Version 6.

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Audit Details
Sedex Company ZC: 000001234 Sedex Site Reference: ZS: 000012345
Reference: (only available on Sedex
(only available on Sedex System)
System)

Business name (Company XXXX Toy Manufacturing Co., Ltd.

name):
Site name: China Toy and Associated Products Co., Ltd.
Site address: No 1 Road 2. China Country: China
(Please include full address) Industry Zone
Site contact and job title: Mr EEE, Factory Manager
Site phone: +86-12345678 Site e–mail: 123@chinatoy.com
SMETA Audit Pillars : Labour Health & Environment Business Ethics
Standards Safety (plus 4-Pillar
Environment 2-
Pillar)
Date of Audit: 25-26 February 2019

Audit Company Name & Logo: Report Owner (payee):

(If paid for by the customer of the site
please remove for Sedex upload)
AAC
XXXX Toy Manufacturing Co., Ltd.

Audit Conducted By

Affiliate Audit Purchaser

Retailer
Company

Brand owner NGO Trade Union

Multi– Combined Audit (select all that apply)

stakeholder

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Audit Content:
(1) A SMETA audit was conducted which included some or all of Labour Standards, Health &
Safety, Environment and Business Ethics. The SMETA Best Practice Version 6.1 November
2018 was applied. The scope of workers included all types at the site e.g. direct
employees, agency workers, workers employed by service providers and workers provided
by other contractors. Any deviations from the SMETA Methodology are stated (with
reasons for deviation) in the SMETA Declaration.

(2) The audit scope was against the following reference documents
2-Pillar SMETA Audit
• ETI Base Code
• SMETA Additions
• Universal rights covering UNGP
• Management systems and code implementation,
• Responsible Recruitment
• Entitlement to Work & Immigration,
• Sub-Contracting and Home working,
4-Pillar SMETA
• 2-Pillar requirements plus
• Additional Pillar assessment of Environment
• Additional Pillar assessment of Business Ethics
• The Customer’s Supplier Code (Appendix 1)

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

(4) Any Non-Compliance against customer code shall not be uploaded to Sedex. However,
in the CAPR these ‘Variances in compliance between ETI code / SMETA Additions/ local
law and customer code’ shall be noted in the observations section of the CAPR.

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SMETA Declaration
I declare that the audit underpinning the following report was conducted in accordance
with SMETA Best Practice Guidance and SMETA Measurement Criteria.

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

(2) Any Non-Compliance against customer code alone shall not be uploaded to Sedex. However, in
the CAPR these ‘Variances in compliance between ETI code / SMETA Additions/ local law and
customer code’ shall be noted in the observations section of the CAPR.

Any exceptions to this must be recorded here (e.g. different sample size): Nil

Auditor Team (s) (please list all including all interviewers):

Lead auditor: Mr AAA, Senior Auditor
Team auditor: Miss CCC, Auditor
Interviewers: Miss CCC

Report writer: Mr AAA

Report reviewer: Miss YYY, Senior Report Reviewer

Date of declaration: 26 February 2019

Note: The focus of this ethical audit is on the ETI Base Code and local law. The additional elements will not be audited in
such depth or scope, but the audit process will still highlight any specific issues.

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

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Audit Parameters

Audit Parameters

A: Time in and time out Day 1 Time in: 9:00 Day 2 Time in: 9:00 Day 3 Time in:
Day 1 Time out: 17:00 Day 2 Time out: 15:00 Day 3 Time out:

B: Number of auditor days used: 3.5 (2 auditors X 1.75 days)

C: Audit type: Full Initial

Periodic
Full Follow–up
Partial Follow–Up
Partial Other
If other, please define:

D: Was the audit announced? Announced

Semi – announced: Window detail: 3 weeks
Unannounced

E: Was the Sedex SAQ available for Yes

review? No
If No, why not
The factory had only just started the SAQ and so did not make it
available to the auditors.

F: Any conflicting information Yes

SAQ/Pre-Audit Info to Audit findings? No
If Yes, please capture detail in appropriate audit by clause

G: Who signed and agreed CAPR Mr EEE – Factory Manager

(Name and job title)

H: Is further information available Yes

(if yes, please contact audit company for No
details)

I: Previous audit date: N/A

J: Previous audit type: N/A

K: Were any previous audits reviewed Yes No

for this audit
N/A

Audit attendance Management Worker Representatives

Senior management Worker Committee Union representatives

representatives

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

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

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

D: If Worker Representatives were Worker committee were present during this audit; however, the
not present please explain reasons factory management said the workers could not be spared for
why (only complete if no worker reps opening and closing meeting.
present)
The management would communicate the outcome of the audit
to the workers though poster in the workshops and would discuss
at next worker committee meeting.

E: If Union Representatives were not There is no union at this factory.

present please explain reasons why:
(only complete if no union reps present)

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Guidance:
The Corrective Action Plan Report summarises the site audit findings and a corrective, and preventative
action plan that both the auditor and the site manager believe is reasonable to ensure conformity with the
ETI Base Code, Local Laws and additional audited requirements. After the initial audit, the form is used to re-
record actions taken and to categorise the status of the non-compliances.

N.B. observations and good practice examples should be pointed out at the closing meeting as well as
discussing non-compliances and corrective actions.

To ensure that good practice examples are highlighted to the supplier and to give a more ‘balanced’ audit
a section to record these has been provided on the CAPR document (see following pages) which will
remain with the supplier. They will be further confirmed on receipt of the audit report.
Root cause (see column 4)
Root cause refers to the specific procedure or lack of procedure which caused the issue to arise. Before a
corrective action can sustainably rectify the situation it is important to find out the real cause of the non-
compliance and whether a system change is necessary to ensure the issue will not arise again in the future.
See SMETA BPG Chapter 7 ‘Audit Execution’ for more explanation of “root cause’’.
Next Steps:
1. The site shall request, via Sedex, that the audit body upload the audit report, non-compliances,
observations and good examples. If you have not already received instructions on how to do this
then please visit the web site www.sedexglobal.com.
2. Sites shall action its non-compliances and document its progress via Sedex.
3. Once the site has effectively progressed through its actions then it shall request via Sedex that the
audit body verify its actions. Please visit www.sedexglobal.com web site for information on how to
do this.
4. The audit body shall verify corrective actions taken by the site by either a "Desk-Top” review process
via Sedex or by Follow-up Audit (see point 5).
5. Some non-compliances that cannot be closed off by “Desk-Top” review may need to be closed off
via a “1 Day Follow Up Audit” charged at normal fee rates. If this is the case then the site will be
notified after its submission of documentary evidence relating to that non-compliance. Any follow-
up audit must take place within twelve months of the initial audit and the information from the initial
audit must be available for sign off of corrective action.
6. For changes to wages and hours to be correctly verified it will normally require a follow up site visit.
Auditors will generally require to see a minimum of two months wages and hours records, showing
new rates in order to confirm changes (note some clients may ask for a longer period, if in doubt
please check with the client).

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Corrective Action Plan

Corrective Action Plan – non-compliances

Non- New or Details of Non- Root cause Preventative and Timescale Verification Agreed by Verification Evidence Status Commented [A3]: Root Cause: This is an opportunity for
Compliance Carried Compliance (completed by the Corrective Actions (Immediate, Method Management and Open/Closed the site to reflect on what the reason for the NC is, and
Number Over Details of Non-Compliance site) Details of actions to be 30, 60, Desktop / and Name of Comments or comment
what in their practices is the root cause of the NC.
taken to clear non- 90,180,365) Follow-Up
The reference Is this a new Responsible Details on corrective action
number of the non- compliance, and the [D/F] evidence Commented [A2]: Details of Non-Compliance: should be
Person:
non-compliance compliance system change to raised with the site as soon as they are found in order that
Note if
from the Audit identified at prevent re- occurrence
management the management can identify root causes.
Report, the follow-up (agreed between site
agree to the non- It is not necessary to cite the full law/code reference here
for example, or one and auditor)
compliance, and – this should be written in the report.
Discrimination carried over document name
No.7 (C) that is still of responsible Commented [A4]: Verification Method: Please refer to
outstanding person Non-Compliance Guidance.
Commented [A1]: Non-Compliance numbers: Should be
NC 1 New During worker interview, Training It is recommended 60 days Desktop Mr. FFF
easy to understand, and easy to connect to
0B 10 out of 42 workers Systems that all workers are HR Manager
corresponding NC in report.
Management interviewed were not Costs made aware of the
systems and aware of the ETI code lack of workers content of the ETI Commented [A6]: Verification Evidence and Comments
code and were not aware it Other – please code and that it is & Status: only for follow up audits.
implementation was posted in the give details: additionally
-1 factory in local displayed in the Commented [A5]: Please include name and position of
language. worker’s canteen, for responsible person.
increased visibility.

NC 2 New It was noted that there Training It is recommended 60 days Follow-Up Mr. FFF
0B were inconsistencies Systems that the HR Manager
Management regarding working hours Costs management adopt
systems and among the time records lack of workers practices and
code provided by factory Other – please controls to ensure
implementation management, give details: poor that accurate and
-2 production records record keeping, complete records
collected from inadequate are provided to
workshops and internal auditor so that the
employees' checks compliance status of
representation. Thus, the wages and working
status of minimum hours can be
wage, overtime wage verified.
and working hours

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could not be fully

verified in this audit.
a. The broken needle
records showed that
some workers (4+3)
were working on 16&23
December 2018 while
attendance records
showed it was a rest
day (see also hours
section).
b. Production &
maintenance records in
the moulding and
painting workshop
showed that workers in
the moulding and
painting workshop were
working on 23
December 2018 while
the attendance records
showed they were
resting (see also wages
and hours sections).

NC 3 New In the sample review of Training Management 30 days Follow-Up Mr. FFF
1 Freely chosen 42 files one was found Systems believed it was an HR Manager
Employment with an original ID card Costs isolated mistake by
-1 and a check was made lack of workers the personnel office
on all other files (610). Other – please and that the
In full check 2 files were give details: Poor procedure for
found to have an internal checking handing back ID
original ID, 3 were found of personal records cards after copying
with original birth was written down
certificate and 5 were and clear. This was
found with original confirmed by 30
academic qualification recently joined
- all others had copies. workers all having
These workers had copied ID’s only in
joined the factory in the their files.
last 6 months, and the Managers suggested
management believe that they implement
that the personnel a system for the HR

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office had overlooked manager checking

giving the originals back the files of all new
to the workers. joiners at the end of
each month to
ensure that ID cards
had been given
back.

NC 4 New Based on documents Training It is recommended 30 days Follow-Up Mr. FFF

1 Freely chosen review and interview Systems that the factory HR Manager
Employment with employees and Costs should stop such
-2 management lack of workers behaviour and
representative it was Other – please ensure no more
found workers were give details: Work deposit happen.
required to lodge materials should
“deposits” of RMB 100 not carry deposits.
separately for the PPE Possible lack of
(all workers), workers in knowledge of the
sewing and cutting code.
additionally had to pay
for scissors (approx. 115
workers). These deposits
were not always
returned to workers
(from document review
approx., 50% got their
deposits back).

NC 5 New The worker’s committee Training The site agreed that 60 days Desktop Mr. FFF
2 Freedom of existed in theory but did Systems worker/management HR Manager
Association not appear to function. Costs committee meetings
-1 It had met only once in lack of workers would take place
the last 6 months and Other – please every 3 months and
the number of workers give details: Lack that female workers
had dropped from 10 to of knowledge of would be elected to
6. The female members local law and code the committee. If
had left which mean requirements in the necessary, women
that the 60% of the area of freedom of representatives
workers at the site had association. would meet
no gender separately with a
representation in the female manager.
worker’s committee. Management
Committee members agreed to publish the

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were dissatisfied at the meeting minutes by

lack of action by displaying them in
management based on the works canteen
the issues they raised at and to continue to
the one meeting. publish the minutes
of any further
meetings.

NC 6 New Workers interviewed Training The site agreed to 60 days Follow-Up Mr. FFF
2 Freedom of knew there was a Systems inform all workers of HR Manager
Association worker’s committee and Costs the worker
-2 that its lack of workers committee and to
members had been Other – please include it as part of
elected, but did not give details: induction training.
know: Communicate the
• How the nominations process for the
and elections were worker committee to
organised workers, during
• Who their induction training
representatives were and on relevant
• The roles and notice boards and in
responsibilities of worker relevant meetings
representatives. following induction.
Ensure worker
representatives are
known to workers, for
example through
pictures on notice
boards.

NC 7 New Worker committee Training Workers to be made 60 days Follow-Up Mr. GGG
2 Freedom of representatives Systems aware that there was H&S Manager
Association reported that their Costs need for gloves and
-3 requests were being lack of workers that the glues in use
ignored. These included Other – please in the factory were
PPE requests for gloves give details: Lack not hazardous to
in detail painting of feedback health. In the future,
workshop (part of mechanisms. if committee
painting workshop in members make
production building 2). requests, ensure any
The H&S manager said follow-up is fed back
he had checked with to the committee
the supplier of the and to workers, even

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adhesives and had in cases are not

been told there was no followed through.
health and safety risk to
workers, in addition
some workers did not
wish to use gloves as it
affected their speed of
work and thus their
production bonus.

NC 8 New Suggestion boxes and Training Management and 60 days Follow-Up Mr. FFF
2 Freedom of confidential email for Systems worker committee to HR Manager
Association grievances were not Costs communicate the
-4 known about lack of workers existence of
throughout the Other – please grievance
workforce, 85% of give details: mechanisms to
workers knew about workers once more,
suggestion box and 60% and how they can
knew about be used most
confidential email. effectively.
Management to put
anonymous
suggestion on a
notice board above
the suggestion box
along with the
management
response to those
suggestions. This will
show to workers the
purpose of the
suggestion box as
well as keep them
informed of the
manager’s response.

NC 9 New During facility tour, it Training It is recommended 30 days Desktop Mr. GGG
3 Safety and was noted that one 1- Systems that the facility H&S Manager
Hygienic storey building was used Costs should ensure at
Conditions as raw materials and lack of workers least 2 safety exits
-1 finished products Other – please are available in this
warehouse. The floor give details: Lack warehouse.
area of this warehouse of awareness of

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was more than 5000 legal requirements

square meters, on H&S.
however, there was only
one safety exit for the
warehouse.

NC 10 New During facility tour, it Training It is recommended 30 days Desktop Mr. GGG
3 Safety and was noted that no exit Systems that the facility H&S Manager
Hygienic sign was installed for 1 Costs should ensure the
Conditions out of 2 safety exits in lack of workers exit signs are installed
-2 the packing workshop Other – please on the top of all
on the 2nd floor of No.2 give details: Lack safety exits in the
production building. of packing workshop.
monitoring

NC 11 New During the facility tour, it Training It is recommended 30 days Desktop Mr. GGG
3 Safety and was noted that total 45 Systems that appropriate PPE H&S Manager
Hygienic workers in the spray- Costs and training is
Conditions painting department lack of workers provided to the
-3 were not wearing Other – please workers in the spray
rubber gloves, goggles give details: Lack department.
and masks. Examination of awareness of
of the MSDS showed health and Safety
that these were solvent risks. No hazardous
based paints and the risk assessment
recommended safety carried out.
precautions were to use
them with the above
PPE.

NC 12 New During facility tour, it Training It is recommended 30 days Desktop Mr. GGG
3 Safety and was noted that 2 fire Systems that the facility H&S Manager
Hygienic extinguishers and 1 fire Costs should ensure all the
Conditions hydrant were blocked lack of workers firefighting
-4 by production materials Other – please equipment in the
in the sewing workshop give details: Lack sewing workshop are
on the 2nd floor of No.1 of free of obstruction.
production building. monitoring

NC 13 New During interview of a Training It is recommended 30 days Follow-Up Mr. FFF

4 Child Labour selection of juvenile Systems that the facility HR Manager

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-1 workers (16-18yrs) and Costs should ensure all the

on review of their lack of workers juvenile workers are
personal files, it was Other – please registered with the
noted that all the 20 give details: Lack local labour bureau.
juvenile workers were of awareness of
not registered with the legal requirements
local labour bureau in on young workers.
the facility. Inadequate
procedures.
Inadequate
internal
management
checks.

NC 14 New During interview of a Training It is recommended 30 days Follow-Up Mr. FFF

4 Child Labour selection of juvenile Systems that the facility HR Manager
-2 workers (16-18yrs) and Costs should ensure all the
on review of their lack of workers juvenile workers are
personal files, it was Other – please provided with regular
noted that all the 20 give details: Lack physical
juvenile workers were of awareness of examinations.
not provided the regular legal requirements
physical examinations. on young workers.
Inadequate
procedures.
Inadequate
internal
management
checks.

NC 15 New Per attendance Training It is recommended 30 days Follow-Up Mr. FFF

4 Child Labour records, it was noted Systems that the facility HR Manager
-3 that 5 out of 20 juvenile Costs should ensure no
workers were assigned lack of workers overtime work was
overtime work in Other – please assigned for juvenile
January 2019. The 5 give details: Lack employees.
juvenile workers worked of awareness of
8 hours on weekend legal requirements
and total 24 overtime on young workers.
hours in January 2019. Inadequate
procedures.
Inadequate
internal

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management
checks.

NC 16 New a. The broken needle Training It is recommended 60 days Follow-Up Mr. EEE
5 Living Wages records showed that Systems that the facility keeps Factory
and Benefits some workers (4+3) Costs accurate and Manager
-1 were working on 16&23 lack of workers complete
December 2018 while Other – please attendance records
attendance records give details: The to ensure that wages
showed it was a rest cause of and hours can be
day (see also hours inconsistencies was accurately verified.
section). workers who wrote
b. Production & the dates on the
maintenance records in production records
the moulding and by mistake. We will
painting workshop require all
showed that workers in department heads
the moulding and to check the
painting workshop were production records
working on 23 on a daily basis to
December 2018 while ensure that all and
the attendance records attendance
showed they were records are
resting (see also wages correctly
and hours sections). completed, in
The auditor was able to order to avoid such
verify some wages and inconsistencies in
hours records, and the future.
these are detailed in
wages and hours
sections.

NC 17 New During document Training It is recommended 60 days Follow-Up Mr. EEE

5 Living Wages review of the payroll it Systems that management Factory
and Benefits was noted that workers Costs should ensure that Manager
-2 were not being paid lack of workers employees are
correct overtime Other – please properly
premiums for those give details: System compensated for all
workers earning more in place which fails overtime worked.
than the minimum to meet the legal
wage, E.g. the highest requirements of
paid worker in the premium paid on
wages table was paid standard wage.

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standard wages at 1500 Lack of awareness

per month (21.75 days of legal
and 8 hours per day), requirements and
that was of code
8.62 currency units per requirements.
hour. For 28 hours
overtime hours per
month the total wage
should be: 8.62
(standard wage rate) X
28 (hrs.) X 1.5 (overtime
rate) = 362 [currency
units], the actual wages
paid were 265.4 i.e.
overtime rates were
calculated on the
minimum wage but not
the normal wages.

NC 18 New 5 of the 42 workers Training It is recommended 60 days Follow-Up Mr. EEE

5 Living Wages sampled did not Systems that factory Factory
and Benefits receive minimum legal Costs management should Manager
-3 wage for standard hours lack of workers ensure that
of 40 hours per week Other – please employees are paid
and 174 hours per give details: Lack at least the local
month. Although each of knowledge of minimum wage.
was paid an legal requirements
attendance bonus and for minimum wage.
production bonus the
standard contracted
hourly rate for these 5
workers was RMB 5.8 per
hour instead of the legal
requirement of RMB 6.32
per hour. Management
confirmed that 10% of
the workforce (65
workers) was
contracted at RMB 5.8
per hour and these
included cleaners (5%
of workforce – 32
workers) and new

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production workers (5%

of workforce – 33
workers). They also
stated that new workers
could earn production
bonus and that both
new workers and
cleaners could earn
attendance bonus.
By discussion it was
clear that these extra
payments were not
guaranteed, and that
was a legal requirement
to guarantee a
minimum legal wage of
RMB 6.32 per hour to all
workers as a minimum
requirement, bonuses
etc. were then in
addition.

NC 19 New It was noted that the Training It is recommended 120 days Desktop Mr. EEE
5 Living Wages social insurance Systems that factory Factory
and Benefits coverage was Costs management should Manager
-4 insufficient in the facility. lack of workers ensure that
According to the social Other – please employees receive
insurance payment give details: Some all of their statutory
receipt provided by workers came from welfare entitlements.
factory management, it other province
was noted that only 50% refused to
employees were participate in the
provided with pension, social insurance
accident,
unemployment,
medical and maternity
insurance in January
2019.

NC 20 New Overtime hours Training It is recommended 60 days Follow-Up Mr. EEE

6 Working Hours exceeded the legal Systems that the facility Factory
-1 requirement of 36 hours Costs should ensure that Manager
per month. According lack of workers employee’s overtime

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to the attendance Other – please hours do not exceed

records of 3 sample give details: the statutory limits.
months, it was noted
that 40 out of 42 sample
workers worked 40-70
overtime hours in
January 2019 (current
month); 42 out of 42
sample workers worked
40-80 overtime hours in
November 2018 (peak
month); 20 out of 42
sample workers worked
37-50 overtime hours in
May 2018 (random
month).

NC 21 New a. Through reviewing Training It is recommended 60 days Follow-Up Mr. EEE

6 Working Hours the Broken Needle / Systems that the factory Factory
-2 Needle Storage Costs should ensure Manager
Records, it was noted lack of workers maintain and
that 4 workers worked Other – please provide accurate
on 16 December 2018, 3 give details: The and complete
workers worked on 23 cause of attendance records
December 2018, but the inconsistencies was to ensure the
attendance records workers who wrote minimum wage,
provided by the facility the dates on the overtime wage and
indicated that those production records working hours can be
workers rested on the by mistake. We will verified.
corresponding require all
mentioned days. department heads
b. Through reviewing to check the
the production records production records
of moulding and on a daily basis to
painting workshop, it ensure that all and
was noted that there attendance
were production records are
records on 23 correctly
December 2018, but the completed, in
attendance records order to avoid such
provided by the facility inconsistencies in
indicated that all the future.
workers in moulding and

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painting workshop
rested on the above-
mentioned days.
The auditor was able to
verify some wages and
hours records, and
these were detailed in
wages and hours
sections.

NC 22 New It was noted that there Training It is recommended 30 days Desktop Mr. EEE
7 Discrimination were discrimination Systems that management Factory
-1 practices based on age Costs adopt practices and Manager
during hiring process. lack of workers recruitment policy to
According to Other – please ensure that labours
recruitment poster at give details: Lack are not discriminated
the main gate, only of knowledge against in
employees between of legal employment,
the ages of 16 to 40 requirements regardless of age.
were allowed to be
employed for the
production workshops.
However, factory
management could not
provide any evidence
to prove that the jobs in
the production
workshops were only fit
for employees between
the ages of 16 to 40.

NC 23 New It was noted that before Training It is recommended 30 days Follow-Up Mr. EEE
7 Discrimination hiring, a health Systems that the facility Factory
-2 examination was Costs should stop this Manager
conducted and for lack of workers practice to avoid
female applicants the Other – please any discrimination on
report including give details: Lack employees.
pregnancy test. This was of awareness
a relatively new of code
practice, which had requirements and
been implemented international
since June 2018. A total standards
of 15 women had done

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the pregnancy test and

one of them had been
found pregnant and
had not been given a
job. It was not clear if
this was due to
pregnancy or other
circumstances.

NC 24 New Anti-discrimination Training The procedure shall 30 days Desktop Mr. EEE
7 Discrimination procedure on hiring, Systems be developed and Factory
-3 compensation, Costs communicated to Manager
promotion and access lack of workers workers through
to training was not Other – please document and
available during the give details: training.
audit. Inadequate
systems and lack of
management
checks

NC 25 New Random checked 42 Training It is recommended 30 days Desktop Mr. EEE

8 Regular workers’ labour Systems that the facility Factory
Employment contracts, it was noted Costs should sign labour Manager
-1 that one worker was lack of workers contracts with the
recruited in April 2018 Other – please employees within
and one worker was give details: Lack one month of the
recruited in May 2018, of knowledge of start of the working
but they both signed legal requirements relationship.
contract on 01 for contracts.
September 2018. The Inadequate
factory would normally systems and lack of
sign labour contract management
with new recruited checks
workers within one
month after the
recruitment, however,
the procedure was not
effective, and some
workers were not given
a contract until they
notified the
management about
this.

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A review of all workers

employed since
February 2018 (30)
showed that 3 more
employees had not
received a contract
within one month of
their joining the facility,
however they had
received after three
months (in June), and so
only two employees
now lacked contacts.

NC 26 New During peak months, Training The factory should 30 days Follow-Up Mr. FFF
8 Regular the facility used up to 50 Systems ensure all temporary HR Manager
Employment temporary workers to Costs workers are provided
-2 support with orders. lack of workers with personnel
These workers came Other – please records, working
from the local region give details: Lack hours and wage
and were recruited of knowledge of records and that
through a local labour legal requirements these are kept on file
agent, Mr LLL. for contracts. for at least two years
According to the Inadequate for each worker.
interview with systems and lack of Where possible the
management, there management site should pay
were no formal system checks. temporary workers
in place to manage by bank transfer.
and monitor the
working conditions of
these workers.
According to the
interview with workers
and records review,
which showed that
workers worked the
same hours and
received the same pay
as permanent workers.
However, the personnel
records for these
workers were
incomplete, and didn’t

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include copies of
identity cards.
Furthermore, these
workers were paid in
cash.

NC 27 New From interview with the Training The site should make 30 days Desktop Mr. EEE
8A Sub– management and Systems their main client Factory
Contracting workers, the main client Costs aware of the sub- Manager
and had not been informed lack of workers contracting units
Homeworking of the subcontracting at Other – please used for Assembling
-1 this facility. give details: Lack and moulding.
It was noted that 2 of awareness of
subcontractors were customer’s
used by the facility. requirements and
Details please refer to standards.
Audit Report.

NC 28 New From interview with Training The site should make 30 days Desktop Mr. EEE
8A Sub– management there was Systems sub-contractors Factory
Contracting no system in place to Costs aware of the Ethical Manager
and manage and monitor lack of workers code and implement
Homeworking the working conditions Other – please a system to monitor.
-2 at the sub-contractors. give details: Lack
There was no of awareness of
communication to the customer’s
subcontract units requirements and
concerning the ethical standards.
code of the main client Inadequate
or of the sites’ own systems for
code and policies. subcontracting
Although QC personnel
from the main facility
visited the subcontract
facilities, there was no
knowledge of the hours,
wages and benefits
paid to the subcontract
workers.

NC 29 New Per factory policy Training It is recommended Immediate Follow-Up Mr. EEE
review, it was noted Systems that the facility Factory
that employees in all Costs should remove the Manager

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9 Harsh or workshops would be lack of workers physical punishment

Inhumane punished to clean up Other – please rule from the
Treatment applicable workshop if give details: handbook.
-1 they violated factory
rules and gained a
written warning letter.
Factory management
represented that they
only established this rule
in the employee
handbook to catch
employees’ attention
and manage
employees better. This
practice was not
adopted since the rule
established till now.

NC 30 New It was noted that the Training It is recommended 30 days Desktop Mr. EEE
10B4 facility provided the Systems that facility should Factory
Environment 4– contact to prove the Costs ensure that the Manager
Pillar waste paint slag (HW12) lack of workers hazardous waste
-1 was disposed by ZZZ Other – please disposed by qualified
Solid Waste Dispose Co., give details: Lack contractors and the
Ltd to. And the of understanding of transfer manifests are
contractor had the legal requirements well retained.
valid contractor’s and environmental
hazardous waste standards.
operation license. Inadequate control
However, the facility systems of
management was environmental
unable to provide the impacts
hazardous waste
transfer manifest for
review.

NC 31 New The facility had not Training It is recommended 30 days Desktop Mr. EEE
10C Business delivered formal training Systems that facility should Factory
Ethics to employees and Costs ensure provide Manager
-1 workers on its Whistle lack of workers training to all
blowing policy. Other – please employees on the
Management agreed give details: whistle-blowing
this had not yet been Inadequate policy and maintain

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delivered and they systems and lack of records of these

meant to update their management training sessions.
training to include it. checks

Corrective Action Plan – Observations

Observation New or Details of Observation Root cause Any improvement actions discussed
Number Carried Details of Observation (completed by the site) (Not uploaded on to SEDEX)
The reference Over
number of the Is this a new
observation from observation
the Audit Report, identified at
for example, the follow-up
Discrimination or one carried
No.7 over (C) that
is still
outstanding

OB 1 New Management is aware of the human rights statement published by the parent Did not see the The site should make appropriate workers
0A: Universal company, but they do not communicate it to the workforce or their suppliers. importance of the issue aware of the human rights statement published
Rights covering by the parent company.
UNGP -1

OB 2 New Before the audit, it was noted that the SAQ had not been completed. Site explained that they The site would finalise the SAQ within the next
0B had not been part of month.
Management Sedex for very long, and
systems and due to heavy workload,
code they had not managed
implementation to fill out the SAQ
-1 completely.

OB 3 New In discussion with management they confirmed that they had not Lack of knowledge of the The HR manager suggested that they start
0B communicated the code to their own suppliers/sub-contractors or conducted code requirements. discussions with these regular suppliers on the
Management social assessment for suppliers/sub-contractors. In addition, they had not code content.
systems and established the procedure of controlling their own suppliers’ conformance to the
code code. The purchasing manager confirmed that some of their suppliers had been
implementation with them for many years and were likely to stay as supplier partners.
-2

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OB 4 New Minutes of the worker’s committee meeting are produced but they are not Negligence from the Managers agreed that it would be a good idea
2 Freedom of shared with the total workforce. Management. to post them in the canteen and they will do so
Association - 1 for the last set of minutes and future minutes.

OB 5 New During worker interviews, some workers reported that sometimes the toilets were Negligence from Management to monitor toilet cleanliness more
3 Safety and not clean. Management reported that they cleaned the toilets regularly and the management/supervisors. closely and ask workers to raise it with their
Hygienic auditor saw the cleaning rota which confirmed this. On the day of the visit, the supervisors if toilets are unclean.
Conditions - 1 toilets were clean and hygienic.

OB 6 New The factory had a minimum working age policy (at least 16 years old), but some Lack of code The HR manager said that as all recruitment
4 Child Labour managers were not aware of this. requirements. went through their office, this had not been an
-1 Inadequate internal issue so far. However, they would re-
training practices. communicate the policy to all members of staff
to ensure this was clear.

OB 7 New Some workers reported other workers found it easier to take time off as they were Inadequate Management will investigate during next worker
7 Discrimination friendlier to supervisors and management. The auditor could not verify this communication and survey to determine if this is an issue and remind
-1 through management interviews or record cross-checking. training given to workers. all workers and supervisors of the 1-step leave
policy to ensure everyone knows the process
and follows it.

OB 8 New There was no formal contract with the 2 sub-contractors, the facility had worked Lack of knowledge of the Formalize contracts with sub-contractors
8A Sub– with the same sub-contractors over a long time and has not seen a need for a code requirements. including control system should be prepared in
Contracting formalised contract as the relationship had always been good; however, they this facility.
and were currently in the process of formalising the subcontracting and set up a
Homeworking written contract (on-going).
-1

OB 9 New Site had not completed the SAQ (including environmental information). Lack of knowledge of the The facility was in the process of finishing the
10B4 requirements and SAQ.
Environment 4– international standards.
Pillar - 1

Good examples Commented [A7]: Please look for and report Good
examples – see SMETA Guidance for definition of what
Good example Details of good example noted Any relevant Evidence and constitutes a GE – do not just report compliance to local
Number Comments law as a GE.
The reference Please ensure anything here is also in the Report and if
number of the applicable, that relevant photos are included.

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non-compliance
from the Audit
Report,
for example,
Discrimination No.7

GE 1 The site has undergone a human rights impact assessment and has acted accordingly to improve its links and impact on the local Human rights impact assessment and
0A: Universal community. follow-up actions.
Rights covering
UNGP

GE 2 The factory had an internal management system which included its own internal audits and workers surveys performed by properly Internal audit reports, annual survey
0B Management trained individuals. The site showed record that two members of the quality audit team had been on a social auditing skills course documentation and
systems and and were trained to review documents. worker/management Interviews.
code The last worker survey was delivered in November 2018 and the internal audit in December 2018.
implementation The site used findings from the survey to increase satisfaction of workers, for example by improving quality of food provided.

GE 3 Annual survey of worker’s satisfaction, used to understand worker sentiment and improve working conditions. Dormitory tour and workers interview.
2 Freedom of
Association

GE 4 A library was provided freely on the first floor of the dormitory. Dormitory tour and workers interview.
3 Safety and
Hygienic
Conditions

GE 5 Factory provided free meals and transportation for workers. Worker interview & transportation
5 Living Wages - Free meal was provided once a day, at lunch, workers had to provide food for themselves at morning and night. This benefit was records.
and Benefits given all workdays of the year and to all workers, both the workers living at site and outside.
- The free transportation was given each morning and night, to workers not living at site (260). The transportation left from three local
bus stations in the morning (in areas where the workers live), and took them to the site, in the evening, all workers not living at site
were provided transportation back to bus stations.

GE 6 The site had policies and processes which upskilled female workers to supervisors and managers. They were still developing this Workers and managers interviews,
7 Discrimination process and keeping records to demonstrate its effectiveness. personnel files.

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Confirmation
Please sign this document confirming that the above findings have been discussed with and understood by you: (site management)
If actual signatures are not possible in electronic versions, please state the name of the signatory in applicable boxes, as indicating the signature.

A: Site Representative Signature: Mr. EEE Title: Factory Manager

Date: 26 February 2019

B: Auditor Signature: Mr. AAA Title: Senior Auditor

Date: 26 February 2019

C: Please indicate below if you, the site management, dispute any of the findings. No need to complete D-E, if no disputes.

D: I dispute the following numbered non-compliances:

Nil

E: Signed: Mr. EEE Title: Factory Manager

(If any entry in box D, please complete
a signature on this line) Date: 26 February 2019

F: Any other site Comments:

Nil

Audit company: AAC Report reference: AAC2019022501 Date: 25-26/02/2019 27

Guidance on Root Cause

Explanation of the Root Cause Column

If a non-compliance is to be rectified by a corrective action which will also prevent the non-
compliance re-occurring, it is necessary to consider whether a system change is required.

Understanding the root cause of the non-compliance is essential if a site is to prevent the issue re-
occurring.

The root cause refers to the specific activity/ procedure or lack of activity /procedure which
caused the non-compliance to arise. Before a corrective action can rectify the situation it is
important to find out the real cause of the non-compliance and whether a system change is
necessary to ensure the issue will not arise again in the future.

Since this is a new addition, it is not a mandatory requirement to complete this column at this time.
We hope to encourage auditors and sites to think about Root Causes and where they are able to
agree, this column may be used to describe their discussion.

Some examples of finding a “root cause”

Example 1
Where excessive hours have been noted the real reason for these needs to be understood, whether due to
production planning, bottle necks in the operation, insufficient training of operators, delays in receiving
trims, etc.

Example 2
A non-compliance may be found where workers are not using PPE that has been provided to them. This
could be the result of insufficient training for workers to understand the need for its use; a lack of follow-up
by supervisors aligned to a proper set of factory rules or the fact that workers feel their productivity (and thus
potential earnings) is affected by use of items such as metal gloves.

Example 3
A site uses fines to control unacceptable behaviour of workers.

International standards (and often local laws) may require that workers should not be fined for disciplinary
reasons.

It may be difficult to stop fines immediately as the site rules may have been in place for some time, but to
prevent the non-compliance re- occurring it will be necessary to make a system change.

The symptom is fines, but the root cause is a management system which may break the law. To prevent the
problem re-occurring it will be necessary to make a system change for example the site could consider a
system which rewards for good behaviour

Only by understanding the underlying cause can effective corrective actions be taken to ensure
continuous compliance.

The site is encouraged to complete this section so as to indicate their understanding of the issues raised and
the actions to be taken.

Audit company: AAC Report reference: AAC2019022501 Date: 25-26/02/2019 28

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