/labor agent/contractor (if applicable) without formal consent.
Good practices: Site observation: Document review: Management interview: Worker interview:
A1.5 Workers are free to leave their employment upon giving reasonable notice, with no penalty.
Good practices: Site observation: Document review: Management interview: Worker interview:
A1.6 Workers are not required to pay fees, deposits or debt repayments for their employment
Good practices: Site observation: Document review: Management interview: Worker interview:
A1.7 There are no unreasonable restrictions on the movement of workers and their access to basic liberties Good practices: Site observation: Document review: Management interview: Worker interview:
A1.8 All relevant labor requirements of the EICC Code/requirements are clearly communicated to labor agents/contractors, and they are monitored/Audited to verify conformance. Good practices: Site observation: Document review: Management interview: Worker interview:
A1.9 Recruitment practices and performance are disclosed to customers and other relevant parties Good practices: Site observation: Document review: Management interview: Worker interview:
A2) Child Labor Avoidance
Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the health or safety of young workers.
A2.1 Workers are not below the minimum age
Good practices: Site observation: Document review: Management interview: Worker interview:
A2.2 An adequate and effective policy and process is established to ensure that workers below the legal minimum working age are not hired both directly or via labor agencies / contractors.
Good practices: Site observation: Document review: Management interview: Worker interview:
A2.3 Access to basic educational needs for workers below the age for compulsory education is applied?
Good practices: Site observation: Document review: Management interview: Worker interview:
A2.4 Workers under the age of 18 are not allowed to perform work that is likely to jeopardize the health or safety of these young workers
Good practices: Site observation: Document review: Management interview: Worker interview:
A2.5 Apprentice/intern employment policies and practices are in place
Good practices: Site observation: Document review: Management interview: Worker interview:
A3) Working Hours
Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off per seven-‐day week.
A3.1 Average hours worked in a workweek over the last 12 months does not exceed 60 hours or the legal limit (whichever is stricter).
Good practices: Site observation: Document review: Management interview: Worker interview:
A3.2 Workers receive at least one (1) day off per every seven (7) days
Good practices: Site observation: Document review: Management interview: Worker interview:
A3.3 Adequate and effective policy and system/procedures are established to determine, record, manage and control working hours including overtime
Good practices: Site observation: Working hours policy and implementation mechanism is displayed in the workplace Document review: Management interview: Worker interview:
A3.4 Workers are allowed legally mandated breaks, holidays and vacation days to which they are legally entitled
Good practices: Site observation: Document review: Management interview: Worker interview:
A3.5 Legal regular and overtime working hours and facility working hours are communicated to all workers
Good practices: Site observation: Document review: Management interview: Worker interview:
A3.6 Reliable time records of workers’ regular and overtime working hours on a daily, weekly and monthly basis are kept and available
Good practices: Site observation: Document review: Management interview:
Worker interview:
A4) Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.
A4.1 Legal wages for regular and overtime hours are correctly calculated and paid to all workers (direct and indirect employed workers)
Good practices: Site observation: Document review: Management interview: Worker interview:
A4.2 Wage calculations are clearly communicated to workers using pay stub or similar documentation
Good practices: Site observation: Document review: Management interview: Worker interview:
A4.3 Social insurance scheme and other benefits as required by local law is provided to all workers (direct and indirect)
Good practices: Site observation: Document review: Management interview: Worker interview:
A4.4 Payments to workers are not delayed or withheld and proof of wage payments to workers is maintained
Good practices: Site observation: Document review:
Management interview: Worker interview:
A4.5 Wages are not deducted or reduced for disciplinary reasons Good practices: Site observation: Document review: Management interview: Worker interview:
A4.6 Deductions or withholdings are calculated correctly and submitted to the appropriate government agency within the time frame specified in the applicable local labor law
Good practices: Site observation: Document review: Management interview: Worker interview:
A5) Humane Treatment
There is to be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.
A5.1 No evidence of sexual harassment or abuse, corporal punishment, mental or physical coercion, verbal abuse or intimidation exists Good practices: Site observation: Document review: Management interview: Worker interview::
A5.2 Adequate and effective policies and procedures on decent/humane working conditions and fair treatment of workers are established and communicated to all workers (direct and indirect employed workers)
Good practices: Site observation: Document review:
Management interview: Worker interview:
A5.3 Disciplinary actions are recorded, consistent with the procedures and reviewed by management
Good practices: Site observation: Document review: Management interview: Worker interview:
A5.4 Managers and supervisors are adequately trained on appropriate disciplinary measures/procedures.
Good practices: Site observation: Document review: Management interview: Worker interview:
A5.5 Workers are permitted time off when ill or for maternity
Good practices: Site observation: Document review: Management interview: Worker interview:
A6. Non-‐Discrimination
Participants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.
A6.1 No evidence of discrimination based on grounds of race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status exists.
A6.2 Adequate and effective policies that ban discrimination and harassment are in place.
Good practices: Site observation: Document review: Management interview: Worker interview:
A7) Freedom of Association
Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. The rights of workers to associate freely, join or not join labor unions, seek representation, and join workers’ councils in accordance with local laws shall be respected. Workers shall be able to openly communicate and share grievances with management regarding working conditions and management practices without fear of reprisal, intimidation or harassment.
A7.1 Legal rights of workers for free association are respected
Good practices: Site observation: Document review: Management interview: Worker interview::
A7.2 Adequate and effective communication/training to workers on their legal rights related to freedom of association is provided
Good practices: Site observation: Document review: Management interview: Worker interview:
A7.3 No evidence of unequal treatment between unionized or worker representatives and non-‐unionized workers exists
Good practices:
Site observation: Document review: Management interview: Worker interview::
A7.4 No evidence of control or attempt to control of labor organizations by any means (incentives or intimidation) exists.
Good practices: Site observation: Document review: Management interview: Worker interview:
A7.5 Workers are informed when being employed if automatically enrolled in union or other forms of worker representation
Good practices: Site observation: Document review: Management interview: Worker interview:
A7.6 Are worker representatives democratically elected?
Good practices: Site observation: Document review: Management interview: Worker interview:
F. HEALTH & SAFETY
B1) Occupational Safety
Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tag out), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well-‐maintained, personal protective equipment. Workers shall not be disciplined for raising safety concerns.
B1.1 All required permits, licenses and test reports for occupational safety are in place and a process
is implemented to ensure permits and licenses are up to date at all times
Good practices: Site observation: Document review: Management interview: Worker interview:
B1.2 Appropriate Personal Protective Equipment (PPE) is consistently and correctly used where
required to control safety hazards and worker exposure
Good practices: Site observation: Document review: Management interview: Worker interview:
B2) Emergency Preparedness
Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.
B2.1 All required permits, licenses and testing reports for emergency preparedness are in place and a process is implemented to ensure permits and licenses are up to date at all times
Good practices: Site observation: Document review:
Management interview: Worker interview:
B2.2 Adequate and effective fire detection, alarm and suppression systems are in place.
Good practices: Site observation: Document review: Management interview: Worker interview:
B2.3 All likely types of emergencies that could affect the site are identified and assessed, and adequate and effective emergency preparedness and response programs (plans/procedures) are established.
Good practices: Site observation: Document review: Management interview: Worker interview:
B2.4 Emergency exits, aisles and stairways are adequate in number and location, readily accessible, and
properly maintained
Good practices: Site observation: Document review: Management interview: Worker interview:
B2.5 All employees are provided with appropriate training/communication on fire and other emergencies, as well as the corresponding preparedness and response plans/procedures.
Good practices: Site observation: Document review: Management interview: Worker interview:
B2.6 Adequate and effective fire and other emergency evacuation and response drills are conducted with
B2.7 Designated emergency response personnel are provided adequate and effective PPE and training on a
regular basis
Good practices: Site observation: Document review: Management interview: Worker interview:
B3) Occupational Injury and Illness
Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement corrective actions to eliminate their causes; and e) facilitate return of workers to work.
B3.1 All required permits, licenses and testing reports for occupational injury and illness are in place and a process is implemented to ensure permits and licenses are up to date at all times
Good practices: Site observation: Document review: Management interview: Worker interview:
B3.2 Investigations to determine root cause(s) and implement corrective/preventive actions for work-‐
related injuries/illness in the past three years are performed and documented
Good practices: Site observation: Document review: Management interview: Worker interview:
B3.3 A effective process and adequate first aiders to provide medical treatment for injured or ill workers is
in place
Good practices: Site observation: Document review: Management interview:
Worker interview:
B3.4 Adequate first aid kits to provide medical treatment for injured or ill workers are in place
Good practices: Site observation: Document review: Management interview: Worker interview:
B3.5 Workers know what to do in the event they are injured or become ill on the job
Good practices: Site observation: Document review: Management interview: Worker interview:
B4) Industrial Hygiene
Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. Engineering or administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is to be protected by appropriate personal protective equipment programs.
B4.1 All required permits, licenses and testing reports for Industrial hygiene are in place and a process is implemented to ensure permits and licenses are up to date at all times
Good practices: Site observation: Document review: Management interview: Worker interview:
B4.2 Appropriate controls for worker exposures to chemical, biological and physical agents are implemented
Good practices: Site observation: Document review: Management interview: Worker interview:
B5) Physically Demanding Work
Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.
B5.1 All required permits, licenses and testing reports for ergonomics are in place and a process is implemented to ensure permits and licenses are up to date at all times
Good practices: Site observation: Document review: Management interview: Worker interview:
B5.2 Worker exposure to the hazards of physically demanding work is identified, assessed and controlled
adequately and effectively
Good practices: Site observation: Document review: Management interview: Worker interview:
B6) Machine Safeguarding
Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.
B6.1 All required permits, licenses and testing reports for machinery are in place and a process is implemented to ensure permits and licenses are up to date at all times
Good practices: Site observation: Document review: Management interview: Worker interview:
B6.2 Workers operate machinery safely, including proper use of machine safeguards and emergency stop switches
Good practices: Site observation: Document review: Management interview: Worker interview:
B6.3 An adequate and effective machine-‐safeguarding program is implemented
Good practices: Site observation: Document review: Management interview: Worker interview:
B7) Food, sanitation and housing
Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the Participant or a labor agent are to be maintained clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, and adequate heat and ventilation and reasonable personal space along with reasonable entry and exit privileges.
B7.1 All required health & safety licenses, permits, registrations and certificates related to food, sanitation and housing are in place and an adequate and effective process is established to ensure permits and licenses are up-‐to-‐date at all times
Good practices: Site observation: Document review: Management interview: Worker interview:
B7.2 Dormitories are clean, safe and well maintained and meet international housing standards
Good practices: Site observation: Document review: Management interview:
Worker interview:
B7.3 Canteens (cafeterias) are clean, well maintained, and managed in compliance with local health regulations
Good practices:
Site observation: Document review: Management interview: Worker interview:
B7.4 Food service workers have undergone appropriate health checks and food safety training, and have
valid certificates.
Good practices: Site observation: Document review: Management interview: Worker interview:
G. ENVIRONMENT
C1) Environmental Permits and Reporting
All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.
C1.1 The facility has obtained all the legally required environmental permits, approvals, licenses and registrations.
Good practices: Site observation: Document review: Management interview: Worker interview:
C1.2 Reporting to environmental authorities as required by law is performed timely.
Good practices: Site observation: Document review: Management interview: Worker interview:
C2) Pollution Prevention and Resource Reduction
Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-‐using materials.
C2.1 Established adequate and effective programs, including targets, to: a) eliminate, reduce or control pollution (emissions, discharges, wastes) and b) conserve resources (energy, water, materials) in place.
Good practices: Site observation: Document review: Management interview: Worker interview:
C3) Hazardous Substances
Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
C3.1 Hazardous materials including wastes are properly categorized, labeled, handled, stored, transported and disposed using government-‐approved/licensed vendors as per local laws. Good practices: Site observation: Document review: Management interview: Worker interview:
C3.2 Workers who work with hazardous substances are provided adequate and effective training.
Good practices: Site observation: Document review: Management interview: Worker interview:
C3.3 Waste vendor(s) have been Audited to verify that waste is handled, stored and disposed of in
accordance with local regulations, permit conditions and contract requirements
Good practices: Site observation: Document review: Management interview: Worker interview:
C4) Wastewater and Solid Waste
Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be characterized, monitored, controlled and treated as required prior to discharge or disposal.
C4.1 Solid waste is managed and disposed of in accordance with applicable legal requirements
Good practices: Site observation: Document review:
Management interview: Worker interview:
C4.2 Effluent discharges (industrial/process wastewater, sewage and storm water) meet the discharge
limits for regulated constituents.
Good practices: Site observation: Document review: Management interview: Worker interview:
C5) Air Emissions
Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-‐products generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge.
C5.1 Air emissions meet the discharge limits for regulated constituents
Good practices: Site observation: Document review: Management interview: Worker interview:
C5.2 Environmental noise levels are within regulatory limits
Good practices: Site observation: Document review: Management interview: Worker interview:
C6) Product Content Restrictions
Participants are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances, including labeling for recycling and disposal.
C6.1 An effective program is in place to make legal and customer requirements for product content as a formal part of their procurement and manufacturing processes including effective processes, procedures and records are in place to measure or document the chemical composition of products.
Good practices: Site observation: Document review: Management interview: Worker interview:
C6.2 Effective processes and procedures are in place to request and obtain relevant chemical composition information from their suppliers, including certificates and analytical reports Good practices: Site observation: Document review: Management interview: Worker interview:
D. ETHICS
D1) Business Integrity
The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement (covering promising, offering, giving or accepting any bribes). All business dealings should be transparently performed and accurately reflected on Participant’s business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-‐corruption laws.
D1.1 Adequate and effective Code of Business Ethics or Standards of business conduct, endorsed by senior management is established Good practices: Site observation: Document review: Management interview: Worker interview:
D1.2 All workers/employees are provided adequate and effective communication/training on the code of ethical conduct. Good practices: Site observation: Document review: Management interview: Worker interview:
D1.3 Effective procedures to ensure conformance with customers’ business integrity standards/code requirements and a system to monitor their performance is in place Good practices: Site observation: Document review: Management interview: Worker interview:
D1.4 Business ethics/integrity procedures are communicated effectively to all subcontractors, suppliers, business partners and relevant parties Good practices: Site observation: Document review:
Management interview: Worker interview:
D1.5 An effective risk assessment to determine vulnerabilities and prioritize corruption risks taking into
account business circumstances (country of operations, stakeholders, ...) is established Good practices: Site observation: Document review: Management interview: Worker interview:
D1.6 Employees who refuse to participate in bribery or facilitation payments are supported by the business
and will not suffer demotion, penalty or other adverse consequences even if this action may result in the enterprise losing business. Good practices: Site observation: Document review: Management interview: Worker interview:
D1.7 Records of employees declaring any personal interest or conflict of interests that may influence their
judgment are kept and available
Good practices: Site observation: Document review: Management interview: Worker interview:
D2) No Improper Advantage
Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.
D2.1 Effective and written policy that ensures gifts to or from suppliers and customers is not excessive in cost and frequency and hospitality, expenses or promises as such that may compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with, or direct business to, any person, or to influence the course of the business or governmental decision-‐making process is established.
Good practices: Site observation: Document review: Management interview:
Worker interview:
D2.2 Effective procedures for addressing its workers or agents suspected of making or accepting improper offers of payments or gifts and attempted bribery in all forms, the appropriate investigation and subsequent sanctions are applied are in place
Good practices: Site observation: Document review: Management interview: Worker interview:
D3) Disclosure of Information
Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain are unacceptable.
D3.1 Is the facility reporting its business activities in accordance with local laws and regulations?
Good practices: Site observation: Document review: Management interview: Worker interview:
D3.2 Is the facility reporting its business activities in accordance with local laws and regulations?
Good practices: Site observation: Document review: Management interview: Worker interview:
D4) Intellectual Property
Intellectual property rights are to be respected; transfer of technology and know-‐how is to be done in a manner that protects intellectual property rights.
D4.1 Effective procedures to ensure the protection of intellectual property (their own and that of their customers) are established
Good practices: Site observation: Document review: Management interview: Worker interview:
D5) Fair Business, Advertising and Competition
Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must be available.
D5.1 The facility has a program to ensure advertising statements are not false or misleading and they meet fair business and advertising legal requirements?
Good practices: Site observation: Document review: Management interview: Worker interview:
D5.2 Effective and written policy prohibiting collusion is established and communicated to workers, employees and business partners
Good practices: Site observation: Document review: Management interview: Worker interview:
D5.3 A formal and effective process to protect customer information is established
Good practices: Site observation: Document review: Management interview: Worker interview:
D6) Protection of Identity
Programs that ensure the confidentiality and protection of supplier and employee whistleblowers are to be maintained.
D6.1 A way to confidentially report suspected ethical misconduct is available to workers and protects them from retaliation or other consequences
Good practices: Site observation: Document review: Management interview: Worker interview:
D6.2 A way to confidentially report suspected ethical misconduct is available to employees of suppliers and protects them from retaliation or other consequences
Good practices: Site observation: Document review: Management interview: Worker interview:
D7) Responsible Sourcing of Minerals
D7.1 A policy to reasonably assure that purchasing of the 3TG minerals does not directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries with an effective procedures to establish and monitor responsible sourcing of minerals and capable of making the due-‐diligence measures available upon request from customers.
Good Practices: Site observation: Clearly posted Company policy or procedure is in place against knowingly purchasing 3TG minerals that directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries, Document review: Training materials exist to educate employees on the policy and procedures to avoid knowingly purchasing 3TG minerals that directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries, Management interview: Managers state that training materials exist to educate employees to avoid knowingly purchasing 3TG minerals that directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries, Worker interview: Workers state they have participated in training on how to avoid knowingly purchasing 3TG minerals that directly or indirectly finance armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of Congo or surrounding countries,
D8) Privacy
We are committed to protecting the reasonable privacy expectations of personal information of everyone we do business with, including suppliers, customers, consumers and employees. Comply with privacy and information security laws and regulatory requirements when personal information is collected, stored, processed, transmitted, and shared.
D8.1 A formal and effective process to protect privacy is established
Participants should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.
D9.1 Effective procedures to ensure non retaliation are established and communicated
Good practices: Site observation: Document review: Management interview: Worker interview:
E. MANAGEMENT SYSTEM
E1) Company Commitment
Corporate social and environmental responsibility policy statements affirming Participant’s commitment to compliance and continual improvement, endorsed by executive management.
E1.1 Adequate and effective policies/codes that are endorsed by executive management, covering: A) Labor B) Health & Safety C) Environment D) Ethics.
Good practices: Site observation: Document review: Management interview: Worker interview:
E2) Management Accountability and Responsibility
The Participant clearly identifies company representative[s] responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.
E2.1 Responsibilities and authorities are adequately and effectively defined and assigned for all employees/workers (senior managers to workers) for implementation of management systems, and for compliance with laws, regulations and codes pertaining to: A) Labor B) Health & Safety C) Environment D) Ethics.
Good practices: Site observation: Document review: Management interview: Worker interview:
E2.2 An adequate and effective management review and continuous improvement process for A) Labor, B) Health & Safety, C) Environment and D) Ethics performance and management systems is established
Good practices: Site observation: Document review: Management interview:
Worker interview:
E3) Legal and Customer Requirements
A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.
E3.1 An adequate and effective compliance process to monitor, identify, understand and ensure compliance with applicable laws and regulations and customer requirements pertaining to: A) Labor B) Health & Safety C) Environment D) Ethics is established
Good practices: Site observation: Document review: Management interview: Worker interview:
E4) Risk Assessment and Risk Management
Process to identify the labor practice and ethics risks associated with Participant’s operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
E4.1 An adequate and effective risk management process to identify, assess, and minimize/mitigate/control its risks in the areas of: A) Labor B) Health & Safety C) Environment D) Ethics is in place
Good practices: Site observation: Document review: Management interview: Worker interview:
E5) Improvement Objectives
Written performance objectives, targets and implementation plans to improve the Participant’s social performance, including a periodic assessment of Participant’s performance in achieving those objectives.
E5.1 An adequate and effective performance management process for A) Labor, B) Health & Safety, C) Environment, and D) Ethics, including setting performance (improvement) objectives and targets, developing and implementing improvement plans, regularly reviewing progress toward achieving targets, and making appropriate adjustments if needed is in place
Good practices: Site observation: Document review: Management interview: Worker interview:
E6) Training
Programs for training managers and workers to implement Participant’s policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.
E6.1 An adequate and effective training process is established for all employees/workers on all policy/procedures/job related aspects and performance targets related to A) Labor, B) Health & Safety, C) Environment, and D) Ethics
Good practices: Site observation: Document review: Management interview: Worker interview:
E7) Communication
Process for communicating clear and accurate information about Participant’s policies, practices, expectations and performance to workers, suppliers and customers.
E7.1 An adequate and effective worker/employee, supplier and customer communication/reporting process about A) Labor, B) Health & Safety, C) Environment, and D) Ethics policies, practices and performance is established
Good practices: Site observation: Document review: Management interview: Worker interview:
E8) Worker Feedback and Participation
Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.
E8.1 An adequate and effective worker grievance/complaint process whereby workers can confidentially communicate work-‐related grievances or complaints without fear of reprisal or intimidation is established
Good practices: Site observation: Document review: Management interview: Worker interview:
E8.2 An adequate and effective worker consultation/participation process whereby management solicits and encourages worker feedback and participation for improvement via various channels is in place
Good practices: Site observation: Document review: Management interview: Worker interview:
E9) Audits and Assessments
Periodic self-‐evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.
E9.1 An adequate and effective Audit process to periodically assess conformance with the EICC Code including compliance with applicable laws and regulations pertaining to: A) Labor B) Health & Safety C) Environment D) Ethics.
Good practices: Site observation: Document review: Management interview: Worker interview:
E10) Corrective Action Process
Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
E10.1 Has established an adequate and effective corrective actions process to rectify and close non-‐conformances with the EICC Code including legal non-‐compliances identified via internal or external Audits, assessments, inspections, investigations and reviews, covering A) Labor B) Health & Safety C) Environment D) Ethics.
Good practices: Site observation: Document review: Management interview: Worker interview:
E10.2 Violations have been corrected or are on track for correction, where monetary penalties were assessed, or where formal corrective actions were mandated by the issuing government agency for A) Labor B) Health & Safety C) Environment D) Ethics.
Good practices: Site observation: Document review: Management interview: Worker interview:
E11) Documentation and Records
Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
E11.1 Adequate and effective documentation and records for A)Labor, B)Health & Safety, C)Environment, and D)Ethics management systems are maintained and appropriate levels of access to ensure privacy are implemented.
Good practices: Site observation: Document review: Management interview: Worker interview:
E12) Supplier Responsibility
Process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.
E12.1 The EICC Code requirements have been communicated to the next tier suppliers
Good practices: Site observation: Supplier on going communication is used such as posters in reception, ... Document review: Has documented EICC code implementation awareness sessions for suppliers. Provide material to suppliers to train workers on EICC code implementation Management interview: Management can describe the training or supplier sessions/refresher sessions which were held within the last year Worker interview: If workers of suppliers are on-‐site: workers can state when they were trained and explain the content of the code.
E12.2 An effective process to ensure that the next tier suppliers implement the Code is implemented Good practices: Site observation: Not Applicable Document review: Suppliers are included into the EICC VAP program Management interview: Management can explain which CAP process they use and how many CAPs have been identified and closed and for how many suppliers. Management has engaged third party Auditing of its suppliers Worker interview: Not Applicable
21. Auditee Self-‐Assessment Questionnaire (Facility level) The Self-‐Assessment Questionnaire (SAQ) is one of the three main tools used to determine a company’s potential corporate responsibility risk. It is used in Phase Two of the Engagement Model.
The SAQ can assess either member’s own operations or a supplier’s. When the SAQ is used with suppliers, the results can be used to set the Priority for further engaging suppliers in the other phases of the Engagement Model
The intent of the questionnaire is to promote an open and constructive dialogue regarding best practices in the management of environmental and social responsibility. An honest and transparent company self-‐assessment represents a first step toward working to improve management systems and overall corporate responsibility performance. Members and suppliers demonstrate their continuous improvement through periodic updates of the questionnaire.
A member generally completes SAQ first for their own operations and then for their suppliers. A completed self-‐assessment questionnaire score primarily indicates the potential for risk but also provides an assessment of conformance to the EICC Code of Conduct. Risk potential is the determination of key facility characteristics (e.g., hazardous materials, contract workers) relevant to inherent risk parameters (e.g., likelihood, severity, exposure or inherent vulnerability). The risk can either be inherent in the company’s operations or program-‐related.
The SAQ is not intended to measure corporate responsibility performance. The output of the tool and associated scoring system do not necessarily indicate how well a company is managing its corporate responsibility risk. The tool can be used to identify the need for managing risk; however implementation of such opportunities may not necessarily impact assessment results.
Through self-‐assessment and training, a company (member) either starts or continues in their journey of continuous improvement. Even the most experienced companies (members) find enhancements that can be made to their business practices and programs.
Self-‐Assessment Questionnaire Framework
The SAQ utilizes a standardized list of questions to assess labor, ethics, health, safety and environmental practices in the supply chain. When utilized with suppliers, it raises their awareness about the importance of these areas, clarifies customer expectations, supports customer assessment of supplier’s characteristics and potential risks, and enables companies to evaluate, improve and communicate their performance.
Specific issues that fall under each area reflect the elements of the EICC Code of Conduct standards. These topics are also frequently found in many company supplier codes of conduct.
Self-‐Assessment Questionnaire Levels: Corporate and Facility Reporting The SAQ is divided into two kinds of assessment: a Corporate Assessment and a Facility Assessment. These assess management of corporate responsibility issues across the company and within specific operations. A company would complete one Corporate Assessment and one or more Facility Assessments, depending on the structure of the company.
• Corporate Self-‐Assessment -‐ examines the business entity that owns or controls operations and/or the assets of other business entities (facilities). The Corporate Assessment examines the corporate headquarters.
• Facility Self-‐Assessment -‐ evaluates the specific facilities that make up the company. The Facility questionnaire examines site-‐specific conditions and processes that may contribute to various Ethics, Labor, Environmental or Health and Safety risks.
For more information and access to the SAQ: http://eicc.info/Self%20Assessment%20Questionnaire.shtml
22. EICC Recognized Audits
In addition to the Validated Audit Process, the EICC is also recognizing two other variations, Customer Manager Audits (CMA) and Auditee Managed Audits (AMA). These two variations of the audit are to support member company efforts to progress the implementation of the EICC Code of Conduct throughout the supply chain and meet membership requirements.
Auditee Managed Audit (AMA) -‐ An audit paid/overseen by the auditee; conducted by an outsourced EICC approved audit firm.
Customer Managed Audit (CMA) -‐ An audit paid/overseen by a customer of an auditee; conducted by an outsourced EICC approved audit firm.
The AMA and CMA leverage the general processes (e.g. auditor qualification) and tools (e.g. audit protocol) developed for the VAP to ensure the audits are of similar quality. This is to protect the credibility of the EICC brand, including the code and membership at large. A comparison of the various aspects of the AMA, CMA and VAP are provided in the table below.
Comparison of Audit Types Validated Audit Process (VAP)
Auditee Managed Audit (AMA)
Customer Managed Audit
(EICC CMA) Audit based on the EICC VAP Checklist (at a minimum)
√ √ √
Number of days on site and worker interviews based on level of complexity
√ √ √
Audit scope includes entire facility (subject to restricted access areas).
√ varies varies
Audit report is owned by the Auditee √ √ varies Report may be shared (subject to auditee approval)
√ Varies varies
Auditor is from an EICC Approved Audit Firm √ √ √ Auditor is either IRCA EICC Certified or EICC VAP Approved
√ √ √
External quality review √ Varies Varies The Company Audit Program Manager who manages the AMA and CMA process is responsible to ensure that the requirements above are adhered to when managing these audits.
For additional guidelines on the AMA and CMA process, please refer to the “EICC Code of Conduct Audits – Definition of Recognized Variations” available on the EICC members’ Sharepoint.
23. Audit Process Flow
24. Intellectual Property Protection Requirements for Auditors In the course of performing CR Audits on behalf of EICC, Auditors will encounter situations involving intellectual property of the Audited facility, a customer of the facility, or other Auditees to the facility. In such cases, the Auditor must strictly adhere to the following requirements to ensure the protection of intellectual property.
24.1 Off-‐Limits Portions of Facilities
In some cases, certain portions of the facility will be off-‐limits to the Audit team due to intellectual property concerns. If any limits have been imposed by a customer of the facility are know in advance, the APM will inform you at the time of Audit assignment.
In all other cases, facility management will inform you of these limits. In these cases:
• Have the Lead Auditor note this limit in the Executive Summary of the Audit Report.
• Do not attempt to enter the off-‐limits portion of the facility or to gather information related to this portion of the facility.
• If you accidentally enter the off-‐limits portion of the facility or discover information related to this portion of the facility, do not include this information in the Audit notes or report, and do not discuss the information with anyone related to or unrelated to the Audit under any circumstances.
24.2 Handling Sensitive Information
In the course of the Audit, you may come across information that is sensitive due to intellectual property concerns. Sensitive information is categorized as “relevant” to the Audit (i.e. necessary to answer an Audit question), or “irrelevant” to the Audit (i.e. not necessary to answer an Audit question). Below are lists of both categories of sensitive information, and requirements for managing each category:
24.2.1 Relevant Sensitive Information includes: • Production processes and equipment • Descriptions of raw materials and components • Financial information
Rules for managing Potentially-‐Relevant sensitive information: • Do not request this data unless necessary to answer an Audit Criteria question.
• If this data is offered to you, do not accept it unless necessary to answer an Audit Criteria question.
• If this data is accidentally provided to you, return it immediately without reviewing it unless necessary to answer an Audit Criteria question.
• Do not record this data in Audit notes unless directly related to the answer to an Audit Criteria question.
• Do not include specific descriptions of this data in the Audit report (e.g., Auditee name of specific components; names of custom production equipment; ....).
• Do not reveal this data to anyone related to or unrelated to the Audit under any circumstances.
24.2.2 Irrelevant Sensitive Information includes: • Name or other identifying information of brands with whom the facility does, has
done, or will do business • Brand-‐specific product information • Product designs • Research and development projects • Third-‐party confidential information • Business plans • Business opportunities
Rules for managing irrelevant sensitive information: • Do not request this data under any circumstances. • If this data is offered to you, do not accept it under any circumstances.
• If this data is accidentally provided to you, return it immediately without reviewing it.
• Do not record this data in Audit notes. • Do not include this data in the Audit report.
• Do not reveal this data to anyone related to or unrelated to the Audit under any circumstances.
24.2.3 General Rules for Protecting Audit Information
For all Audits, observe the following rules to protect information: • Only make copies of paper or electronic files as necessary.
• Only share paper or electronic files with other members of the Audit team, and only as necessary.
• Once the Audit report is finalized, secure all paper and electronic working papers and drafts in appropriately protected, limited access storage.
• Do not discuss the Audit results or any information gained from the Audit with anyone outside of the Audit team or the APM, and only as necessary to finalize the Audit report.
25 Workers’ accommodation: processes and standards
These Worker’s accommodation processes and standard are modified form the original International Finance Corporation (IFC), member of the World Bank Group and European Bank for Reconstruction and Development (EBRD) “Workers’ accommodation: processes and standards” EICC Acknowledges and thanks IFC and EBRD for the generation of the processes and standards and allowing modified use for EICC purposes.
25.1 A process approach
There are several stages to the process of addressing issues raised by worker accommodation. These are:
§ Awareness of the national and local regulatory framework § Determining the standards to apply to the location of facilities, the construction of housing and
provision of facilities § Managing accommodation effectively
There are no comprehensive international regulations relating to worker accommodation. However, there are legal and regulatory instruments and guidance that relate to particular aspects of the provision of worker housing. This guidance note is based on a review of these instruments and legislation, as well as guidelines and best practices produced by a range of different private and public sector actions at national and international level. As such, the processes and standards cited often represent a range of acceptable practice. The particular standard to be applied will depend on criteria such as the type of project, location, climate and length of project. However, in all cases at least the minimum standard should be applied.
25.2 PLANNING AND ASSESSING REQUIREMENTS FOR WORKERS’ ACCOMMODATION
25.2.1 The general regulatory framework
In considering worker housing it is important to be aware of the international, national and local regulatory framework. At a general level, several international instruments recognise a right to an adequate standard of housing for everyone or for specific categories of the population. To ensure the full realisation of this right, binding instruments generally require the State to take appropriate steps and measures. For workers, the recognition of such a right has been included in ILO Conventions and Recommendations on Plantations and on Safety and Health in Agriculture and in the ILO Recommendation 115 on Workers’ Housing (1961) in particular. Although the latter is a non-‐binding recommendation providing guidance on policy, legislation and practice to the State and to the national authorities in charge of housing in particular, it offers useful guidance on what is expected from employers who provide housing to their employees, and it spells out a number of housing standards
25.2.2 ILO Workers' Housing Recommendation 115
§ It is generally not desirable for employers to provide housing for their workers directly and employers should use alternatives where possible. If there are no alternatives, specific attention should be paid to renting arrangements, workers’ rights and housing standards. In addition, the possibility of worker-‐occupants acquiring, for a fair price, ownership of housing provided by the employer should also be examined.
• Renting arrangements should be fair. Adequate and decent housing should not cost the worker more than a reasonable proportion of their income and should never include a speculative profit.
• The employer should be entitled to repossess the accommodation within a reasonable time in the event of termination of the worker's contract of employment and the worker should be entitled to a reasonable period of continued occupancy and / or fair compensation when he ceases to exercise his employment.
• During the time workers spend in the worker accommodation they should enjoy their fundamental human rights and freedom of association in particular. Workers’ accommodation arrangements should not restrict workers’ rights and freedoms.
• Housing standards should include special attention to the following:
ü Minimum space allocated per person or per family (floor area; cubic volume; or size and number of rooms)
ü Supply of safe water in the workers' dwelling in such quantities as to provide for all personal and household uses;
ü Adequate sewage and garbage disposal systems;
ü Appropriate protection against heat, cold, damp, noise, fire, and disease-‐carrying animals, and, in particular, insects;
ü Adequate sanitary and washing facilities, ventilation, cooking and storage facilities and natural and artificial lighting;
ü A minimum degree of privacy both between individual persons within the household and for the members of the household against undue disturbance by external factors; and
ü The suitable separation of rooms devoted to living purposes from quarters for animals.
• Where accommodations are provided for single workers or workers separated from their families, additional housing standards should be considered:
ü A separate bed for each worker;
ü Separate gender accommodation
ü An adequate drainage and sanitary conveniences; and
ü Common dining rooms, canteens, rest and recreation rooms and health facilities, where not otherwise available in the community.
At a national or regional level, regulations tend to contain only general provisions requiring employers to provide a decent standard of accommodation to workers. However, in some jurisdictions there are detailed regulations or standards setting out a comprehensive framework to be applied2. There may also be building regulations relating to issues such as sanitation, safety or building materials that must be adhered to. Therefore, national regulations and standards are the first place to look when determining the necessary standards for living facilities. However, responsibility for planning and building standards may well lie with regional or local levels of government, so it is important that these local authorities are consulted. Provisions on worker accommodation can also be found in policy, guidelines or codes of practice adopted by a wide variety of actors such as international bodies, industry associations, national, regional or local authorities. Compliance with national and local law is the basic and essential requirement.
25.3 STANDARDS OF WORKERS’ ACCOMMODATION.
25.3.1 Standards for workers’ accommodation
This section looks at the principles and standards applicable to the location and construction of workers’ accommodation, including the transport systems provided, the general living facilities, rooms / dormitories facilities, sanitary facilities, canteen and cooking facilities, food safety, medical facilities and leisure/social facilities
25.3.1.1 National/local standards
The key standards that need to be taken into consideration as a baseline are those contained in national/local regulations. Although it is quite unusual to find regulations specifically covering worker accommodation, there may well be general construction standards that will be relevant. These may include standards on the following: • Building construction: e.g. quality of material, construction methods, and resistance to
earthquakes. • Housing and public housing: in some countries regulations for housing and public housing
contain requirements on issues such as the basic amenities, and standards of repair. • General health, safety and security: requirements on health and safety are often an important
part of building standards and might include provisions on occupation density, minimal air volumes, ventilation, the quality of the flooring (slip-‐resistant) or security against intrusion.
2 See for instance: United States -‐ Occupational Health and Safety Act (Standards 29, paragraph 1910.142) Brazil -‐ Health and safety regulation in the agricultural, livestock farming, forestry and aquaculture sectors, 2005 Malaysia -‐ Workers' minimum standards of housing and amenities Act, 1990 Singapore -‐ Code of practice on environmental health, 2005
• Fire safety: requirements on fire safety are common and are likely to apply to housing facilities of any type. This can include provision on fire extinguishers, fire alarms, number and size of staircases and emergency exits, restrictions on the use of certain building materials.
• Electricity, plumbing, water and sanitation: national design and construction standards often include very detailed provisions on electricity or plumbing fixtures/fittings, water and sanitation connection/equipment.
25.3.2 General living facilities
Ensuring high standards in living facilities is important in order to avoid safety hazards and to protect workers from diseases and/or illness resulting from humidity, bad/stagnant water (or lack of water), cold, spread of fungus, proliferation of insects or rodents. The location of the facilities is important to prevent exposure to wind, fire, flood and other natural hazards. It is also important that workers’ accommodation is unaffected by the environmental or operational impacts of the worksite (for example noise, emissions or dust) but is sufficiently close that workers do not have to spend undue amounts of time travelling from their accommodation to the worksite. Living facilities should be built in adequate materials and should always be kept in good repair, clean and free from rubbish and other refuse. Benchmarks 1. Facilities are located to avoid flooding and other natural hazards. 2. Where possible, workers’ accommodation is located within a reasonable distance from the worksite. 3. Transport from worker accommodation to worksite is safe and free. 4. The living facilities are built with adequate materials, kept in good repair and maintained clean and free from rubbish and other refuse
25.3.2 Drainage
The presence of stagnant water is a factor of proliferation of potential disease vectors such as mosquitoes, flies and others, and must be avoided.
Benchmarks 1. The site of building is adequately drained to avoid the accumulation of stagnant water.
25.3.3 Heating, air conditioning, ventilation and light
Heating, air-‐conditioning and ventilation should be appropriate for the climatic conditions and to provide workers with a comfortable and healthy environment to rest and spend their spare time.
Benchmarks 1. When living facilities are located in cold weather zones, the temperature is kept at a level of around 20 degrees Celsius notwithstanding the need for adequate ventilation. 2. When they are located in hot weather zones, living facilities are provided with adequate ventilation and/or air conditioning systems. 3. Both natural and artificial lighting are provided in living facilities. It is best practice that the window area represents not less than 5 to 10% of the floor area.
25.3.4 Water
Special attention to water quality and quantity is absolutely essential. To prevent dehydration, water poisoning and diseases resulting from lack of hygiene, workers should always have an easy access to a source of clean water. An adequate supply of potable water must be available in the same buildings where bedrooms or dormitories are provided. Drinking water must meet local or WHO drinking water standards. Depending on the local context, it could either be produced by dedicated catchment and treatment facilities or be tapped from existing municipal facilities if their capacity and quality are adequate. It is also best practice to provide workers with cool drinking water.
Benchmarks 1. Workers have access to an adequate and convenient supply of free potable water is always available. Depending on climate, weather conditions and accommodation standards, 80 to 180 litres per person per day are available. 2. Drinking water meets national / local or WHO drinking water standards3. 3. All tanks used for the storage of drinking water are constructed and covered as to prevent water stored therein from becoming polluted or contaminated.
25.3.5 Waste water and solid waste
Waste water treatment and effluent discharge as well as solid waste treatment and disposal must comply with local or World Bank effluent discharge standards and be adequately designed to prevent contamination of any water body, to ensure hygiene and to avoid the spread of infections and diseases, the proliferation of mosquitoes, flies, rodents, and other pest vectors. Depending on the local context, treatment and disposal services can be either provided by dedicated or existing municipal facilities.
Benchmarks 1. Waste water, sewage, food and any other waste material are adequately discharged, in compliance with local or World Bank standards and without causing any significant impacts on camp residents, the biopysical environment or surrounding communities. 2. Specific containers for rubbish collection are provided and emptied on a regular basis. Standards range from providing adequate number of rubbish containers to providing leak proof, non-‐absorbent, rust and corrosion resistant containers protected from insects and rodents. In addition it is best practice to locate rubbish containers 30 meters of each shelter on a wooden, metal, or concrete stand. Such containers must be emptied on regular intervals (to be determined based on temperatures and volumes generated) to avoid unpleasant odours associated with decaying organic materials. 3. Pest extermination, vector control and disinfection are carried out throughout the living facilities in compliance with local requirements and/or good practice. Where warranted, pest and vector monitoring should be performed on a regular basis.
The standards of the rooms or dormitory facilities are important to allow workers to rest properly and to maintain good standards of hygiene. Overcrowding should be avoided particularly. This also has an impact on workers’ productivity and reduces work-‐related accidents. It is generally acknowledged that rooms/dormitories should be kept clean and in a good condition. Exposure to noise and odour should be minimised. In addition, rooms/dormitories design and equipments should strive to offer workers a maximum of privacy. Resorting to dormitories should be minimised and single or double rooms must be preferred. Dormitories and rooms must be separate sex. Benchmarks 1. Rooms / dormitories are kept clean and in good condition. 2. Rooms / dormitories are aired and cleaned at regular intervals. 3. Rooms / dormitories are built in easily cleanable flooring material. 4. Sanitary facilities are located within the same buildings. 5. Density standards are expressed either in terms of minimal volume per resident or of minimal floor space. Usual standards range from 10 to 12.5 cubic m (volume) or 4 to 5.5 square meters (surface). 6. A minimum ceiling height of 2.10 meters is provided. 7. In collective rooms, which are minimised, in order to provide workers with some privacy, only a reasonable number of workers are allowed to share the same room. Standards range from 2 to 8 workers. 8. All doors and windows should be lockable, and provided with mosquito nets where conditions warrant. 9. There should be mobile partitions or curtains to ensure privacy 10. Every resident is provided with adequate furniture such as a table, a chair, a mirror and a bedside light. 11. Separate sleeping areas are provided for men and women, except in family accommodation.
25.3.7 Bed arrangements and storage facilities
The provision of an adequate numbers of beds of an appropriate size is essential to provide workers with decent, safe and hygienic conditions to rest and sleep. Here again, particular attention should be paid to privacy. Consideration should be given to local customs so beds could be replaced by hammocks or sleeping mats for instance.
Benchmarks 1. A separate bed for each worker is provided. The practice of “hot-‐bedding” is prohibited. 2. There is a minimum space between beds of 1 meter. 3. Double deck bunks are not advisable for fire safety and hygiene reasons, and their use is minimised. Where they are used, there must be enough clear space between the lower and upper bunk of the bed. Standards range from to 0.7 to 1.10 meters. 4. Triple deck bunks are prohibited. 5. Each worker must be provided with a comfortable mattress, pillow, cover and clean bedding. 6. Bed linen is washed frequently and applied with repellents and disinfectants where conditions warrant (malaria).
7. Facilities for the storage of personal belongings for workers are provided. Standards vary from providing an individual cupboard for each worker to providing 475 litre big lockers and 1 meter of shelf unit. 8. Separate storage for work boots and other PPE, as well as drying/airing areas may need to be provided depending on conditions.
25.3.8 Sanitary and toilet facilities
It is essential to allow workers to maintain a good standard of personal hygiene but also to prevent contamination and the spread of diseases that result from inadequate sanitary facilities. Sanitary and toilet facilities will always include all of the following: toilets, urinals, washbasins and showers. Sanitary and toilet facilities should be kept in a clean and fully working condition. Facilities should also be constructed of materials that are easily cleanable and ensure privacy. Sanitary and toilet facilities are never shared between male and female residents, except in family accommodation. Benchmarks 1. Sanitary and toilet facilities are constructed of materials that are easily cleanable. 2. Sanitary and toilet facilities are cleaned frequently and kept in working condition. 3. Sanitary and toilet facilities are designed to provide workers with adequate privacy, including ceiling to floor partitions and lockable doors. 4. Sanitary and toilet facilities are not shared between men and women, except in family accommodation.
25.3.9 Toilet facilities
Toilet arrangements are essential to avoid any contamination and prevent the spread of infectious disease.
Benchmarks 1. An adequate number of toilets are provided to workers. Standards range from 1 unit to each 15 persons to 1 unit per 6 workers. For urinals, usual standards are 1 unit to each 15 persons. 2. Toilet facilities are conveniently located and easily accessible. Standards range from 30 to 60 meters from rooms/dormitories. Toilet rooms shall be located so as to be accessible without any individual passing through any sleeping room. In addition, all toilet rooms should be well lighted, have good ventilation or external windows, have sufficient hand wash basins and be conveniently located. Toilets and other sanitary facilities should be (“must be” in cold climates) in the same building as rooms and dormitories.
25.3.10 Showers/bathrooms and other sanitary facilities
Hand washbasins and showers should be provided in conjunction with rooms/dormitories. These facilities must be kept in good working condition and cleaned frequently. Flooring in shower facilities should be of hard washable materials, impervious to damp and properly drained. Adequate space must be provided for hanging, drying and airing clothes. Suitable light, ventilation and soap should be provided. Finally hand washing, shower and other sanitary
facilities should be located within a reasonable distance from other facilities and from sleeping facilities in particular.
Benchmarks 1. Showers/bathroom flooring is made of anti-‐slippery hard washable materials. 2. An adequate number of hand wash facilities are provided to workers. Standards range from 1 unit to each 15 persons to 1 unit per 6 workers. Hand wash facilities should consist of a tap and a basin, soap and hygienic means of drying hands. 3. An adequate number of shower/bathroom facilities are provided to workers. Standards range from 1 unit to each 15 persons to 1 unit per 6 workers. 4. Showers/bathrooms are conveniently located. 5. Shower/bathroom facilities are provided with an adequate supply of cold and hot running water.
25.3.11 Canteen, cooking and laundry facilities
Good standards of hygiene in canteen/dining halls and cooking facilities are crucial. Adequate canteen, cooking and laundry facilities and equipments should also be provided. When caterers are contracted to manage kitchen and canteens, special attention should be paid to ensure that the following requirements are taking into account and implemented. To this end, adequate reporting/monitoring mechanisms should be implemented. When workers can individually cook their meals, they should be provided with dedicated space outside of the sleeping compounds. Facilities must be kept in a clean and sanitary condition. In addition, canteen, kitchen, cooking and laundry floor, ceiling and wall should be made of easily cleanable material.
Benchmarks 1. Canteen, cooking and laundry facilities are built in adequate and easy to clean materials. 2. Canteen, cooking and laundry facilities are kept in clean and sanitary condition.
25.3.12 Laundry facilities
Providing facilities for workers to wash work and non-‐work related clothes is essential for personal hygiene. The alternative is for the employer to provide a free laundry service.
Benchmarks 1. Adequate facilities for washing and drying clothes are provided. Standards range from providing sinks or tubs with hot and cold water, cleaning soap and drying lines to providing washing machine and dryers.
25.3.13 Canteen and cooking facilities
Canteen and cooking facilities should provide sufficient space for preparing food and eating, as well as conforming to safety requirements.
Benchmarks 1. Canteens have a reasonable amount of space per worker. Standards range from 1 square meter to 1.5 square meter. 2. Canteens are adequately furnished. Standards range from providing tables, benches, individual drinking cups and plates to providing special drinking fountains.
3. Places for food preparation are adequately ventilated and equipped. Standard range from providing burners to providing extractor hoods, stoves, refrigerators, freezers, boiling water, stainless steel sink for dishwashing. 4. All kitchens floor, ceiling and wall surfaces adjacent to or above food preparation and cooking areas are built in non-‐absorbent, easily cleanable materials. 5. Wall surfaces adjacent to cooking areas are made of fire-‐resistant materials. Food preparation tables are also equipped with a smooth impervious washable surface. Finally, in order to enable easy cleaning, it is good practice that stoves are not sealed against a wall; benches and fixtures not built into the floor, and all cupboards and other fixtures and all walls and ceilings have a smooth impervious washable surface.
25.3.14 Standards for food safety
When cooking for a number of workers, food safety is absolutely critical. In addition to providing safe food, providing decent food is important as it has a very direct impact on workers’ productivity. An ILO study demonstrates that good nutrition at work leads to gains in productivity and worker morale, prevention of accidents and premature deaths and reductions in health-‐care costs4.
Benchmarks 1. The WHO 5 keys to safer food or an equivalent process is implemented (see box 6 below) 2. Food provided to workers contains an appropriate level of nutritional value. It is also good practice that food catering and preparation take into account religious background and that meals are prepared by nutritionists. It is also best practice that different choices of food are served taking into consideration cultural and religious background.
25.3.15 Medical facilities
Access to adequate medical facilities is important to maintain workers’ health and to provide adequate responses in case of health emergency situations. The availability or level of medical facilities provided in worker accommodation is likely to depend of the number of workers living onsite and of the medical facilities already existing in the neighbouring communities. However, first aid must always be available on site.
25.3.16 First aid facilities
Providing adequate first aid can save lives and prevent minor injuries becoming major ones.
25.3.17 Other medical facilities
Depending on the number of workers living onsite and the medical services offered in the surrounding communities, it is important to provide workers with additional medical facilities. Special facilities for sick workers and medical services such as dental care, surgery, emergency room can also be provided.
4 ILO -‐ C. Wanjek, Food at Work – Workplace solutions for malnutrition, obesity and chronic disease, 2005.
Benchmarks 1. An adequate number of first aid kits are available. 2. First aid kits are adequately stocked. Where possible a 24/7 first aid service/facilities is available. 3. An adequate number of staff/workers are trained to provide first aid. 4. Where possible and depending on the medical infrastructures existing in the community, other medical facilities are provided (nurse rooms, dental care, small surgery)
25.3.18 Leisure, social and telecommunication facilities
Basic leisure and social facilities are important for workers to rest and also to socialise during their free time. This is particularly true where workers’ accommodation is located in remote areas far from any communities. Where worker accommodation is located in the vicinity of a village or a town, existing leisure or social facilities can be used so long as this does not cause disruption. But in any case, social spaces should also be provided onsite. Exercise and recreational facilities will increase workers’ welfare and reduce the impact of the presence of workers in the surrounding communities. In addition it is also important to provide workers with adequate means to communicate with the outside world, especially when worker accommodation is located in remote location or where workers live on site without their family or are migrants. Consideration of cultural attitudes is important. Provision of space for religious observance needs to be considered taking cognisance of the local context and potential conflicts in certain situations.
25.3.19 Leisure and social facilities
Worker accommodation is a place where workers are expected to eat and sleep but also to spend part of their free time. This is particularly true where worker accommodation is located in remote areas far from any communities. Where worker accommodation are located in the vicinity of a village or a town, the use of the existing leisure or social facilities can be recommended if it does not cause major disruption to the normal functioning of those facilities nor to the possibility for community members to enjoy the use of those facilities. In any cases, it is important that enough social spaces are also provided on site.
Benchmarks 1. Basic collective social/rest spaces are provided to workers. Standards range from providing workers multi-‐purpose halls to providing designated area for radio, TV, Cinema. 2. Recreational facilities are provided. Standard range from providing exercise equipment to providing library, swimming pool, tennis courts, table tennis, educational facilities. 3. Workers are provided with dedicated places for religious observance if the context warrants.
25.3.20 Telecommunication facilities
Workers must be given access to communication means.
Benchmarks 1. Workers have access to public phones at affordable/public prices (i.e. not inflated). 2. Internet facilities can also be provided, particularly where large numbers of expatriates / TCNs are accommodated.
25.4 Managing workers’ accommodation
Once facilities have been constructed and are operational, effective ongoing management of living facilities is essential. This encompasses issues such as the physical maintenance of buildings, security and consultation with residents and neighbouring communities in order to ensure the implementation of the housing standards on the long term. 25.4.1 Management and staff
Housing facilities should have a written management plan, including management policies or plans on health and safety, security, living conditions, workers rights and representation, and relationships with the communities. The quality of the staff managing and working at the accommodation facilities will have a decisive impact on the level of standards which are implemented and the well-‐being of workers (for instance on the food safety or overall hygiene standards). It is therefore important to ensure that managers are competent and other workers are adequately skilled. The manager will be responsible for overseeing staff, for ensuring the implementation of the accommodation standards and for the implementation of the management plans. It is important the accommodation manager has the corresponding authority to do so. If the facility is being managed by a contractor, as is often the case, the expected housing and management standards should be specified in the relevant contract, and mechanisms to ensure that those standards are implemented should be set up. As part of this process, the accommodation manager (or contractor) should have a duty to monitor the application of the accommodation standards and to report frequently on their implementation to the client. Benchmarks 1. There are management plans and policies especially in the field of health and safety (with emergency responses), security, workers rights, relationships with the communities. 2. An appointed person with the adequate background and experience is in charge of managing the workers’ accommodation. 3. If contractors are being used, there are clear contractual management responsibilities and reporting requirements. 4. Depending on the size of the accommodation, there is a sufficient number of staff in charge of cleaning, cooking and of general maintenance. 5. Such staff are recruited from the local communities. 6. Staff have received basic health and safety training. 7. Persons in charge of the kitchen are trained in nutrition and food-‐handling and adequately supervised.
25.4.2 Charging fees for accommodation and services
Charging fees for the accommodation or the services provided to workers such as food or transport should be avoided where workers do not have the choice to live or eat anywhere else, or if deemed unavoidable take into account the specific nature of worker accommodation. Any charges should be transparent, discussed during recruitment and specified in workers’ contracts.
Any such charges should still leave workers with sufficient income and should never lead to a worker becoming indebted to an employer.
Benchmarks 1. When fees are charged, the renting arrangements are fair and do not cost the worker more than a reasonable proportion of income and never include a speculative profit. 2. Food and other services are free or are reasonably priced, never above the local market price. 3. The provision of accommodation or other services by employers as a payment for work is prohibited.
25.4.3 Health and safety on site
The company or body in charge of managing the workers’ accommodation should have the prime responsibility for ensuring workers’ physical well-‐being and integrity. This involves making sure that the facilities are kept in good condition (ensuring that sanitary standards or fire regulations are respected for instance), and that adequate health and safety plans and standards are designed and implemented.
Benchmarks 1. Health and safety management plans including, electrical, mechanical, structural and food safety have been carefully designed and are implemented. 2. The person in charge of managing the accommodation has a specific duty to report to the health authorities the eruption of any contagious diseases, food poisoning and other important casualties. 3. An adequate number of staff/workers is trained to provide first aid. 4. A specific fire safety plan is prepared, including training of fire wardens, periodic testing and monitoring of fire safety equipment and periodic drills. 5. Guidance on the detrimental effects of the abuse of alcohol and drugs and other potentially harmful substances, and the risk and concerns relating to HIV/AIDS and of other health risk related activities is provided to workers. It is best practice to develop a clear policy on this issue. 6. Workers have an easy access to medical facilities. 7. Emergency plans on health and fire safety are prepared. Depending on the local context, additional emergency plans are prepared as needed to handle specific occurrences (earthquakes, floods, tornadoes).
25.4.4 Security on workers’ accommodation
Ensuring the security of workers and their property on the accommodation site is of a key importance. To this end, a security plan must be carefully designed including policies regarding the use of force (force can only be used for preventive and defensive purposes in proportion to the nature and the extent of the threat). To implement this plan, it may be necessary to contract security services or to recruit one or several staff whose main responsibility is to provide security, to safeguard workers and property. Before making any security arrangements, it is necessary to assess the risks of such arrangements to those within and outside the workers’ accommodation and to respect best international practices and applicable law5. Particular attention should be paid to women workers safety and security.
5 See for instance the Voluntary Principles on Security and Human Rights. www.voluntaryprinciples.org/principles
Benchmarks 1. A security plan including clear policies on the use of force has been carefully designed and is implemented. 2. Security staff have been checked to ensure that they have not been implicated in any previous crimes or abuses. 3. Security staff have received clear instruction about their duty and responsibility. 4. Security staff have received an adequate training in the use of force. 5. Security staff have a good understanding about the importance of respecting workers’ rights and the rights of the communities and adopt an appropriate conduct. 6. Security staff adopt an appropriate conducts towards workers and communities. 7. Workers and members of the surrounding communities have specific means to raise concern about security arrangement and staff.
25.4.5 Workers rights, rules and regulations on workers’ accommodation
Freedoms and human rights of workers should be recognised and respected within their living quarters just as within the working environment. House rules and regulations should be reasonable and non discriminatory and should not prevent workers from exercising their basic rights. In particular, workers’ freedom of movement needs to be preserved if they are not to become effectively “trapped”. To this end it is good practice to provide workers with a 24/7 access to the accommodation and free transport services to and from the surrounding communities. Any restriction to this freedom of movement should be limited and duly justified Penalties for breaking the rules should be proportional and implemented through a proper procedure allowing workers to defend themselves and to contest the decision taken. The relationship between continuing employment and compliance with the rules of the worker accommodation should be clear and particular attention should be paid to ensure that housing rules do not create indirect limitation of the right to freedom of association. Best practice might include a code of conduct relating to the accommodation to be signed together with the contract of employment.
Benchmarks 1. Restriction to workers freedom of movement to and from the site is limited and duly justified. It is good practice to provide workers to 24/7 access to the accommodation site. Any restrictions based on security reasons should be balanced by the necessity to respect workers’ freedom of movement. 2. Where possible, an adequate transport system to surrounding communities is provided. It is good practice to provide workers with free transportation to and from local communities. 3. Withholding workers ID papers is prohibited. 4. Freedom of association is expressly respected. Provisions restricting workers’ rights on site should take into account the direct and indirect effect on workers’ freedom of association. 5. Workers’ religious, cultural and social background is respected. In particular, workers should be provided with the possibility to celebrate religious holidays and observances. 6. Workers are made aware of their rights and obligations and are provided with a copy of the internal worker accommodation rules, procedures and sanction mechanisms in a language or through a media they understand. 7. Non-‐discriminatory house regulations are strictly limited to the rules which are necessary to ensure the smooth running of the worker camp and to maintain good relationship with the surrounding communities. 8. Decisions should be made on whether to prohibit alcohol, tobacco
and third parties access or not on the camp and the rules relating to these should be clearly communicated to all residents and workers. 9. A fair and non-‐discriminatory procedure exists to implement disciplinary procedures including the right for workers to defend themselves (see also next section).
25.4.6 Consultation and grievance mechanisms
All residents should be made aware of any rules governing the accommodation and the consequences of breaking such rules. Processes that allow for consultation between site management and the resident workers will assist in the smooth running of an accommodation site. These may include a dormitory or camp committee as well as formal processes that allow workers to lodge any grievances about their accommodation.
Benchmarks 1. Mechanisms for workers’ consultation have been designed and implemented. 2. Processes and mechanisms for workers to articulate their grievances are provided to workers. 3. In case conflicts between workers or between workers and staff break out, workers have the possibility to easily access a fair conflict resolution mechanism. 4. In cases where more serious offences occur, there are mechanisms to ensure full cooperation with the police authority (where adequate).
25.4.7 Management of community relations
Workers’ living facilities have various ongoing impacts on adjacent communities. In order to manage these, it is good practice to design a thorough community relations management plan. This plan will contain the processes to implement the findings of the preliminary community impact assessment and to identify, manage, mitigate or enhance ongoing impacts of the workers’ accommodation on the surrounding communities. Issues to be taken into consideration include:
• Community development – impact of workers camp on local employment, possibility to enhance local employment and income generation through local sourcing of goods and services;
• Community needs – ways to identify and address community needs related to the arrival of specific infrastructures such as telecommunication, water sanitation, roads, health care, education, housing;
• Community health and safety – addressing and reducing the risk in the increased in communicable diseases, corruption, trade in illegal substance such as drugs, alcohol (in the Muslim context), petty crimes and other sort of violence, road accidents; and
• Community social and cultural cohesion – ways to mitigate the impact of the presence of large numbers of foreign workers, often males, with different cultural and religious background, ways to mitigate the possible shift in social, economic and political structures due to changes in access to income generation opportunities.
Benchmarks 1. Community relations plans addressing issues around community development, community needs, community health and safety and community social and cultural cohesion have been designed and implemented.
2. Community relations plans include the setting up of a liaison mechanism allowing an exchange of information and consultation with the local communities in order to identify and respond quickly to any problems and maintain good working relationships. 3. A senior manager is in charge of implementing the community relations management plan and liaising with the community 5. The impacts of workers’ accommodation on local communities are periodically reviewed, mitigated or enhanced. 6. Community representatives are provided with easy means to voice their opinions and to lodge complaints.
25.5 ANNEX I: CHECK LIST ON WORKERS’ ACCOMMODATION
1 Question Y N Comments
General regulatory framework
Have the international / national / local regulatory frameworks been reviewed?
Are identified mandatory provisions on workers’ accommodation identified?
Standards for workers’ accommodation
National/local standards
Have the relevant national/local regulations been identified and implemented?
General living facilities
Is the location of the facilities designed to avoid flooding or other natural hazards?
Is workers’ accommodation located within a reasonable distance from the worksite?
Is transport provided to worksite safe and free?
Are the living facilities built in adequate material, kept in good repair and maintained clean and free from rubbish and other refuse?
Drainage
Is the site adequately drained?
Heating, air conditioning, ventilation and light
Depending on climate are living facilities provided with adequate heating, ventilation, air conditioning and light systems?
Water
Do workers have easy access to a supply of clean/potable water in adequate quantities?
Does the quality of the water comply with the national / local requirements or WHO standards?
Are tanks used for the storage of drinking water constructed and covered as to prevent water stored therein from becoming polluted or contaminated?
Waste water and solid waste
Are waste water, sewage, food and any other waste materials adequately discharged in compliance local or World Bank standards and without causing any significant impacts on camp residents, the environment and the surrounding communities?
Are specific containers for rubbish collection provided and emptied on a regular basis?
Are pest extermination, vector control and disinfection carried out throughout the living facilities?
Rooms/dormitories facilities
Are the rooms/dormitories kept in a clean and good condition?
Are the rooms/dormitories aired and cleaned at regular intervals?
Are the rooms/dormitories built in easily cleanable flooring material?
Are the rooms / dormitories and sanitary facilities located in the same buildings?
Are residents provided with enough space?
Is the ceiling height high enough?
Is the number of workers sharing the same room/dormitory minimised?
Are the doors and windows lockable and provided with mosquito nets when necessary?
Are mobile partitions or curtains provided?
Are suitable furniture such as table, chair, mirror, bedside light provided for every worker?
Are separate sleeping area provided for men and women?
Bed arrangements and storage facilities
Is there a separate bed provided for every worker?
Is the practice of “hot-‐bedding” prohibited?
Is there a minimum space of 1 meter between beds?
Is the use of double deck bunks minimised?
When double deck bunks are in use, is there enough clear space between the lower and upper bunk of the bed?
Are triple deck bunks prohibited?
Are workers provided with comfortable mattresses, pillows and cleaned bed linens?
Are the bed linen washed frequently and applied with adequate repellents and disinfectants (where conditions warrant)?
Are adequate facilities for the storage of personal belongings
provides? Are there separate storages for work clothes and PPE and
depending on condition, drying/airing areas?
Sanitary and toilet facilities
Are sanitary and toilet facilities constructed of materials that are easily cleanable?
Are sanitary and toilet facilities cleaned frequently and kept in working condition?
Are toilets, showers/bathrooms and other sanitary facilities designed to provide workers with adequate privacy including ceiling to floor partition and lockable doors?
Are separate sanitary and toilet facilities provided for men and women?
Toilet facilities
Is there an adequate number of toilets and urinals?
Are toilets facilities conveniently located and easily accessible?
Showers/bathrooms and other sanitary facilities
Is the shower facilities flooring made of anti-‐slippery hard washable materials?
Is there an adequate number of hand wash basins and showers / bathrooms facilities provided?
Are the sanitary facilities conveniently located?
Are shower facilities provided with adequate supply of cold and hot running water?
Canteen, cooking and laundry facilities
Are canteen, cooking and laundry facilities built in adequate and easy to clean materials?
Are the canteen, cooking and laundry facilities kept in clean and sanitary condition?
Laundry facilities Are adequate facilities for washing and drying clothes provided?
Canteen and cooking facilities
Are workers provided with enough space in the canteen?
Are canteen adequately furnished?
Are places for food preparation and adequately ventilated and equipped??
Are kitchen floor, ceiling and wall surfaces adjacent to or above food preparation and cooking areas built in non-‐absorbent, easily
cleanable materials? Are wall surfaces adjacent to cooking areas made of fire resistant
materials and food preparation tables equipped with smooth imperious washable surface?
Standards for food safety
Is there a special sanitary process such as the WHO “5 keys to safer food” implemented in relation to food safety?
Is the food provided contains appropriate nutritional value? Medical facilities
Are first aid kits provided in adequate numbers?
Are first-‐aid kits adequately stocked?
Is there an adequate number of staff/workers trained to provide first-‐aid?
Are there any other medical facilities/services provided on site? If not why?
Leisure, social and telecommunication facilities
Are basic social collective spaces and adequate recreational areas provided to workers?
Are workers provided with dedicated places for religious observance?
Can workers access a telephone at affordable/public price?
Are workers provided with access to internet facilities?
Managing workers’ accommodation
Management and staff
Are there carefully designed a worker camp management plans and policies especially in the field of health and safety (including emergency responses), security, workers’ rights and relationships with the communities?
Where contractors are used, have they clear contractual management responsibilities and duty to report?
Does the person appointed to manage the accommodation has the required background, competency and experience to conduct his mission and is he/she provided with the adequate responsibility and authority to do so?
Is there enough staff to ensure the adequate implementation of housing standards (cleaning, cooking and security in particular)?
Are staff members recruited from surrounding communities?
Have the staff received basic health and safety training?
Are the persons in charge of the kitchen particularly trained in nutrition and food-‐handling and adequately supervised?
Charging fees for accommodation and services Are the renting arrangements fair?
Are food and other services provided for free or reasonably priced below the local market price?
Is the payment in kind for accommodation and services prohibited?
Health and safety on site
Have health and safety management plans including electrical, mechanical, structural and food safety been designed and implemented?
Has the accommodation manager a duty to report to the health authority specific diseases, food poisoning or causalities?
Is there an adequate number of staff/workers trained in providing first aid?
Has a specific and adequate fire safety management plan been designed and implemented?
Are guidance on alcohol, drug and HIV/AID and other health risk related activities provided to workers?
Do workers have an easy access to medical facilities?
Have emergency plans on health and fire safety been prepared?
Depending on circumstances, have specific emergency plans (earthquakes, floods, tornadoes) been prepared?
Security on workers’ accommodation
Has a security plan including clear provisions on the use of force been designed and implemented?
Have security staff background been checked against previous crimes or abuses?
Have security staff received clear instruction about their duty and responsibility?
Have security staff been adequately trained in the use of force?
Do security staff have a good understanding about the importance of respecting workers’ rights and the rights of the surrounding communities and adopt an appropriate conduct?
Do workers and communities have specific means to raise
concern about security arrangement and staff? Workers rights, rules and regulations on workers’
accommodation
Are limitations on workers’ freedom of movement limited and justified?
Is an adequate transport system to the surrounding communities provided?
Is the practice of withholding workers ID papers prohibited?
Is freedom of association expressly respected?
Are workers religious, cultural and social backgrounds respected?
Are workers made aware of their rights and obligations and provided with a copy of the accommodations internal rules, procedures and sanction mechanisms in a language or through a media they understand?
Are house regulations non discriminatory, fair and reasonable?
Are regulations on alcohol, tobacco and third parties access to the camp clear and communicated to workers?
Is a fair and non-‐discriminatory procedure to implement disciplinary procedures including the right for workers to defend themselves set up?
Consultation and grievance mechanisms
Have mechanisms for workers’ consultation been designed and implemented?
Are workers provided with adequate processes and mechanisms to articulate their grievances?
Are there fair conflict resolution mechanisms in place?
In case where serious offences occur, are there mechanisms to ensure full cooperation with police authorities?
Management of community relations
Have community relation management plans addressing issues around community development, community needs, community health and safety and community social and cultural cohesion have been designed and implemented?
Do community relation management plans include the setting up of liaison mechanisms allowing a constant exchange of information and consultation of the surrounding communities?
Is there a senior manager in charge of implementing the community relation management plan?
Is there a senior manager in charge of liaising with the surrounding communities?
Are the impacts generated by workers accommodation periodically reviewed, mitigated or enhanced?
Are community representatives provided with easy means to voice their opinions and lodge complaints?
26 Quality Management Overview
26.1 Introduction
The EICC Validated Audit Process (VAP) provides the highest quality information gathering and analysis of working conditions at a facility within the industry. In order to ensure this consistent level of quality the EICC has implemented the following key components of its VAP program:
• Independent selection and allocation of third party qualified Audit firms and overall quality review through an expert APM with consistent governance of the EICC Code of Conduct Audit guidance
• Independent performance review of each Audit firm and qualified/certified Auditor within the EICC VA process
• Assurance of sufficient time on site, with a minimum of 2 Auditors to ensure the integrity and depth of information gathering
• Optimized scope of coverage for seamless sharing of the resulting VA report to multiple site customers at the Auditee’s discretion
• Recognized EICC Labor & Ethics certification program for lead Auditors • Independent management of the Validated Audit Process Corrective Action program • Commitment to quality and continuous improvement per the Service Level and Quality
Statement • Expert helpdesk on working conditions, EICC Code of Conduct and its provisions available to
Auditees, Auditors (throughout the entire process) and EICC members
26.2 Definitions
Term Definition
Priority Nonconformance
A major Nonconformance with significant and immediate impact. These are predefined such as the presence of child labor in a facility. If a Priority Issue is found, the Auditor must report this immediately to facility management and to the EICC APM. Other Priority issues include: forced labor, health and safety issues that can cause immediate danger to life or serious injury, and environmental issues that can result in serious and immediate harm to the community. Priority non conformances are indicated in the EICC Audit Protocol (light red color in the question field)
Major Nonconformance
A significant failure in the management system – one that affects the ability of the system to produce the desired results. It may also be caused by failure to implement an established process or procedure or if the process or procedure is totally ineffective. For example, the failure of an
organization to verify its compliance to applicable laws and regulations is a Major Non conformance.
Minor Nonconformance
A minor Nonconformance by itself doesn’t indicate a systemic problem with the management system. It is typically an isolated or random incident. Examples are: an internal Audit with an overdue corrective action request pending, or a procedure that has not been revised to reflect a change in regulations.
Risk of Nonconformance
An observation is used in several situations: • When there is insufficient evidence to conclusively
determine conformance or Nonconformance. An example of this would be when worker interview information contradicts program documentation and records, but it cannot be determined whether the records have been falsified or the workers have been coached to answer in a certain way.
• When evaluating working hours, an insufficient number of workers in a sample are found to exceed the EICC 60-‐hour working hours limit or the applicable legal limit.
• If the condition or practice is in conformance with the requirement, but in the Auditors' judgment, it could deteriorate to a Nonconformance without some additional action or effort on the part of facility management.
N/A
The question is not applicable to the entire Audited facility and to each specific part of the facility. N/A responses should be minimized and replaced by as many observations as possible.
26.3 Allocation of Audit Firms
The APM, an expert qualified third party without competing Auditing business assigns a qualified Audit firm and Auditors to each Audit. The qualification process of the Audit firm is a detailed review of the Audit firms capacity and capability to deliver high quality third party Audits in line with ISO 19011and all applicable legal requirements and international good practice on workplace Auditing. Some of the criteria reviewed during the selection process are:
• Selection process of Auditors • Capacity in country • Experience in the electronics sector • Internal quality management processes
• Integrity and allegation investigation processes • Auditor training and current knowledge processes
The review process is managed by the EICC APM and approved by the board of the EICC. For each Validated Audit (VA) individual qualified/certified Auditors are selected from an available list by the APM. This selection is based on availability, expertise level as required by the risk level of the Auditee (e.g. high EHS risk requires higher level Auditor expertise). The qualification process evaluates the following criteria for each individual Auditor: Formal education degrees
• Auditor's accreditation (e.g. IRCA, RAB-‐QSA, ....) • Skills in interview and group dynamics • Skills in Labor and Employment • Skills in Business Ethics • Skills in Occupational Health and Safety • Skills in Environment • Skills in Management Systems • Skills in Root Cause Analysis (including Corrective and Preventive Action) • External training (last 3 years) • Audits participated in over last three years • Languages spoken
For lead Auditors an IRCA certification specifically for the electronics Industry (designed in collaboration with EICC and IRCA) is required (in transition)
26.4 Allocation of Time on Site
In most Audits Auditors spend limited time on site. It has been proven that time on site is critical to the level of depth, understanding and quality of information Auditors receive, enabling them to make accurate professional conclusions on the level of conformance of a site against the EICC Code of Conduct provisions, laws and regulations. Many research projects and civil society organization advocate for more time on site as compared to the regular “risk assessment” type Audit. EICC in its effort to ensure quality of its VAP and in line with its objective to improve the conditions with the supply chain of its members have integrated adequate time on site into its VA process. The time allocation of a minimum of two Auditors for each Audit is allocated as follows:
The Audit will most commonly be a four to six person-‐day event depending on the size and complexity of the facility. The size of the Audit team and number of Audit days will depend on a number of factors such as:
• Physical size of the facility, • Number of workers, • Process complexity, • Results of the facility self-‐assessment, and
• Type of Audit (e.g. initial vs. follow-‐up)
• The Audit scope (size of the team and duration of the Audit) will be determined jointly between the Audit firm and the EICC APM on a case-‐by-‐case basis, using the facility profile information obtained through the Self-‐Assessment Questionnaire, and other pertinent information about the site.
The process uses the following reference as guidance to on-‐site Audit time allocation:
Complexity of operations within the scope of the Audit.
Criteria: dormitory, significant chemical operations, intensive physical handling, complex manufacturing operations, canteen, special operations, ....
Size -‐ number of workers at a facility
< 1000 1000-‐5000 > 5000
Low – no listed complexity criteria
2 person days
4 person days
8 person days
Medium – 2 listed complexity criteria
4 person days
6 person days
10 person days
High – 3 or more listed complexity criteria
8 person days
12 person days
26.5 Validated Audit report review process
Each Validated Audit Report (VAR) is reviewed by the APM both at draft and at final stage before release. The quality assurance process consists of the following:
• Review of scope and application (assurance Audit covered entire site and all operation) • Review of confidentiality (assurance no product, customer, other info which needs removal
to ensure compliance with applicable legal requirements such as anti-‐trust/anti-‐competition, fair business, foreign corrupt practice, ....)
• 2 independent reviews of the report against o Format o Good reporting criteria o EICC code and provision o Good Auditing practices (including review of submitted Auditor notes and
supporting evidence) o Applicable legislation
26.6 Performance Review
The EICC has institutionalized a process for both process improvement but also performance management of the qualified Audit firms and qualified/certified Auditors. The allocation of an Audit to a qualified Audit firm and individual Auditors is a balance between availability, price and performance (at the Audit firm and individual Auditor level). The performance management consists of the following components
o Feedback surveys o Auditee o Observer
o Shadow Audits by APM o Complaint process o VAP “process” performance: § Onsite performance -‐ 20% (Auditor) § Feedback Surveys § Timeliness to process deadlines -‐ 15%
all requirements minus points for non conformance on good reporting guidance per incident – see below)
§ 2/3 performance on final report (100 points = all requirements minus points for non conformance on good reporting guidance per incident – see below)
§ Response to complaint/allegation -‐ 25% (Auditor / Audit firm)
§ 100 points on agreed timely corrective action plan closure
The EICC APM has monthly phone calls with the qualified Audit forms to ensure performance improvements are discussed and agreed to. The EICC performance governance process is in place to ensure that only performing Auditors and Audit firms are use in the VAP. The performance governance process consists of:
§ First – written notice; 3-‐month improvement plan § Second – written warning; 3-‐month improvement plan; shadow Audit by APM (paid by Audit
A re-‐qualification is possible through a successful and full re-‐ application/re-‐certification to the process as an Audit firm.
26.7 Good Reporting Criteria for a Validated Audit Report (VAR)
Based on good Auditing principles, ISO guidance on good reporting and good reporting practice across sectors (e.g. GMP in the pharmaceutical industry), the following good reporting criteria are used: § Relevance (3 performance points) § Content (1 performance point) § Language (0.5 performance points) § Format (0.25 performance points)
25.7.1 Relevance (3 performance points)
€ Ensure the conclusion is relevant to the question
o E.g. when asked if management verifies workers understanding on labor and Ethics – this is not a suggestion box for feedback. It is a test, survey, interview, or other method on knowledge verification.
€ Justification needs to be given why a rating is changed up (increased risk) or down (decreased risk) from the EICC VAP default rating (please note that final approval of rating change is done by VAP APM upon review of risk assessment provided). This justification takes the form of a detailed risk assessment including at least o Hazard o Likelihood of occurrence o Impact
§ The following supplier Risk factors to consider are when changing a rating from the default rating:
• Health and Safety risk to workers • Health and Safety risk to community • Adverse product safety impact • Restriction in workers’ rights • Violation of local law • Reputation risk/Operational risk • Short or medium term environmental risk
€ Inaccurate rating
25.7.2 Content (1 performance point)
€ Indicate the period for which documents / records and documents / records were
reviewed € Data points need to describe process used by Auditors if different than standard
process references used and result o e.g. the age of workers was identified by using the website xxxx, 23 workers ID info
selected and verified against the info the website (official government information is referenced) the result is 20 showed birth year accurate and over 16 3 showed birth year inaccurate and under 18
€ Worker interview composition should be stated for each relevant question o e.g. as of the XXX workers -‐ YYY confirmed ZZZZ by stating " AAAAA"
€ Auditee documents should list the title, date and other references and ideally a quote from the document to prove relevance to the question and conformance status
€ Ensure any service provider for the last three years is listed in either certification or consultancy sections. This includes o Certifications received o Consultancy received or service provided such as testing services o Audits/assessments conducted
€ Do state if there is a legal violation
o Need legal reference – title of law, article, year of issue and quote from law specific to non conformance
o State and quote legal reference wherever they exist and what the conformance gap is
§ e.g. labor law XXX of date art YYY "zzz" current practice "AAAA" does not conform in the following points CCCCC
€ Supporting evidence is related to the question € Do NOT repeat the data points or the reference information in the conclusion € The conclusion is NOT a sentence which repeats the same info as the question but a
summary of the gap in conformance or a statement based on data points why the Auditee is in conformance
€ Ensure documented evidence (copies/pictures of) is taken during the Audit and is attached as supporting evidence and submitted with the VAR (draft and final)
€ Ensure Auditor notes are submitted with the draft VAR € Ensure Closing meeting and daily wrap up templates are completed and submitted
within 48h of close meeting € Ensure daily wrap up is submitted at the end of day when a Priority non conformance
is identified and discussed with the Auditee € Facility description should be completed and include a lay out in supporting evidence
€ Ensure that information included in the report cannot identify o A customer o Specific product or any proprietary information o An individual who is not part of the management team or a section head
€ When a question refers to a person then always verify if the person is competent,
trained and state how this was verified € When a question refers to testing or control, then always state
o What tests were done o If the person/company was competent, licensed, authorized o What the results were o Trends and what action result from these o This applies to Audit questions, control questions, drill questions, testing questions
€ When a question or response mentions training then always state
o What training o Who was trained o If trainer was competent o What the results of the training were o If the training was effective (can trainees explain and implement what they were
trained on) how the Auditor verified this
€ Data points from the same (or non-‐independent) source of information should be combined together under 1 data point.
26.7.3 Language (0.5 performance points)
€ Data points cannot have opinion subjective statements or judgment. Only facts and neutral info
€ Language use is present or current tense not past tense as the data reflects what happened on the day of the Audit
€ Do not assume a reader of the VAR is familiar with a country o State local words or term used (even in local characters) o English term and o Definition or explanation
€ All information is triangulated (3 independent data point proving a finding). This is true
for both conformance and non conformance € Refrain from the use of abbreviations where possible.
o If the abbreviation is used frequently then provide explanation when first used in the document e.g. Personal Protective Equipment (PPE).
€ Refrain from stating personal opinion. o E.g. do not make statement such as: “in the Auditor's opinion the contents of the
self-‐Audit report are fine.”
26.7.4 Format (0.25 performance points) € No filler words should be used
o E.g. furthermore, it was also observed, In addition to, It was noted that “XXX” € Avoid words such as “etc.” – as the lists need to be complete € Do not state if in violation of the EICC Code of Conduct for a question, as this is obvious
from the rating € Supporting evidence is all of the documents submitted to the EICC APM with a
reference that allows easy retrieving of the evidence o Name Auditee -‐ sequential number or name Auditee -‐ date Audit -‐ sequential
number € Spell check and grammar check (running the EICC VAP Audit Protocol macro) € Do not leave any fields or titles blank in the report € Ensure that findings are simply a clear description of the conformance or
Nonconformance that will enable the facility to understand what needs to be improved.
€ The conclusion is no longer than 3 sentences € All information needs to fit with the maximum data and view field of the entry cell € Risk of non-‐conformance. Note this should be on an exception only basis, no report
will be accepted if Risk of non-‐conformance exceeds 3 percent of total questions € Good Practices sections, when appropriate, should be completed under the code
section -‐ nowhere else in the document o Good practice must be truly a good "uncommon" practice
€ Facility description should NOT cover information captured in other sections such as employee demographics
€ Worker attitude section should only describe the worker attitude o If workers have different attitudes by section describe each
€ Exception management section is only completed by providing a clear list of o Findings which need further investigation or no conclusion could be reached o Process component which have not been executed o Documents could not be viewed or copied/photographed as evidence o Areas of the facility that were not covered during the Validated Audit. The default
scope of an EICC Validated Audit is the entire Auditee site or as listed in the Scope description issued by the VAP APM
o This should occur by exception only
€ Process Integrity should only be provided if an attempt was made to subvert the VA
process by the Auditee or one of its agents o All relevant information should be listed such as when the occurrence took place,
by whom, details of the interaction, details of request, Auditor response and follow up process.
o Please note that any attempt to subvert the Validated Audit process must be IMMEDIATELY reported to the EICC VAP APM
€ Executive summary section should completed and be a short standalone statement including: o Summary of Audit (scope, date, length of Audit, number of Auditors) o Exception or Integrity issues, if relevant o Summary of Priority and Major non conformances
€ Closing meeting section is completed by providing:
o A brief of how the closing meeting was conducted o Who from the management team participates in the closing meeting o How the discussion was o Any other suggestions or solutions discussed o Were Priority and Major non conformance findings accepted o Were exception management items accepted o Attitude of the Auditee during the discussion and towards these findings,
suggestions and/or solutions
€ Ensure document is delivered to the VAP Program Manager in at least Microsoft Excel 2007 Macro-‐Enabled Workbook (xlsm) format
€ Indicate clearly what source of information the data point was based on, such as o "Document review" o "Management interview" o "Worker interview" o "Observation during the factory tour"
If there is any question on the interpretation of the guidance or the question then contact the EICC VAP APM immediately by phone or email during the Audit and when writing the report
27. EICC VAP Protocol version comparison
EICC has four VAP Protocols that are applied to different Auditee sites/types:
1. Manufacturing: Protocol applies to any site of which the main activity is manufacturing, assembly, repair, chemical, significant mechanical or distribution operation AND the site has more than or equal to 500 people as total population.
2. Small and Medium Enterprise: Protocol applies to any site of which the main activity is manufacturing, assembly, repair, chemical, significant mechanical or distribution operations AND the site has less than 500 people as total population.
3. Service Provider: Protocol applies to any site of which the main activity is to provide a service such as design, tele-‐center, helpdesk, customs service agency,…. . A labor agent or labor contractor is excluded for use of this Protocol and have a special Protocol. The application of this Protocol is not limited to the minimum number of people at the site.
4. Labor Agent/Labor Contractor: Protocol applies to a service provider who provides any type of labor or staff to a site. The application of this Protocol is not limited to the minimum number of people at the site.
Some areas within the Protocol can be marked “Out of Scope”. This means that the EICC VAP auditor in most cases does not need to complete these areas within the Protocol. However if during the preparation or the on site visit it is clear that the area marked Out of Scope then the EICC VAP Auditor has an obligation to complete these Protocol areas
Manufacturing Small and Medium Enterprise
Service Provider Labor
Agent/Labor Contractor
4.0.1M 4.0.1K 4.0.1S 4.0.1L
Electronic Industry Code of Conduct
G1.1
Management demonstrates a good understanding of and commitment to the EICC Code of Conduct/requirements, has
integrated the EICC code/requirements into facility procedures and communicated this effectively to all levels of employees and
workers.
Applicable Applicable Applicable Applicable
Labor
A1 Freely Chosen Employment Forced, bonded (including debt bondage) or indentured labor; involuntary prison labor; slavery or trafficking of persons shall not to be used. This includes transporting, harboring, recruiting, transferring or receiving vulnerable persons by means of threat, force, coercion, abduction or fraud for the purpose of exploitation. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Workers must not be required to surrender any government-‐issued identification, passports, or work
permits as a condition of employment. Excessive fees are unacceptable and all fees charged to workers must be disclosed.
A1.1 Any type of forced, prison, indentured, or bonded (including debt bondage) labor is
not used Applicable Applicable Applicable Applicable
A1.2
Adequate and effective policy and procedures are established against slavery and human trafficking ensuring that any form of forced, bonded or involuntary
prison labor is not used.
Applicable Applicable Applicable Applicable
A1.3
Workers are informed in writing and in their own language prior to employment (in case of migrant workers, before they leave their home country/region) of the key employment terms and conditions via
employment letter/agreement/contract as required by law
Applicable Applicable Applicable Applicable
A1.4
Upon hiring, the workers government issued identification and personal
documentation originals are not withheld by employer/labor agent/contractor (if applicable) without formal consent.
Applicable Applicable Applicable Applicable
A1.5 Workers are free to leave their
employment upon giving reasonable notice, with no penalty.
Applicable Applicable Applicable Applicable
A1.6 Workers are not required to pay fees, deposits or debt repayments for their
A1.7 There are no unreasonable restrictions on the movement of workers and their access
to basic liberties Applicable Applicable Applicable Applicable
A1.8
All relevant labor requirements of the EICC Code/requirements are clearly
communicated to labor agents/contractors, and they are monitored/Audited to verify
conformance.
Applicable Applicable Applicable Applicable
A1.9 Recruitment practices and performance are disclosed to customers and other relevant
parties Applicable Out of Scope Applicable Applicable
A2) Child Labor Avoidance Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the health or safety of young workers.
A2.1 Workers are not below the minimum age Applicable Applicable Applicable Applicable
A2.2
An adequate and effective policy and process is established to ensure that
workers below the legal minimum working age are not hired both directly or via labor
agencies / contractors
Applicable Applicable Applicable Applicable
A2.3 Access to basic educational needs for workers below the age for compulsory
education is applied Applicable Applicable Applicable Applicable
A2.4
Workers under the age of 18 are not allowed to perform work that is likely to jeopardize the health or safety of these
young workers
Applicable Applicable Applicable Applicable
A2.5 Apprentice/intern/student worker employment policies and practices are in place
Applicable Applicable Applicable Applicable
A3) Working Hours Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in emergency or unusual situations. Workers shall be allowed at least one day off per seven-‐day week.
A3.1
Average hours worked in a workweek over the last 12 months does not exceed 60 hours or the legal limit (whichever is
stricter)
Applicable Applicable Applicable Applicable
A3.2 Workers receive at least one (1) day off per every seven (7) days
Applicable Applicable Applicable Applicable
A3.3
Adequate and effective policy and system/procedures are established to determine, record, manage and control
working hours including overtime
Applicable Applicable Applicable Applicable
A3.4 Workers are allowed legally mandated
breaks, holidays and vacation days to which they are legally entitled
Applicable Applicable Applicable Applicable
A3.5 Legal regular and overtime working hours
and facility working hours are communicated to all workers
Applicable Applicable Applicable Applicable
A3.6
Reliable time records of workers’ regular and overtime working hours on a daily, weekly and monthly basis are kept and
available
Applicable Applicable Applicable Applicable
A4) Wages and Benefits Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates. Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being
paid is to be provided in a timely manner via pay stub or similar documentation.
A4.1 Legal wages for regular and overtime hours
are correctly calculated and paid to all workers
Applicable Applicable Applicable Applicable
A4.2 Wage calculations are clearly
communicated to workers using pay stub or similar documentation
Applicable Applicable Applicable Applicable
A4.3 Social insurance scheme and other benefits as required by local law is provided to all
Deductions or withholdings are calculated correctly and submitted to the appropriate government agency within the time frame specified in the applicable local labor law
Applicable Applicable Applicable Applicable
A5) Humane Treatment There is to be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or
physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements shall be clearly defined and communicated to workers.
A5.1
No evidence of sexual harassment or abuse, corporal punishment, mental or physical coercion, verbal abuse or intimidation
exists
Applicable Applicable Applicable Applicable
A5.2
Adequate and effective policies and procedures on decent/humane working conditions and fair treatment of workers are established and communicated to all
workers
Applicable Applicable Applicable Applicable
A5.3 Disciplinary actions are recorded, consistent with the procedures and
reviewed by management Applicable Applicable Applicable Applicable
A5.4 Managers and supervisors are adequately
trained on appropriate disciplinary measures/procedures.
Applicable Applicable Applicable Applicable
A5.5 Workers are permitted time off when ill or
for maternity Applicable Applicable Applicable Applicable
A6) Non-‐Discrimination Participants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in
discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition,
workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.
A6.1
No evidence of discrimination based on grounds of race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy,
religion, political affiliation, union membership or marital status exists.
Applicable Applicable Applicable Applicable
A6.2 Adequate and effective policies that ban
discrimination and harassment are in place. Applicable Applicable Applicable Applicable
A7) Freedom of Association Open communication and direct engagement between workers and management are the most effective ways to resolve workplace
and compensation issues. The rights of workers to associate freely, join or not join labor unions, seek representation, and join workers’ councils in accordance with local laws shall be respected. Workers shall be able to openly communicate and share grievances
with management regarding working conditions and management practices without fear of reprisal, intimidation or harassment.
A7.1 Legal rights of workers for free association
are respected Applicable Applicable Applicable Applicable
A7.2
Adequate and effective communication/training to workers on their legal rights related to freedom of
association is provided
Applicable Applicable Applicable Applicable
A7.3 No evidence of unequal treatment between unionized or worker representatives and
control of labor organizations by any means (incentives or intimidation) exists.
Applicable Applicable Applicable Applicable
A7.5 Workers are informed when being
employed if automatically enrolled in union or other forms of worker representation
Applicable Applicable Applicable Applicable
A7.6 Worker representatives are democratically
elected Applicable Applicable Applicable Applicable
Health & Safety
B1) Occupational Safety Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures
(including lockout/tag out), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well maintained, personal protective equipment. Workers shall not be disciplined for raising safety
concerns.
B1.1
All required permits, licenses and test reports for occupational safety are in place and a process is implemented to ensure permits and licenses are up to date at all
times
Applicable Applicable Applicable Applicable
B1.3
Appropriate Personal Protective Equipment (PPE) is consistently and correctly used where required to control safety hazards
and worker exposure
Applicable Applicable Out of Scope Out of Scope
B2) Emergency Preparedness Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training
and drills, appropriate fire detection and suppression equipment, adequate exit facilities and recovery plans.
B2.1
All required permits, licenses and testing reports for emergency preparedness are in place and a process is implemented to
ensure permits and licenses are up to date at all times
Applicable Applicable Applicable Applicable
B2.2 Adequate and effective fire detection, alarm and suppression systems are in place.
Applicable Applicable Applicable Applicable
B2.3
All likely types of emergencies that could affect the site are identified and assessed, and adequate and effective emergency preparedness and response programs (plans/procedures) are established
Applicable Applicable Applicable Applicable
B2.4 Emergency exits, aisles and stairways are adequate in number and location, readily
accessible, and properly maintained Applicable Applicable Applicable Applicable
B2.5
All employees are provided with appropriate training/communication on fire
and other emergencies, as well as the corresponding preparedness and response
plans/procedures.
Applicable Applicable Applicable Applicable
B2.6
Adequate and effective fire and other emergency evacuation and response drills are conducted with all employees, and
records are maintained.
Applicable Applicable Applicable Applicable
B2.7 Designated emergency response personnel are provided adequate and effective PPE
and training on a regular basis Applicable Applicable Out of Scope Applicable
B3) Occupational Injury and Illness Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate
cases and implement corrective actions to eliminate their causes; and e) facilitate return of workers to work.
B3.1
All required permits, licenses and testing reports for occupational injury and illness are in place and a process is implemented to ensure permits and licenses are up to
date at all times
Applicable Applicable Applicable Applicable
B3.2
Investigations to determine root cause(s) and implement corrective/preventive
actions for work-‐related injuries/illness in the past three years are performed and
documented
Applicable Applicable Applicable Applicable
B3.3 A effective process and adequate first aiders to provide medical treatment for
injured or ill workers is in place Applicable Applicable Applicable Applicable
B3.4 Adequate first aid kits to provide medical treatment for injured or ill workers are in
place Applicable Applicable Applicable Applicable
B3.5 Workers know what to do in the event they
are injured or become ill on the job Applicable Applicable Applicable Applicable
B4) Industrial Hygiene Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. Engineering or
administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is to be protected by appropriate personal protective equipment programs.
B4.1
All required permits, licenses and testing reports for Industrial hygiene are in place and a process is implemented to ensure permits and licenses are up to date at all
times
Applicable Applicable Out of Scope Out of Scope
B4.2 Appropriate controls for worker exposures to chemical, biological and physical agents are implemented
Applicable Applicable Out of Scope Out of Scope
B5) Physically Demanding Work Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting,
prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled
B5.1
All required permits, licenses and testing reports for ergonomics are in place and a process is implemented to ensure permits and licenses are up to date at all times
Applicable Applicable Applicable Applicable
B5.2
Worker exposure to the hazards of physically demanding work is identified, assessed and controlled adequately and
effectively
Applicable Applicable Applicable Applicable
B6) Machine Safeguarding Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and
properly maintained where machinery presents an injury hazard to workers.
B6.1
All required permits, licenses and testing reports for machinery are in place and a process is implemented to ensure permits and licenses are up to date at all times
Applicable Applicable Out of Scope Applicable
B6.2 Workers operate machinery safely,
including proper use of machine safeguards and emergency stop switches
Applicable Applicable Out of Scope Applicable
B6.3 An adequate and effective machine-‐safeguarding program is implemented
Applicable Applicable Out of Scope Applicable
B7) Food, sanitation and housing Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and
eating facilities. Worker dormitories provided by the Participant or a labor agent are to be maintained clean and safe, and provided with appropriate emergency egress, hot water for bathing and showering, and adequate heat and ventilation and reasonable personal
space along with reasonable entry and exit privileges.
B7.1
All required health & safety licenses, permits, registrations and certificates
related to food, sanitation and housing are in place and an adequate and effective process is established to ensure permits and licenses are up-‐to-‐date at all times
Applicable Applicable Applicable Applicable
B7.2 Dormitories are clean, safe and well
maintained and meet international housing standards
Applicable Applicable Out of Scope Applicable
B7.3 Canteens (cafeterias) are clean, well
maintained, and managed in compliance with local health regulations
Applicable Applicable Applicable Applicable
B7.4 Food service workers have undergone appropriate food safety training.
Applicable Applicable Applicable Applicable
Environment
C1) Environmental Permits and Reporting All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept
current and their operational and reporting requirements are to be followed.
C1.1 The facility has obtained all the legally
required environmental permits, approvals, licenses and registrations.
Applicable Applicable Applicable Out of Scope
C1.2 Reporting to environmental authorities as
required by law is performed timely. Applicable Applicable Applicable Out of Scope
C2) Pollution Prevention and Resource Reduction Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying
production, maintenance and facility processes, materials substitution, conservation, recycling and re-‐using materials.
C2.1
Established adequate and effective programs, including targets, to: a)
eliminate, reduce or control pollution (emissions, discharges, wastes) and b) conserve resources (energy, water,
materials) in place.
Applicable Applicable Applicable Out of Scope
C3) Hazardous Substances Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe
handling, movement, storage, use, recycling or reuse and disposal.
C3.1
Hazardous materials including wastes are properly categorized, labeled, handled, stored, transported and disposed using
government-‐approved/licensed vendors as per local laws.
Applicable Applicable Out of Scope Out of Scope
C3.2 Workers who work with hazardous
substances are provided adequate and effective training.
Applicable Applicable Out of Scope Out of Scope
C3.3
Waste vendor(s) have been Audited to verify that waste is handled, stored and disposed of in accordance with local
regulations, permit conditions and contract requirements
Applicable Out of Scope Out of Scope Out of Scope
C4) Wastewater and Solid Waste Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be characterized,
monitored, controlled and treated as required prior to discharge or disposal.
C4.1 Solid waste is managed and disposed of in
accordance with applicable legal requirements
Applicable Applicable Applicable Out of Scope
C4.2
Effluent discharges (industrial/process wastewater, sewage and storm water) meet the discharge limits for regulated
constituents.
Applicable Applicable Applicable Out of Scope
C5) Air Emissions Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-‐products
generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge.
C5.1 Air emissions meet the discharge limits for
regulated constituents Applicable Applicable Out of Scope Out of Scope
C5.2 Environmental noise levels are within
regulatory limits Applicable Applicable Applicable Out of Scope
C6) Product Content Restrictions Participants are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific
substances, including labeling for recycling and disposal.
C6.1
An effective program is in place to meet legal and customer requirements for
product content as a formal part of their procurement and manufacturing processes including effective processes, procedures and records are in place to measure or document the chemical composition of
products.
Applicable Applicable Applicable Out of Scope
C6.2
Effective processes and procedures are in place to request and obtain relevant
chemical composition information from their suppliers, including certificates and
analytical reports
Applicable Applicable Applicable Out of Scope
Ethics
D1) Business Integrity The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero tolerance policy to
prohibit any and all forms of bribery, corruption, extortion and embezzlement (covering promising, offering, giving or accepting any bribes). All business dealings should be transparently performed and accurately reflected on Participant’s business books and records.
Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-‐corruption laws.
D1.1
Adequate and effective Code of Business Ethics or Standards of business conduct,
endorsed by senior management is established
Applicable Applicable Applicable Applicable
D1.2
All workers/employees are provided adequate and effective
communication/training on the code of ethical conduct.
Applicable Applicable Applicable Applicable
D1.3 Effective procedures to monitor ethics
performance is in place Applicable Applicable Applicable Applicable
D1.4
Business ethics/integrity procedures are communicated effectively to all
subcontractors, suppliers, business partners and relevant parties
Applicable Applicable Applicable Applicable
D1.5
An effective risk assessment process to determine vulnerabilities and prioritize corruption risks taking into account business circumstances (country of
operations, stakeholders, ...) is established
Applicable Out of Scope Applicable Applicable
D1.6
Employees who refuse to participate in bribery or facilitation payments are
supported by the business and will not suffer demotion, penalty or other adverse consequences even if this action may result
in the enterprise losing business.
Applicable Applicable Applicable Applicable
D1.7
Records of employees declaring any personal interest or conflict of interests
that may influence their judgment are kept and available
Applicable Applicable Applicable Applicable
D2) No Improper Advantage Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.
D2.1
Effective and written policy that ensures gifts to or from suppliers and customers is not excessive in cost and frequency and hospitality, expenses or promises as such that may compromise the principles of fair competition or constitute an attempt to obtain or retain business for or with, or direct business to, any person, or to
influence the course of the business or governmental decision-‐making process is
established.
Applicable Applicable Applicable Applicable
D2.2
Effective procedures for addressing its workers or agents suspected of making or accepting improper offers of payments or gifts and attempted bribery in all forms, the appropriate investigation and subsequent
sanctions are applied are in place
Applicable Applicable Applicable Applicable
D3) Disclosure of Information Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with
applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain is unacceptable.
D3.1 Business activities are reported in
accordance with local laws and regulations Applicable Applicable Applicable Applicable
D4) Intellectual Property Intellectual property rights are to be respected; transfer of technology and know-‐how is to be done in a manner that protects
intellectual property rights.
D4.1
Effective procedures to ensure the protection of intellectual property (their own and that of their customers) are established
Applicable Applicable Applicable Applicable
D5) Fair Business, Advertising and Competition Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must
be available.
D5.1
An effective program to ensure advertising statements are not false or misleading and meet fair business and advertising legal
requirements is in place
Applicable Applicable Applicable Applicable
D5.2
Effective and written policy prohibiting collusion is established and communicated
to workers, employees and business partners
Applicable Applicable Applicable Applicable
D5.3 A formal and effective process to protect
customer information is established Applicable Applicable Applicable Applicable
D6) Protection of Identity Programs that ensure the confidentiality and protection of supplier and employee whistleblowers are to be maintained.
D6.1
A way to confidentially report suspected ethical misconduct is available to workers and protects them from retaliation or other
consequences
Applicable Applicable Applicable Applicable
D6.2
A way to confidentially report suspected ethical misconduct is available to
employees of suppliers and protects them from retaliation or other consequences
Applicable Out of Scope Out of Scope Applicable
D7) Responsible Sourcing of Minerals Participants shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo or an adjoining country. Participants shall exercise due diligence on the source and chain of custody of these
minerals and make their due diligence measures available to customers upon customer request.
D7.1
A policy to reasonably assure that purchasing of the 3TG minerals does not directly or indirectly finance armed groups that are perpetrators of serious human
rights abuses in the Democratic Republic of Congo or surrounding countries with an effective procedures to establish and
monitor responsible sourcing of minerals and capable of making the due-‐diligence measures available upon request from
customers.
Applicable Applicable Applicable Applicable
D8) Privacy We are committed to protecting the reasonable privacy expectations of personal information of everyone we do business with, including suppliers, customers, consumers and employees. Comply with privacy and information security laws and regulatory
requirements when personal information is collected, stored, processed, transmitted, and shared.
D8.1 A formal and effective process to protect
privacy is established Applicable Applicable Applicable Applicable
D9) Non-‐Retaliation Participants should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.
D9.1 Effective procedures to ensure non retaliation are established and
Does the facility have credible, accredited third-‐party certified (valid) management
systems for: A) Labor (e.g. SA8000)
B) Health & Safety (e.g. OHSAS18001) C) Environment (e.g. ISO14001)
D) Ethics
Not rated Not rated Not rated Not rated
E1) Company Commitment Corporate social and environmental responsibility policy statements affirming Participant’s commitment to compliance and continual
improvement, endorsed by executive management.
E1.1
Adequate and effective policies/codes that are endorsed by executive management, covering: A) Labor B) Health & Safety C)
Environment and D) Ethics.
Applicable Applicable Applicable Applicable
E2) Management Accountability and Responsibility The Participant clearly identifies company representative[s] responsible for ensuring implementation of the management systems and
associated programs. Senior management reviews the status of the management system on a regular basis.
E2.1
Responsibilities and authorities are adequately and effectively defined and
assigned for all employees/workers (senior managers to workers) for implementation
of management systems, and for compliance with laws, regulations and
codes pertaining to: A) Labor B) Health & Safety C) Environment and D) Ethics.
Applicable Out of Scope Applicable Applicable
E2.2
An adequate and effective management review and continuous improvement
process for A) Labor, B) Health & Safety, C) Environment and D) Ethics performance and management systems is established
Applicable Applicable Applicable Applicable
E3) Legal and Customer Requirements A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of
this Code.
E3.1
An adequate and effective compliance process to monitor, identify, understand
and ensure compliance with applicable laws and regulations and customer requirements pertaining to: A) Labor B) Health & Safety C) Environment and D) Ethics is established
Applicable Applicable Applicable Applicable
E4) Risk Assessment and Risk Management Process to identify the labor practice and ethics risks associated with Participant’s operations. Determination of the relative
significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory compliance.
E4.1
An adequate and effective risk management process to identify, assess, and minimize/mitigate/control its risks in the areas of: A) Labor B) Health & Safety C)
Environment and D) Ethics is in place
Applicable Applicable Applicable Applicable
E5) Improvement Objectives Written performance objectives, targets and implementation plans to improve the Participant’s social performance, including a
periodic assessment of Participant’s performance in achieving those objectives.
E5.1
An adequate and effective performance management process for A) Labor, B)
Health & Safety, C) Environment, and D) Ethics, including setting performance (improvement) objectives and targets,
developing and implementing improvement plans, regularly reviewing progress toward achieving targets, and making appropriate
adjustments if needed is in place
Applicable Out of Scope Applicable Applicable
E6) Training Programs for training managers and workers to implement Participant’s policies, procedures and improvement objectives and to meet
applicable legal and regulatory requirements.
E6.1
An adequate and effective training process is established for all employees/workers on all policy/procedures/job related aspects and performance targets related to A)
Labor, B) Health & Safety, C) Environment, and D) Ethics
Applicable Applicable Applicable Applicable
E7) Communication Process for communicating clear and accurate information about Participant’s policies, practices, expectations and performance to
workers, suppliers and customers.
E7.1
An adequate and effective worker/employee, supplier and customer communication/reporting process about A) Labor, B) Health & Safety, C) Environment,
and D) Ethics policies, practices and performance is established
Applicable Out of Scope Applicable Applicable
E8) Worker Feedback and Participation Ongoing processes to assess employees’ understanding of and obtain feedback on practices and conditions covered by this Code and
to foster continuous improvement.
E8.1
An adequate and effective worker grievance/complaint process whereby workers can confidentially communicate work-‐related grievances or complaints without fear of reprisal or intimidation is
established
Applicable Applicable Applicable Applicable
E8.2
An adequate and effective worker consultation/participation process whereby
management solicits and encourages worker feedback and participation for improvement via various channels is in
place
Applicable Applicable Applicable Applicable
E9) Audits and Assessments Periodic self-‐evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual
requirements related to social and environmental responsibility.
E9.1
An adequate and effective Audit process to periodically assess conformance with the EICC Code including compliance with
applicable laws and regulations pertaining to: A) Labor B) Health & Safety C)
Environment and D) Ethics.
Applicable Applicable Applicable Applicable
E10) Corrective Action Process Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
E10.1
Has established an adequate and effective corrective actions process to rectify and
close non-‐conformances with the EICC Code including legal non-‐compliances identified via internal or external Audits, assessments, inspections, investigations and reviews, covering A) Labor B) Health & Safety C)
Environment and D) Ethics.
Applicable Applicable Applicable Applicable
E10.2
Violations have been corrected or are on track for correction, where monetary
penalties were assessed, or where formal corrective actions were mandated by the issuing government agency for A) Labor B) Health & Safety C) Environment D) Ethics.
Applicable Applicable Applicable Applicable
E11) Documentation and Records Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements
along with appropriate confidentiality to protect privacy.
E11.1
Adequate and effective documentation and records for A) Labor, B)Health & Safety,
C)Environment, and D)Ethics management systems are maintained and appropriate levels of access to ensure privacy are
implemented.
Applicable Out of Scope Applicable Applicable
E12) Supplier Responsibility Process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.
E12.1 The EICC Code requirements have been communicated to the next tier suppliers
Applicable Applicable Out of Scope Applicable
E12.2 An effective process to ensure that the next
tier suppliers implement the Code is implemented
Applicable Applicable Out of Scope Applicable
28. VAP Definitions
1. Audit
An Audit is an evidence gathering process. Audit evidence is used to evaluate how well Audit criteria are being met. Audits must be objective, impartial, and independent, and the Audit process must be both systematic and documented.
There are three types of Audits: first-‐party, second-‐party, and third-‐party Audits. First-‐party Audits are internal Audits. Second and third party Audits are external Audits.
Organizations use first party (internal) Audits to Audit themselves for internal purposes. However, you don’t have to do them yourself. You can ask an external organization to carry out an internal Audit on behalf of your organization. First party Audits are often used to declare that your organization complies with an ISO standard (this is called a self-‐declaration). However, this practice is not applicable to EICC.
Second party Audits are external Audits. They’re usually done by customers or by others on their behalf. However, they can also be done by any external party that has an interest in your organization.
Third party Audits are external Audits as well. However, they’re performed by independent (disinterested) external organizations. Third party Audits are used to determine whether or not an organization complies with a particular standard or set of Audit criteria.
2. Audit criteria
Audit criteria include policies, procedures, and requirements. Audit evidence is used to determine how well such Audit criteria are being met. Audit evidence is used to determine how well policies are being implemented, how well procedures are being applied, and how well requirements are being met.
3. Auditee
An Auditee is an organization (or part of an organization) that is being Audited. Organizations include companies, corporations, enterprises, firms, charities, associations, and institutions. Organizations can be either incorporated or unincorporated and can be privately or publicly owned.
4. Audit evidence
Audit evidence includes records, factual statements, visual observations, factual statements, and other verifiable information that is related to the Audit criteria being used. In most cases, Audit evidence must be triangulated to justify a finding of conformance or Nonconformance Audit evidence can be either qualitative or quantitative. Objective evidence is data that shows or proves that something exists or is true. Data Triangulation is a form of data corroboration and is the use of three independent pieces of evidence to prove a conformance or Nonconformance. Audit evidence can be independent in type or source.
5. Audit findings
Audit findings result from a process that evaluates Audit evidence and compares it against Audit criteria. Audit findings can show that Audit criteria are being met (conformity) or that they are not being met (nonconformity). They can also identify improvement opportunities. Audit findings are used to assess the effectiveness of the CSR management system and to identify opportunities for improvement.
Audit evidence includes records, documents, visual observations, factual statements, and other verifiable information that is related to the Audit criteria being used. Audit evidence must be triangulated to justify a finding of conformance or Nonconformance.
6. Auditor
In the context of EICC, this management standard, an Auditor is a person who collects evidence in order to evaluate how well an Auditee’s CSR management systems meet requirements.
Auditors are expected to determine whether management systems comply with standards and other planned arrangements. They must also be able to determine whether management systems are properly implemented and maintained. And they must be able to do all of this while being independent, objective, impartial, and competent.
7. Audit plan
An Audit plan specifies how you intend to conduct a particular Audit. It describes the activities you intend to carry out and the arrangements you intend to make.
8. Audit scope
The scope of an Audit is a statement that specifies the focus, extent, and boundary of a particular Audit. The scope of an Audit is generally defined by specifying the physical location of the Audit, the organizational units that will be examined, the processes and activities that will be included, and the time period that will be covered.
9. Benchmarking
Benchmarking is a methodology that is used to search for best practices. Benchmarking can be applied to strategies, policies, operations, processes, products, and organizational structures. By finding and adopting best practices you can improve your organization’s overall performance. Best practices can be found either within your own organization or within other organizations. It usually means identifying organizations that are doing something in the best possible way and then trying to emulate how they do it.
There are at least two types of external benchmarking: competitive benchmarking and generic benchmarking. Competitive benchmarking involves comparing how you do things with how your competitors do things while generic benchmarking involves comparing yourself with organizations in unrelated sectors.
In order to carry out benchmarking projects, you need to develop a benchmarking methodology. Your benchmarking methodology should define rules that control:
a) How the scope of each project is defined. b) How benchmarking partners are selected. c) How confidentiality is respected and ensured. d) How benchmarking characteristics are specified. e) How benchmarking indicators or metrics are chosen. f) How benchmarking data is collected and analyzed. g) How potential improvements are identified. h) How improvement plans are developed.
i) How your benchmarking experience is added to your organization’s knowledge base.
10. Bonded Labor:
Another form of debt bondage, it often starts with the worker agreeing to provide labor in exchange for a loan, but quickly develops into bondage as the employer adds more and more "debt" to the bargain. (source ILO Jurisprudence)
11. Characteristic
A characteristic is a distinctive feature or property of something. Characteristics can be inherent or assigned. An inherent characteristic exists in something or is a permanent feature of something, while an assigned characteristic is a feature that is attributed or attached to something.
12. Coercion
(A) Threats of serious harm to or physical restraint against any person;
(B) any scheme, plan, or pattern intended to cause a person to believe that failure to perform an act would result in serious harm to or physical restraint against any person; or
(C) The abuse or threatened abuse of the legal process. (source: US code – title 22: foreign relations and intercourse – chapter 78: trafficking victims protection)
13. Compulsory labor
People are required by law to work on public construction projects such as roads and bridges. (source ILO Jurisprudence)
14. Conformity or Conformance
To conform means to meet or comply with requirements. There are many types of requirements. There are EICC requirements, customer requirements, product requirements, management requirements, legal requirements, and so on.
Requirements can be explicitly specified (like the EICC Code of Conduct requirements) or implied. A specified requirement is one that has been stated (in a document, for example). When your organization meets a requirement, you can say that it conforms to that requirement.
15. Containment
Containment is the act, process, or means of immediately reducing a threat or lowering a risk. Containment is kept in place until more permanent corrective actions are implemented. For example: an Auditor observes a worker operating an unguarded metal stamping press. This is a Priority Nonconformance (see definition xx) because it can cause serious injury or death. An appropriate containment of this hazard could
16. Continual improvement
Continual improvement is a set of activities that an organization carries out in order to enhance its ability to meet requirements. Continual improvements can be achieved by carrying out Audits, self-‐assessments, management reviews, and benchmarking projects. Continual improvements can also be realized by collecting data, analyzing information, setting objectives, and implementing corrective and preventive actions.
17. Correction
A correction is any action that is taken to eliminate a nonconformance. However, corrections do not address causes.
18. Corrective action
Corrective actions are steps that are taken to remove the causes of an existing nonconformity or undesirable situation. The corrective action process is designed to prevent the recurrence of nonconformities or undesirable situations. It tries to make sure that existing nonconformities and situations don’t happen again. It tries to prevent recurrence by eliminating causes. Corrective actions address actual problems. Because of this, the corrective action process can be thought of as a problem solving process.
19. Customer
A customer is anyone who receives products or services from a supplier organization. Customers can be people or organizations and can be either external or internal to the supplier organization. For example, a factory may supply products or services to another factory (customer) within the same organization. According to EICC, examples of customers include clients, consumers, end-‐users, purchasers, retailers, and beneficiaries.
20. Debt bondage
The term “debt bondage” means the status or condition of a debtor arising from a pledge by the debtor of his or her personal services or of those of a person under his or her control as a security for debt, if the value of those services as reasonably assessed is not applied toward the liquidation of the debt or the length and nature of those services are not respectively limited and defined. (Source: US code – title 22: foreign relations and intercourse – chapter 78: trafficking victims protection)
21. Effectiveness
Effectiveness refers to the degree to which a planned result is achieved. Planned activities are effective if these activities are realized. Similarly, planned results are effective if these results are actually achieved. For example, an effective process is one that realizes planned activities and achieves planned results.
22. Efficiency
Efficiency is a relationship between results achieved (outputs) and resources used (inputs). Efficiency can be enhanced by achieving more with the same or fewer resources. The efficiency of a process or system can be enhanced by achieving more or getting better results (outputs) with the same or fewer resources (inputs).
23. Excessive fees
An excessive fee is any fee that can lead the worker into debt bondage.
* No fee or cost for recruitment shall be charged directly or indirectly, in whole or in part, to the worker, including costs associated with the processing of official documents and work visas, unless authorized by national law. If fees are collected from workers in compliance with national law and disclosed.
* If national law allows recruitment fees to be charged to workers then workers are free to terminate employment at any time, without threat or penalty related to repayment (maximum set by law or definition by debt bondage)
* For services fees such as food, dormitories, .., fees shall be equal or lower than local market value for same amenity
* For employer mandated requirements and amenities no fee shall be charged, e.g. personal protective equipment, uniforms, time cards,..
* Administrative fees for recruitment cannot be charged to workers
* Service fees for processing of official documents (e.g. passports) if allowed by law shall be equal or lower to local market non recruitment service fees and not exceed what could lead worker into debt bondage
* In some countries limits of hiring fees (the combination of recruitment, administrative and service fees) for worker is governed by national law.
* Fees shall not exceed 10 percent monthly wage repayment at national set interest rate or better for a maximum period of 6 months, with exception of Employer sponsored educational development the amount shall not exceed 10 percent monthly wage repayment at national set interest rate or better for a maximum period of 1 year.
In all cases national law or provisions of the Code whichever is stricter applies. National law is defined as law of sending and receiving country
24. Forced or compulsory labor
All work or service that is exacted from any person under the menace of any penalty and for which the said person has not offered himself voluntarily.
Nevertheless, for the purposes of this Convention, the term forced or compulsory labor shall not include (a) any work or service exacted in virtue of compulsory military service laws for work of a purely military character; (b) any work or service which forms part of the normal civic obligations of the citizens of a fully self-‐governing country; (c) any work or service exacted from any person as a consequence of a conviction in a court of law, provided that the said work or service is carried out under the supervision and control of a public authority and that the said person is not hired to or placed at the disposal of private individuals, companies or associations; (d) any work or service exacted in cases of emergency, that is to say, in the event of war or of a calamity or threatened calamity, such as fire, flood, famine, earthquake, violent epidemic or epizootic diseases, invasion by animal, insect or vegetable pests, and in general any circumstance that would endanger the existence or the well-‐being of the whole or part of the population; (e) minor communal services of a kind which, being performed by the members of the community in the direct interest of the said community, can therefore be considered as normal civic obligations incumbent upon the members of the community, provided that the members of the community or their direct representatives shall have the right to be consulted in regard to the need for such services. (Source: ILO Convention (No. 29) concerning Forced or Compulsory Labor)
25. Inspection
Inspections use observation, measurement, testing and judgment to evaluate conformity. Inspection results are compared with specified requirements in order to establish whether conformity has been achieved. Workplace inspections compare workplace conditions with legal and Code requirements in order to evaluate conformity.
26. Interested party
An interested party is a person or group that has a stake in the success or performance of an organization. Interested parties may be directly affected by the organization or actively concerned about its performance. Interested parties can come from inside or outside of the organization. Examples of interested parties include customers, suppliers, owners, partners, employees, NGOs, unions, bankers, or members of the general public. Interested parties are also referred to as stakeholders.
27. Internal Audit
Internal Audits are referred to as first-‐party Audits. Organizations use internal (first-‐party) Audits to Audit themselves for internal purposes. Furthermore, you don’t have to do them yourself. You can ask an external organization to carry out an internal Audit on behalf of your organization.
28. Involuntary servitude
The term “involuntary servitude” includes a condition of servitude induced by means of—
(A) Any scheme, plan, or pattern intended to cause a person to believe that, if the person did not enter into or continue in such condition, that person or another person would suffer serious harm or physical restraint; or (B) the abuse or threatened abuse of the legal process. (Source: US code – title 22: foreign relations and intercourse – chapter 78: trafficking victims protection)
29. Key performance indicator (KPI)
A key performance indicator (KPI) is a metric or measure. KPIs are used to quantify and evaluate organizational success. They measure how much success you’ve had and how much progress you’ve made relative to the objectives you wish to achieve. KPIs are also used to set measurable objectives, evaluate progress, monitor trends, make improvements, and support decision making. KPIs should be quantifiable and appropriate and should collect information that is useful to your organization and relevant to the needs and expectations of interested parties.
Examples of KPIs include the following: employee turnover rate, average hours worked per week, average time to closure of nonconformities, lost workday case rate, employee satisfaction survey score, and energy costs per unit of production.
The following analogy might help make the point: when you go to your doctor he or she might measure blood pressure, cholesterol levels, heart rate, and your body mass index as key indicators of health. KPIs try to do the same thing for organizations.
30. Major Nonconformance
A nonconformance seen a significant failure in the management system – one that affects the ability of the system to produce the desired results. It may also be caused by failure to implement an established process or procedure or if the process or procedure is totally ineffective. For example, the failure of an organization to verify its compliance to applicable laws and regulations is a Major Nonconformance
31. Management
The term management refers to all the activities that are used to coordinate, direct, and control an organization. In this context, the term management does not refer to people. It refers to activities. EICC uses the term top management to refer to people.
32. Management review
The overall purpose of a management review is to evaluate the suitability, adequacy, and effectiveness of an organization's CSR management system, and to look for improvement opportunities.
Management reviews are also used to identify and assess opportunities to change an organization’s Labor, Ethics, or EHS policies and objectives, to address resource needs, and to look for opportunities to improve its CSR performance.
33. Management system
A management system is a set of interrelated or interacting elements that organizations use to implement policy and achieve objectives.
There are many types of management systems. Some of these include labor management systems, environmental management systems, emergency management systems, food safety management systems, occupational health and safety management systems, information security management systems, and business continuity management systems.
34. Management System Manual
A CSR manual documents an organization's management system. It can be a paper manual or an electronic manual. Your management system manual should:
• Define the scope of your system.
• Describe how your MS processes interact.
• Document your CSR procedures or refer to them.
35. Minor Nonconformance
A nonconformance that by itself doesn’t indicate a systemic problem with the management system. It is typically an isolated or random incident. Examples are: an internal Audit with an overdue corrective action request pending, or a procedure that has not been revised to reflect a change in regulations
36. Nonconformity
Nonconformity refers to a failure to comply with requirements. A requirement is a need, expectation, or obligation. It can be stated or implied by an organization, its customers, or other interested parties.
There are many types of requirements. Some of these include Code requirements, customer requirements, management requirements, and legal requirements. Whenever your organization fails to meet one of these requirements, nonconformity occurs. The EICC Audit criteria list CSR management system requirements. When your organization deviates from these requirements, nonconformity occurs.
37. Objective evidence
Objective evidence is data that shows or proves that something exists or is true. Objective evidence can be collected by performing observations, measurements, tests, or by using any other suitable method.
38. Outsourced process
An outsourced process is any process that is part of your organization’s CSR management system but is performed by a party that is external to your organization.
According to management system principles, you must identify and control your outsourced processes, and you must ensure that each outsourced process is effective. You also need to figure out how to control the interaction between internal and outsourced processes.
According to ISO/TC 176/SC 2/N526R, “the terms subcontract and outsource are interchangeable and have the same meaning”.
39. Planning
Planning involves setting CSR improvement objectives and then specifying the operational processes and resources that will be needed to achieve those objectives. Planning is one part of CSR management.
40. Policy
An organization’s policy defines top management’s commitment to Labor, Ethics or EHS. A policy statement should describe an organization’s general Labor, Ethics and EHS orientation and clarify its basic intentions.
Policies should be used to generate objectives and should serve as a general framework for action. Policies can be based on the EICC Code of Conduct and should be consistent with the organization’s other policies.
41. Preventive action
Preventive actions are steps that are taken to remove the causes of potential nonconformities or potential situations that are undesirable. The preventive action process is designed to prevent the occurrence of nonconformities or situations that do not yet exist. It tries to prevent occurrence by eliminating causes.
While corrective actions prevent recurrence, preventive actions prevent occurrence. Both types of actions are intended to prevent nonconformities. Preventive actions address potential problems, ones that haven't yet occurred.
42. Priority Nonconformance
Priority findings are the highest severity finding and require escalation by Auditors. Priority findings confirm the presence of intolerable practices or conditions, such as the presence of underage child workers (below the legal age for work or apprenticeship), forced labor, health and safety issues that can cause immediate danger to life or serious injury, and environmental practices that can cause serious and immediate harm to the community. Some Codes refer to these as “Zero Tolerance” issues.
43. Prison labor The contracting out of prison labor or forcing of prisoners to work for profit-‐making enterprises. (Source ILO Jurisprudence
44. Procedure
A procedure is a way of carrying out a process or activity. Procedures may or may not be documented. However, in most cases, EICC expects you to document your procedures.
Documented procedures can be very general or very detailed, or anywhere in between. While a general procedure could take the form of a simple flow diagram, a detailed procedure could be a one page form or it could be several pages of text.
A detailed procedure defines and controls the work that should be done, and explains how it should be done, who should do it, and under what circumstances. In addition, it explains what authority and what responsibility has been allocated, which inputs should be used, and what outputs should be generated.
45. Process
A process is a set of activities that are interrelated or that interact with one another. Processes use resources to transform inputs into outputs. Processes are interconnected because the output from one process becomes the input for another process. In effect, processes are “glued” together by means of such input output relationships. For example, the output from a risk assessment process is the input to an organization’s objective setting process.
Organizational processes should be planned and carried out under controlled conditions. An effective process is one that realizes planned activities and achieves planned results.
46. Process approach
The process approach is a management strategy. When managers use a process approach, it means that they manage the processes that make up their organization, the interaction between these processes, and the inputs and outputs that tie these processes together.
47. Process-‐based management system (MS)
A process-‐based management system uses a process approach to manage and control how its Labor, Ethics, or EHS policy is implemented and how its improvement objectives are achieved. A process-‐based management system is a network of interrelated and interconnected processes.
Each process uses resources to transform inputs into outputs. Since the output of one process becomes the input of another process, processes interact and are interrelated by means of such input-‐output relationships. These process interactions create a single integrated process-‐based MS.
48. Program
A program is a collection of organizational resources that is geared to accomplish a certain major goal or set of goals. A program is also defined as an ongoing set of activities, processes and procedures internal to the organization, for example, a Personal Protective Equipment (PPE) Program.
In the example of a PPE program, the goals are to ensure PPE is properly selected, used and maintained, and that worker exposure to health hazards is controlled.
The program may include a PPE risk assessment process, a respirator fit testing procedure, etc.
49. Record
A record is a type of document. Records provide evidence that activities have been performed or results have been achieved. They always document the past. Records can, for example, be used to show that traceability requirements are being met, that verification is being performed, and that preventive and corrective actions are being carried out.
50. Requirement
A requirement is a need, expectation, or obligation. It can be stated or implied by an organization, its customers, or other interested parties. A specified requirement is one that has been stated (in a document for example), whereas an implied requirement is a need, expectation, or obligation that is common practice or customary.
There are many types of requirements. Some of these include EICC requirements, customer requirements, management requirements, product requirements, and legal requirements.
51. Review
A review is an activity. Its purpose is to figure out how well the thing being reviewed is capable of achieving established objectives. Reviews ask the following question: is the subject of the review a suitable, adequate, effective, and efficient way of achieving your organization’s objectives?
There are many kinds of reviews. Some of these include management reviews, objectives reviews, customer requirement reviews, and nonconformity reviews.
52. Risk of Nonconformance
An Audit finding used in a limited number of situations.
a. When there is insufficient evidence to conclusively determine conformance or Nonconformance. This could happen as a result of insufficient time, or unavailability of key documents or individuals,
b. When there is conflicting evidence. An example of this would be when worker interview information contradicts program documentation or management statements, or
c. If the condition or practice is in conformance with the requirement, but in an Auditor’s judgment, it would likely deteriorate to a Nonconformance without some additional action or effort on the part of facility management
53. Slavery
A "physical abduction" followed by forced labor. (Source: ILO Jurisprudence)
54. Strategy
A strategy is a logically structured plan or method for achieving long term goals. You need to develop a strategy and policies to ensure that your organization’s mission, vision, and values are accepted and supported by interested parties.
55. Supplier
A supplier is a person or an organization that provides products or services. Suppliers can be either internal or external to the organization. Internal suppliers provide products to people within their own organization while external suppliers provide products to other organizations. Examples of suppliers include organizations and people who produce, distribute, or sell products, provide services, or publish information.
56. Sustained success
An organization achieves sustained success when it meets its objectives and continues to do so over the long term. Objectives can only be achieved if the organization consistently meets the needs and expectations of interested parties (stakeholders).
57. Systems approach
When managers use a systems approach, it means that they treat the interrelated processes that make up an organization as an integrated system and then they use this system to achieve its objectives. A system is a set of elements that are interrelated or interact with one another.
58. Trafficking
The recruitment, harboring, transportation, provision, or obtaining of a person for labor or services, through the use of force, fraud, or coercion for the purpose of subjection to involuntary servitude, peonage, debt bondage, or slavery. (Source: US code – title 22: foreign relations and intercourse – chapter 78: trafficking victims protection)
59. Validation
Validation is a process. It uses objective evidence to confirm that the requirements that define an intended outcome have been met. Whenever all requirements have been met, a validated status is achieved.
60. Values
Your values are the general principles and beliefs that are important to your organization.
61. Verification
Verification is a process. It uses objective evidence to confirm that specified requirements have been met. Whenever specified requirements have been met, a verified status is achieved.
There are many ways to verify that requirements have been met. For example, you could do tests, perform demonstrations, carry out alternative calculations, or you could inspect documents before you issue them.
62. Vision
An organization's vision describes what it wants to be and how it wants to be seen by interested parties.
63. Work environment
The term work environment refers to working conditions. It refers to all of the conditions and factors that influence work. In general, these include physical, social, psychological, and environmental conditions and factors. Work environment includes lighting, temperature, and noise factors, as well as the whole range of ergonomic influences. It also includes things like supervisory practices as well as reward and recognition programs. All of these things influence work.
64. EICC VAP Auditors
Auditor with a valid EICC VAP Qualification and/or a valid EICC-‐IRCA certification
65. VAP Qualified
Auditor who has a valid EICC VAP qualification issued by the APM (has scored 3 or higher out of 5 for either Labor/Ethics and/or Environment/Health/Safety)
66. EICC-‐IRCA Certified
Auditor who has a valid EICC-‐IRCA certification, which is Auditor or Lead Auditor Status
