Winwin Industrial Co., Ltd. (L-1149...

Compliance Assessment Report

Winwin Industrial Co., Ltd. (L-1149 (NT-036))

Audited on April 30, 2015 Page 1 of 16 NBCUniversal Confidential

Report Date: May 8, 2015 Audit Date: April 30, 2015 Factory ID number: L-1149 (NT-036)

To: Mr. Jianwen Huang <[email protected]>

From: Summer Chen / AECOM <[email protected]>

Cc: Parul Chandra / NBCUniversal <[email protected]> Sophie Zhao / NBCUniversal <[email protected]> Tori Carroll / NBCUniversal <[email protected]> Jonathan Castillo / NBCUniversal <[email protected]> Karen Tiongson / NBCUniversal <[email protected]> Jo Trostle / NBCUniversal <[email protected]> Erquiaga, Margaret /NBCUniversal <[email protected]> Sagar Brahmbhatt / BB Designs Europe Ltd. <[email protected]> Gloria Hsu / BB Designs Europe Ltd. <[email protected]> <[email protected]>

Subject: Summary of Findings – Supplier CSSR Re-audit Winwin Industrial Co., Ltd. (L-1149 (NT-036)) North 1

st Road #3, Chikan Industrial Park, Shipai Town, Dongguan City, Guangdong

Province, China

Audit type: 2nd

Audit The initial audit was conducted by Robert Huang from URS on April 8, 2013.

This report summarizes the findings of the Corporate Supplier Social Responsibility (CSSR) Re-Audit conducted at the facility of Winwin Industrial Co., Ltd. located at North 1

st Road #3, Chikan Industrial

Park, Shipai Town, Dongguan City, Guangdong Province, China.

The findings of the CSSR Reviews were based upon a review of the documents furnished by Winwin Industrial Co., Ltd. and the observations obtained by AECOM on behalf of NBCUniversal during the Site visit on April 30, 2015. For the purpose of this audit, the facility of Winwin Industrial Co., Ltd. is referred to as the ‘Site’ in this report.

Guidance The CSSR Audit Report summarizes the Site audit findings and includes a corrective, and preventative action plan that both the Auditor and the Site Manager believe is reasonable to ensure conformity with the country specific and local laws.

NBCUniversal (NBCU) upholds a worldwide reputation for integrity and high standards of business conduct. NBCU Supplier Relationship Policy requires that we source only from suppliers who comply with local laws and any applicable NBCU standards in such areas as labour, environment, health and safety. In order to ensure compliance with applicable laws and company policies please provide evidence of closure on all open red findings within 90 days from receipt of report.

If you have any questions about the memorandum please contact the following persons:

Karen Tiongson / NBCUniversal <[email protected]> and

Summer Chen / AECOM <[email protected]>on behalf of NBCUniversal

mailto:[email protected]








Supplier General Information

Name of Factory Winwin Industrial Co., Ltd.

（东莞市永昌美工艺品有限公司）

Physical Location Address

North 1st Road #3, Chikan Industrial Park, Shipai Town, Dongguan City, Guangdong Province, China

（中国广东省东莞市石排镇赤坎工业区北一路 3 号）

Factory Contact Name(s) Mr. Jianwen Huang, Manager （黄建文，经理）

Factory Contact Number/Email

Tel: +86-769-8136 9092 / +86-158 2093 5569 Email: [email protected]

Licensee/Vendor Company Name

BB Designs Europe Ltd.

License/Vendor Company Contact Name/Email

Sagar Brahmbhatt / BB Designs Europe Ltd. <[email protected]>

Gloria Hsu / BB Designs Europe Ltd. <[email protected]> <[email protected]>

Waivers from Government

One social insurance waiver was issued by Social Security Bureau of Shipai Town, Dongguan City on April 21, 2015, which indicated there were 38 employees covered with five types of social insurance and the factory was compliant with the local requirements.

Certifications received from Government or other Companies.

OHSAS18001 Certificate: valid from October 11, 2014 to October 10, 2017

Principal Products Manufactured

Badges, Magnets, Coasters, Key Chains

Output of Products Approximately 500,000 pieces per month.

Major Customers Blue Square Ltd; Kwrios Co., Ltd etc.

Production Process Molding (mold making, machinery processing and carving), casting, scraping, drilling, punching, polishing, coloring, epoxy doming, off-set printing, screen printing, drying, quality check and packaging

Factory Normal Working Days and Normal Work Hours

From Monday to Friday, five days a week;

Daily working hours: 8:00~12:00; 14:00~18:00, one shift

Departments that run more than one shift

Security guards (3 shifts)




Peak Production Months No obvious peak production months

Number of Production Buildings

The Site has one three-storey production building and one singles-storey warehouse for chemcial and molds storage.

Canteen/Cafeteria Services The canteen is located on the 1st floor of the dormitory building.

Dormitories The Site has one four-storey dormitory building.

Security Four security guards are working at the Site for 24 hours a day, 7 days a week in 3 shifts.

Overall findings In view of findings raised, non-compliances were observed in the areas of production buildings. Details of the findings are listed below.

Findings Total Findings 15 Black Flags – 0 Red Flags -7 Yellow Flags – 8

Permits – the following government documents and permits were provided for review.

1. One Safety Officer Certificate of Mr. Jianwen Huang, valid to September 5, 2017;

2. Environmental Impact Assessment (EIA) Statement Form for Initial Project and Approval, issued by Environmental Protection Bureau (EPB) of Dongguan City, April 2009;

3. Environmental Impact Assessment (EIA) Statement Form for Expansion Project and Approval, issued by EPB of Dongguan City, June 2014;

4. Five Hazadous Waste Transfer Manifests for empty chemical containers, waste oil, waste solvents, waste rags and waste fluorescent tube, 2014;

5. Hazardous Waste Handling Agreement and License of hazardous waste vendors (Dongguan Yufeng Chemical Industrial Construction Co., Ltd), valid to August 17, 2015;

6. Industrial Wastewater Handling Agreement and License of Industrial Wastewater Vendor (Dongguan Yuefeng Wastewater Disposal Co., Ltd), valid to April 23, 2016;

7. Environmental Monitoring Report for sanitary wastewater, air emission, cooking fume and boundary noise, issued by Guangzhou Huanliang Environmental Monitoring Service Co., Ltd, August 2014;

8. 24 On-employment Occupational Health Check-up Reports, issued by Shijie Hospital, April 2015;

9. Industrial Hygiene Monitoring Report (including noise, high temperature and indoor air), issued by Guangdong Anbiao Monitoring Technology Co., Ltd, June 2014;

10. Two Special Equipment (Cargo Elevator) Operator and Management Licenses, valid to June 24, 2017;

11. One Special Equipment (Pressure Vessel) Operator License, valid to




May 30, 2018;

12. One Electrician License, valid to January 2019;

13. One Inspection Report of Cargo Elevator, valid to October 15, 2015;

14. Fire Protection Check and Acceptance (FPCA) Approval for one three-storey office building, one three-storey productin building and one four-storey dormitory building, issued by Fire Protection Bureau of Shipai Branch, Dongguan City, 2009;

15. One First Aider Training Certificate issued by Shipai Hospital, dated March 5, 2010;

16. Catering Service Permit of Canteen, valid to January 13, 2018;

17. One Health Certificate of Food Handler, valid to March 31, 2016.

Audit Score Percentage and Audit Re-extension Status

92.1%




Background

Winwin Industrial Co., Ltd. was founded in 2006 in Boluo Town, Huizhou City. The Site moved to the current location in 2009. The Site covers a land area of about 3,000 m

2, and a construction area of 9,000

m2, including one three-storey office building, one three-storey production building and one singles-storey

warehouse for chemcial and molds storage as well as one four-storey dormitory building. The canteen is located on the 1

st floor of the dormitory building. Half part of the dormitory building and another three-

storey production building located in the compound were occupied by another factory named Dongguan Lanxin Rubber Plastic Technology Co., Ltd, which leased the production and dormitory buildings since February 2015 and the production building was in process of decoration during Site visit. Meanwhile, the business license of the factory was in process of application. Adjacent properties of the Site are as follows:

- North: Fengyi Toys Factory;

- South: Shuangcuo Electronic Factory;

- West: Dongguan Lanxin Rubber Plastic Technology Co., Ltd;

- East: Boda Packaging Co., Ltd.

The production activities at the Site include molding (mold making, machinery processing and carving), casting, scraping, drilling, punching, polishing, coloring, epoxy doming, off-set printing, screen printing, drying, quality check and packaging. The raw materials used at the Site include copper sheets, iron sheets and kirsite. The main chemicals used at the Site are cyclohexane oil for molding making; inks, paint, thinner, cleaning agent and ethanol for coloring, screen printing and off-set printing; mucilage and glue for epoxy doming; lubricating oil for machines.

During Site visit, it was observed that only 73 employees including office staff present at the Site, no employee was working in the molding, drilling & punching, polishing, screen printing and set-off printing workshops. As per the Site management, all the employees in the aforementioned workshop were arranged to help scraping and packaging processes, which was confirmed by the interviewed employees. The Site had more than 100 employees at most during urgent production period.

The wastewater resources at the Site were sanitary wastewater and semi-goods cleaning wastewater. The sanitary wastewater was discharged to the public sewer system after being treated by the septic tank. Water is used to clean the semi-products after polishing process, and the industrial wastewater generated was collected in one concrete pool.

EHS Management

Mr. Jianwen Huang, Manager of the Site, takes charge of the general EHS affairs, and he holds the Safety Officer Certificate.

Employee Interview

Number of Selected Employees: There were 77 employees working at the Site. 25 employees (about 32.4% of the total staff) were selected for the worker interview.

Age Groups/Gender: Of the selected employees, 8 were 20-30 years old, 11 were 30-40 years old and 6 were 40-50 years old, including 18 males and 7 females.




Employment Period: Of the selected employees, 14 have worked for less than 1 year, 7 have worked for 1-2 years, 4 have worked for 2-5 years.

Operational Activities: Of the selected employees, 5 were from the casting workshop; 1 was from the molding workshop; 6 were from the scraping workshop, 8 were from the drilling and punching workshop; 3 were from the coloring workshop and 2 were from the packaging workshop.

Finding Numbers: None

Best Practices

All exits were installed for exit signs and emergency lights. All the evacuation aisles were clear of obstruction. Firefighting and evacuation facilities were well managed and the Site conducted daily, monthly inspections to ensure all facilities are in good condition. The dormitory and meals provided to the employees were free. The conditioner was equipped in each living room.

Opening and Closing Meetings

An opening meeting attended by Mr. Jianwen Huang (Manager), Mr. Feng (Manager Assistant), Ms. Li (HR Staff) and the auditor Ms. Summer Chen from AECOM was held at the beginning of the audit at 9:30 am. The auditor introduced the audit purpose, content and procedure, as well as the NBCU’s Code of Conduct (COC). The COC was signed by the Site representative.

A closing meeting attended by Mr. Jianwen Huang (Manager), Mr. Feng (Manager Assistant), Ms. Li (HR Staff) and the auditor Ms. Summer Chen from AECOM was conducted from 4:40 pm to 5:10 pm. The auditor presented all issues identified during the audit and introduced the follow-up procedure. All the findings were confirmed by the Site representatives and the Site representatives indicated that they would take corrective action as soon as possible.




Results Summary

Section Is there a finding?

If there is a finding, then list finding ID/Flag Type

Auditor Notes

Underage Labor No /

Forced Labor No /

Prison Labor No /

Working Hours No /

Wages & Compensation No /

Discrimination/Human Rights

No /

Freedom of Association No /

Facilities/Building Conditions

No /

Fire Prevention/Emergency Response

No 1.4 – Yellow Flag /

Occupational Health & Safety (Include all permits)

Yes

1.3.1 – Yellow Flag 1.3.2 – Yellow Flag 2.23 – Red Flag

/

Environmental Conditions (Include Waste, Air, Water)

No

1.2.1 – Yellow Flag 1.2.2 – Yellow Flag 1.2.3 – Yellow Flag 1.2.4 – Yellow Flag 1.2.5 – Yellow Flag 2.13.1 – Red Flag 2.13.2 – Red Flag 2.32.1 – Red Flag 2.32.2 – Red Flag 2.32.3 – Red Flag

/

Dormitories No

Canteen & Cafeteria Services

No /

Medical No 2.38 – Red Flag /




Security No /




1. Number of Fulltime Employees/Workers

Department First Shift Second Shift Third Shift as

applicable Peak Season

Molding 1 / / /

Casting 6 / / /

Scraping 6 / / /

Drilling and punching 10 / / /

Coloring and screen printing 8 / / /

Epoxy doming 2 / / /

Off-set printing 2 / / /

Quality Check 1 / / /

Drying and packaging 11 / / /

Management and Office 26 / / /

Security guards 2 1 1 /

Total Number of Employees/Workers

75 1 1 100

2. Production Process – include chemicals used in the production process

Production process Check if

applicable to Site

Chemicals used

Approximate volume of chemicals used/stored

monthly as observed by Auditor

Coloring, Screen Printing and Off-set printing

Yes

Inks Paint

Thinner Cleaning Agent

Ethanol

3kg/month 10kg/month 15kg/ month 1kg/month

1 drum/month (15L/drum)

Epoxy doming Yes Mucilage

Glue 1kg/month 20L/month

Molding Yes Cyclohexane Oil 5kg/month

Machines Yes Lubricating oil 3L/month




Issues to be addressed

No. Finding

Category Repeat Finding

Flag Type

Audit Findings Recommendations Photos

Environmental Permits

No Yellow

1.2.1 No Environmental Protection Check and Acceptance (EPCA) Approval was

provided for review. （工厂未提供环保竣工

验收批复。）

1.2.1 The Site should contact the local EPB to perform the EPCA and

obtain the approval. （工厂应向当地

环保局申请环保竣工验收并通过验

收。）

N/A


No Yellow

1.2.2 The pollutant sources at the Site were mainly sanitary wastewater, air emission via exhausting stacks from the casting, polishing, off-set printing, screen printing, epoxy doming, hand-coloring processes, cooking fume, noise, solid wastes and hazardous wastes (such as cleaning wastewater). However, no Pollution Discharge Permit (PDP) was provided for

review. （工厂主要产生生活废水、压铸、抛

光、柯式印刷、丝印、滴胶和入色工序通过

排气筒排放的废气、食堂油烟、噪音、固废

和危险废弃物（如清洗废水），但是工厂没

有提供排污许可证供查看。）

1.2.2 It is recommended the Site consult local environmental authority, and obtain Pollution

Discharge Permit as required. （建

议工厂咨询当地的环保局，并根据要

求取得排污许可证。）

N/A


Yes Yellow

1.2.3 No Annual Pollution Discharge Registration (PDR) was provided for review.

（工厂没有提供年度污染物排放申报登记供

查看。）

1.2.3 The Site should register the pollution discharge with local EPB

annually and keep the records. （工

厂应联系当地环保局进行污染物排放

申报登记，并保留相应记录。）

N/A


No Yellow

1.2.4 The sanitary wastewater was discharged into the public sewer system. However, no Wastewater Discharge Permit

was provided for review.（工厂产生的生活

1.2.4 The Site should consulate Shipai Water Management Institute (contact number: 0769-86550313) and Dongguan Water Bureau (0769-22830781) and apply for this permit.

N/A




No. Finding


Flag Type


废水排入市政管道，但工厂没有提供排水许

可证。）

（工厂需咨询石排水利管理所（联系

电话：0769-86550313）和东莞水务

局（联系电话：0769-22830781），

申请并获得该证。）


No Yellow

1.2.5 The wastewater and air emission discharge points were not identified or documented on an inventory using a unique discharge source identification method.

（废水和废气排放口没有标识或记录识别为

排放源。）

1.2.5 The Site should prepare an inventory to document all the wastewater and air emission source onsite and assign a unique identification number to each source.

（工厂应该制定一个识别和记录所有

废水和废气排放源的汇总表，并且给

所有排放源编号，该号码必须是唯

一。）

N/A

1.3 Health &

Safety Permits Yes Yellow

1.3.1 Potential occupational hazards at the Site included noise from the casting, drilling, punching, carving and polishing processes, dust from the polishing and machinery processing processes and Volatile Organic Compounds (VOCs) from the off-set printing, screen printing, epoxy doming and coloring processes. However, no Occupational Health Protection Facilities Check and Acceptance Assessment (HPCA) report or HPCA Approval was

available for review. （现场发现潜在的职

业病危害因素主要包括压铸、钻床、冲床、

雕刻和抛光工序产生的噪声，抛光和机加工

工序产生的粉尘，以及柯式印刷、丝印、滴

胶和入色工序产生的有机挥发物。但没有职

业病危害控制效果评价与防护设施竣工验收

1.3.1 It is recommended the Site consult the local Work Safety Bureau (WSB), retain a licensed company to prepare an HPCA report, apply for and obtain HPCA

Approval as required. （建议工厂咨

询当地安监局，委托一家有资质的机

构进行职业病危害控制效果评价，申

请并获取防护设施竣工验收批复。）

N/A




No. Finding


Flag Type


报告供审阅。）

Health & Safety Permits

Yes Yellow

1.3.2 No records or documents were available to indicate that Occupational Health Hazards had been registered with

competent authority. （工厂未提供职业危害

因素申报登记记录。）

1.3.2 The Site should register occupational hazards on the website and submit related documents to the

local WSB.（建议工厂在安监局的网

页上对所有职业危害因素进行申报登

记，并将申报登记文件提交至当地安

监局）。

http://211.100.47.109/zywsmain/index.asp

N/A

1.4 Fire Protection

Permits No Yellow

1.4 The Fire Protection Check and Acceptance (FPCA) Approval provided for review covered one three-storey office building, one three-storey production building and one four-storey dormitory building, but which did not cover the single-storey warehouse building for chemical and

mold storage. （工厂提供了一栋三层办公

楼、一栋三层厂房和一栋四层宿舍的消防验

收批复供查阅，但是没有出示一栋用于化学

品和模具存放的单层仓库的消防验收批

复。）

1.4 The Site should contact the landlord to confirm if FPCA has been conducted for the single-storey warehouse building for chemical and molds storage and if FPCA approvals have been received., If not, apply to the local fire protection authority for FPCA and obtain the

approval for the building . （工厂应

联系房东确认是否对该栋单层化学品

和模具存放仓库进行过消防验收，并

获得消防验收批复。如果没有，应联

系当地消防部门申请消防验收）。

N/A

2.13 Chemical Storage

Yes Red

2.13.1 There was no secondary containment provided for three chemical containers in the auto-coloring workshop.

（自动入色车间三桶化学品容器没有提供二

次容器。）

2.13.1 The Site should ensure the liquid chemical storage areas have appropriate secondary containment.

（工厂应确保存放化学品区域有合适

的二次容器。）




No. Finding


Flag Type


Chemical Storage

No Red

2.13.2 It was observed onsite that drinking water bottles were used to contain chemicals, and no safety labels were provided for approximately 40% of the

bottles. （现场发现工厂把化学品分装在矿

泉水瓶里，并且所有使用的约 40%的小瓶化

学品容器均无标签。）

2.13.2 The Site should use special chemical containers to replace drinking water bottles to contain chemicals, and post proper safety labels on all chemical containers.

（工厂应用指定的化学品容器，而非

矿泉水瓶来承装化学品，并且在所有

化学品容器上贴上合适的标签。） 1)

2)

2.23 Machine Guarding

No Red

2.23 There was no machine guard for the rotation areas of one pressing machine and

one punching machine. （一台压床和一台冲

床皮带轮转动部分没有安装保护罩。）

2.23 The Site should install machine guards for the rotation areas of the pressing machines and punching

machines.（工厂应给所有压床和冲

床皮带轮转动区域安装保护罩。）

1)




No. Finding


Flag Type


2)

2.32

Hazardous Waste Mgmt.

No Red

2.32.1 The waste hardware accessories were stored together with the hazardous wastes in the hazardous waste storage

area.（工厂把废五金零件与危险废弃物一起

存放在危险废弃物储存区域内。）

2.32.1 The Site should separate the non-hazardous wastes and other materials from the hazardous wastes. The hazardous storage areas should be provide with proper rain protection, ventilation, warning sign, secondary containment, emergency equipment, such as fire extinguishers and spill clean-up

materials. （工厂识别出所有危险废

物，并应将危险废物与其他废物或物

料分开进行管理和存放。危险废物存

放的场所应该有防雨措施、通风、警

告标示、二次围堰和应急用品，例如

灭火器和处理泄漏的设施。）


No Red

2.32.2 The blow-down generated from the air compressor in the machine maintenance room was discharged onto the concrete

floor directly.（机修房里空压机的冷凝水直

接排放到水泥地面上。）

2.32.2 The Site should collect the oily blow-down from the air compressor and dispose of it as

hazardous waste. （工厂应收集空压

机的冷凝水，并以危险废物进行处

理。）




No. Finding


Flag Type



No Red

2.32.3 The industrial wastewater generated at the Site was semi-goods cleaning wastewater. As per the Site management, the wastewater was collected in the concrete pool and transferred by the outsourced qualified vendor. The collection agreement and qualification license of the vendor were provided for review. However, no transfer manifest of the industrial

wastewater was provided for review. （工厂

产生的工业废水主要为半成品的清洗废水。

根据厂方解释，该废水收集在一个水泥池

里，并由一家有资质的回收商回收。废水回

收合同、回收商的资质证明有提供查看，但

是工厂没有提供工业废水的转移联单供查

看。）

2.32.3 The industrial wastewater should be collected and disposed of by a licensed company, and the Site should fill the transfer manifests for each shipment. The manifests should be kept for at least 5 years.

（工厂应委托一家有资质的危险废物

处置商收集处理工业废水，每次转移

都需要填写联单并保留危险废物转移

联单至少 5 年。）

N/A

2.38 Medical No Red

2.38 The Site only provided on-employment occupational health check-up to the employees exposed to the occupational health hazards. No pre- and post-occupational health check-up was provided for the workers exposed to the occupational

health hazards.（工厂为暴露于这些职业危

害因素的员工仅提供了在岗期间的职业健康

体检，但工厂未对暴露于这些职业危害因素

的员工提供岗前和岗后的职业健康体检。）

2.38 The Site should commission a licensed agency to provide pre-, on- and post-employment occupational health check-up to the employees exposed to occupational health

hazards. （工厂应识别出有职业危害

因素暴露的岗位，并为这些职位的员

工提供岗前、岗中和离职职业健康体

检。）

N/A




Notes

1. Black Flag - if there is a finding of possible child or prison labor, factory will be disqualified for use if confirmed.

2. Red Flag - all red flags findings must be closed or downgraded within 90 days of the audit.

3. Yellow Flag - all yellow flag findings must be closed before scheduled re-audit.

4. NBCUniversal has implemented a scoring system to provide an index by which our approved suppliers are rated to predict the sustainability of their compliance programs. If your factory scores 85% or above on the initial audit and then works to also close all mandatory findings, this will qualify the factory for an extension of the annual audit requirement. As an incentive for demonstrating commitment to an ongoing improvement plan, the annual audit requirement may be extended to 18 month or 24 month re-audit cycle. Note: If the factory scores below 85% then will only re-qualify for the re-audit extension based on new score from the second audit after 12 months.

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