GSCP Reference Tools APM Interactive

Global Social
Compliance Programme
Audit Process
and Methodology
Reference tools
October 2009
About the GSCP
Global Social Compliance Programme
/ GSCP objectives and scope / Users & Usage

The Global Social Compliance Programme is a business‐driven These tools are openly available for all to use. Users
programme for the continuous improvement of working can include GSCP member and non‐member buying
and environmental conditions in global supply chains. companies, suppliers and employment sites. Multi‐
The GSCP was created by and for global buying companies Stakeholder Initiatives and other initiatives, auditing
(manufacturers and retailers) wanting to work collaboratively bodies and other scheme owners can and are encouraged
on improving the sustainability (social and environmental) of to also use the GSCP Reference tools.
their often‐shared supply base. To this end, these companies
The Reference tools can voluntarily either be:
seek to harmonise existing efforts to deliver a shared, global
and sustainable approach. • integrated by users into their respective systems; or
The scope of the Programme encompasses: • utilised by users as a reference against which to
compare their existing tools through the GSCP
• social and labour practices,
Equivalence Process1.
• site‐specific environmental practices
(not product related).
/ Responsibility
The Programme can be applied at all levels of the supply
The GSCP does not monitor nor audit in any way the
chain.
compliance by a user’s supply chain with the GSCP
The Programme is neither a monitoring initiative, nor Reference tools or any standards.
a substitute to existing systems. The GSCP will not
The adoption of part or all of one or more Reference
undertake accreditation or certification activities as it
tools cannot be put forward as a proof of adequate
must remain a non‐aligned, neutral reference framework.
due diligence. The responsibility of the implementation
of these tools, of the monitoring of the user’s supply
/ The GSCP Reference tools chain’s compliance and of any due diligence linked to
it, resides with the user. Any use of the GSCP name or
To drive convergence, the GSCP has developed a set of
logo has to follow the terms established by the GSCP.
Reference tools and processes that provide a common
These terms are available on the GSCP website (www.
interpretation, based on best existing practice, of fair
gscpnet.com).
labour/social and environmental requirements and their
implementation in the supply chain.
1. The Equivalence Process is a mechanism by which a social and/or environmental compliance scheme is objectively benchmarked against the requirements defined in
one or more GSCP Reference tools, to determine their level of equivalence. Through the Equivalence Process, the GSCP enables the comparison of various standards and
schemes against the GSCP Reference tools, aiming at bringing convergence in requirements and approaches and building mutual recognition.
The Consumer Goods Forum

The GSCP is housed by The Consumer Goods Forum, a retailer and manufacturer parity industry body, driven by its
members2. It brings together retailers, manufacturers and suppliers to collaborate across the value chain to enrich
shopper and consumer value in all markets. It supports processes and practices that optimize the value chain as an
interrelated whole, in accordance with all anti-trust laws.
2. For more information, please visit www.theconsumergoodsforum.com
Acknowledgments
Thank you to those who contributed to this Reference tool
This Reference tool has been developed by supply chain experts from GSCP member companies, with input from key
stakeholders, including other brands and retailers, initiatives and international organisations, auditing and certification
bodies and civil society representatives. The GSCP would like to thank all those who have helped with the development
and continuous improvement of this Reference tool.
Global Social
Compliance Programme
Table of contents
// Introduction 02
// 1. Risk Assessment System 04

1.1 Self-assessment questionnaire 04
// 2. Audit Request 05
2.1 Launching the audit request 05
2.2 Pre-audit employment site profile 05
// 3. Preparation 06
3.1 Background and context review 06
3.2 Audit organisation 06
3.3 Communicating the audit arrangements 09
3.4 Supplier preparation 11
// 4. Audit Execution 12
4.1 Opening meeting 12
4.2 Employment site tour 13
4.3 Interviews 14
4.4 Document review 16
4.5 Alert notifications 17
4.6 Audit team pre-closing meeting 17
4.7 Closing meeting 27
// 5. Audit Outputs 28
5.1 Audit report 28
5.2 Supplementary audit information 29
5.3 Information management 29
5.4 Audit follow-up 30
// Glossary of Terms 31
// List of Appendices:
There are seven reference tools available that complement the audit process described above by providing further
reference guidelines and templates for carrying out the described process. These are:
Appendix 1: GSCP Reference Self Assessment Questionnaire
Appendix 2: GSCP Reference Pre-Audit Employment Site Profile
Appendix 3: GSCP Reference Audit Checks
Appendix 4: GSCP Reference Alert Notification
Appendix 5: GSCP Reference Audit Report
Appendix 6: GSCP Reference Supplementary Audit Information
Appendix 7: GSCP Reference Summary of Findings and Corrective Actions
GLOBAL SOCIAL COMPLIANCE PROGRAMME_01

INTRODUCTION
AUDIT PROCESS AND METHODOLOGY REFERENCE TOOLS - OCTOBER 2009

RISK ASSESSMENT SYSTEM
ABOUT THE GSCP REFERENCE TOOLS

ON AUDIT PROCESS & METHODOLOGY
Scope & usage
AUDIT REQUEST
The Reference tools on Audit Process and Methodology detail The Reference tools on Audit Process and Methodology are
the requirements that should be met by buying companies based on the GSCP Reference Code but can be adopted and
and auditors in order to conduct best practice social audits. tailored to other codes of conduct.
They cover all steps to be taken prior, during and after an audit
The Reference tools are not a substitute for existing audit
and includes where relevant templates to complement the
process or existing systems.
audit process. They apply to auditing of sites of employment
PREPARATION
from all sectors, categories and countries.
Overview of the audit process

AUDIT EXECUTION
The REFERENCE TOOL ON AUDIT PROCESS is designed to This can be done:

provide best practice guidance for the audit process. After
• by sharing briefing notes with the supplier explaining
benchmarking existing processes, the members of the Expert
the background, process, applicable codes and audit
Working Group on Audit Process & Methodology developed
methodology;
the following process.
• by developing a Best Practice manual giving examples of
“what good looks like” against each topic, with practical
Involvement of Suppliers in the audit process
AUDIT OUTPUTS
advice on ways to address common social compliance issues;

Suppliers should be involved as much as possible in the audit
• by encouraging suppliers to request social compliance
process.
audits themselves. This can be promoted as a way of
prompting continuous improvement or of demonstrating
their own commitment to social compliance.
GLOSSARY
APPENDICES
02_GLOBAL SOCIAL COMPLIANCE PROGRAMME

INTRODUCTION

Audit process
STEPS GSCP REFERENCE TOOL
ollecting risk criteria. For example, by evaluating:

C • Reference Self Assessment Questionnaire (Appendix 1)
AUDIT REQUEST
• Country of employment site
• Industry
• Processe
• Workforce size and type
• Self assessment questionnaire (optional)
PREPARATION
REQUEST FOR SOCIAL AUDIT
• Initial communication with employement site • Reference Pre Audit Employment Site Profile (Appendix 2)
AUDIT EXECUTION
• Collection of site information
PREPARATION
AUDIT OUTPUTS
• Background and content review
• Audit organisation: type, team, length
• Communicating audit arrangements
• Supplier preparation
AUDIT
GLOSSARY
• Opening meeting • Reference Audit Checks (Appendix 3)

• Site tour • Reference Alert Notifications (Appendix 4)
APPENDICES
• Management and worker interviews

• Document review
• Audit team prelosing meeting
• Closing meeting
AUDIT OUTPUTS
• Audit reporting • Reference Audit Report (Appendix 5)

• Followup and verification • Reference Supplementary Information (Appendix 6)
• Reference Summary of Findings and Corrective Action
(Appendix 7)

INTRODUCTION

1. RISK ASSESSMENT SYSTEM

A buying company should implement an efficient process nature of any subcontracting, level of supplier commitment
to measure social compliance and identify risk in its supply and/or previous audit results.
chain. This will enable the company to focus attention on
This information upon which the risk assessment is based is
key areas of potential risk and direct its audit resources
AUDIT REQUEST
provided by the supplier or employment site either through

accordingly.
a self-assessment questionnaire (Appendix 1) or through
Existing risk assessment tools for suppliers and employment questions asked as part of the commercial relationship.
sites include criteria such as: geographical area, employment
site function, product/service category, type of purchase,
employment patterns (migrant, casual workers etc.), level and
PREPARATION
1.1 Self-assessment questionnaire

The self-assessment questionnaire enables a supplier Companies should communicate the following to employment
or employment site to provide information about the sites when requesting this information:
AUDIT EXECUTION
employment site, how it manages social compliance and

• reason for the information request;
its performance against local and international labour
standards. The employment site is asked to respond to a • how the risk assessment fits within the audit process;
series of questions and provide supporting documentation.
• to whom to send the completed self assessment (or how to
The buying company may then use this information as
upload the self assessment on to a database);
the basis of a risk assessment. The auditor may also use
information from the self-assessment questionnaire to focus • timeframe for completion;
the on-site investigation on high risk areas.
AUDIT OUTPUTS
• process and timeframe for updating the self-assessment.
A Reference Self-Assessment Questionnaire is available in

Appendix 1.
GLOSSARY
APPENDICES

INTRODUCTION

2. AUDIT REQUEST
2.1 Launching the audit request
An audit request may be made by: • any other party with an interest in the commercial
AUDIT REQUEST
relationship and social performance of the employment
• the employment site;
site. For example, industry or monitoring bodies.
• the supplier;
Any company/organisation requesting an audit is termed an
• the buying company; ‘audit requestor’.
PREPARATION
2.2 Pre-audit employment site profile
When an audit request is made, the auditor should supply • the pre-audit employment site profile should be completed
the employment site with a pre-audit employment site and returned to the auditor two weeks from the date of
profile questionnaire asking for general information about the request being made;
AUDIT EXECUTION
location, size, workforce profile and production processes.
• if an audit is requested and scheduled in less than two
This information allows auditors to:
weeks, the auditor and employment site should work
• prepare relevant briefing materials (industry or country- together to ensure the pre-audit employment site profile
specific); is returned as soon as possible, and in any event before the
audit is carried out.
• plan the assessment, for example the gender and language
capabilities of the audit team members and the required A pre-audit employment site profile should have four main
number of auditor days (cf. 3.2.2 Audit length). areas:
AUDIT OUTPUTS
Each employment site to be audited should complete a pre- 1. supplier overview;
audit employment site profile. The information provided
2. employment site overview;
should be used by the auditor to make the necessary
preparations for the audit and may also be used during 3. employment site details;
audits to focus the auditor on high risk areas.
4. subcontracting activities.
The audit company should communicate the following
Where the employment site itself is the audit requestor, the
GLOSSARY
to each employment site to be audited and any relevant
auditor should ensure that an agreement is in place with
parties, such as agents, in the supply chain:
the employment site to allow the auditor to communicate
• the importance of accuracy in completing the pre-audit audit findings and any alert notifications to any customers
employment site profile; concerned.
APPENDICES
• timeframe for completion of the pre-audit employment

A Reference Pre-Audit Employment Site Profile is available
site profile;
in Appendix 2.
• to whom to send the completed pre-audit employment
site profile.
Recommended timeframe:
• the auditor should supply the pre-audit employment site
profile to the employment site within five working days of
the audit being confirmed;

INTRODUCTION
Background and context review

3. PREPARATION
Audit organisation
3.1 Background and context review

The auditing organisation or auditor must be fully aware of information on broader social, economic and political issues
AUDIT REQUEST
the conditions, challenges and issues prevailing in the country, affecting workers and the local community from a broad
region and industry where the audit is to be conducted. range of sources including governments and CSOs. This
The auditing organisation and/or the auditor should be in should include an understanding of what constitutes an
Communicating the audit arrangements
regular contact with local, relevant civil society organisations appropriate wage in the region that enables workers to meet
(CSOs) which are knowledgeable about the issues which basic needs and provides some discretionary income (for
affect workers in the country, region or industry concerned. example, this might be done by using the ‘basket’ technique,
CSOs may be NGOs, Trade Unions, academic institutions, e.g. total of different aspects of expenditure such as food,
PREPARATION
industry bodies, or any other relevant organisations. The clothing and housing).
auditing organisation or auditor should also regularly gather
3.2 Audit organisation

AUDIT EXECUTION
3.2.1 Audit type deceitful, that the auditor will not be able to gain access to the
Supplier preparation
facility and that the necessary information and personnel may

Audits should take place during a period when the
not be available on the day of the visit to complete the audit.
employment site is in full operation (such as peak production
or harvest). To minimise these risks, the buying company should clearly
communicate its policy on unannounced audits to suppliers
Audits may be:
and employment sites. The policy should state that:
AUDIT OUTPUTS
• unannounced (the employment site has no prior warning

of the audit); • audits may occur at any time on an unannounced basis;
• semi-announced (the employment site is aware that an • all employment sites are required to provide both pre-
audit will take place during a given time period, but the audit and self assessment information on a regular basis
actual date of audit is not communicated); and this information must be accurate;
• announced (at a mutually convenient date agreed with • auditors presenting the correct credentials should be
GLOSSARY
employment site). allowed full access to the employment site;
In all cases, the buying company should clearly communicate • the necessary records should always be kept on employment
its audit policy and process to suppliers and employment site or readily available (cf. 3.4 Supplier preparation).
sites as part of its commercial terms. The buying company’s Note: Whilst unannounced audits are extremely effective
APPENDICES
policy may include provision for all three types of audit at identifying an accurate picture of working conditions
under certain circumstances. at the employment site, and may help uncover high risk
The risk assessment process can be used to influence the issues, their use can undermine the relationships along the
type of audit selected. For example, the audit requestor supply chain, reducing the ability of the buying company to
may decide to execute semi-announced audits in all high remediate. The experience of many companies indicates
risk employment sites. However, other considerations such that unannounced audits should be reserved for due
as the relationship with the employment site should be diligence checks or to investigate specific issues (critical
taken into account since semi-announced and unannounced issues suspected, lack of commitment/involvement of the
audits can negatively impact supply chain relationships. suppliers, suspicion of fraud).
> Unannounced audits > Semi-announced audits

Unannounced audits allow auditors to assess the conditions Semi-announced audits reduce the risks to the commercial
at an employment site in their normal state, since the relationship and increase the ability of the buying company to
employment site has not had the opportunity to make remediate. Buying companies should clearly communicate their
any special preparations. However there is a risk that the policy on semi-announced audits to suppliers and employment
employment site will perceive unannounced auditing as sites. The policy should include the following points:

INTRODUCTION

• the buying company will specify a window during which an Workers should be interviewed individually and in groups
audit may take place. Audit windows may range between 2 and in formal and informal settings without management
Audit organisation
weeks and 2 months; present. Best practice is to interview some workers off-site,
where they may feel more able to speak freely about any
• all employment sites are required to provide up-to-date
concerns they may have. Workers should be interviewed
and accurate pre-audit and self assessment information at
preferably in their own language. In any event management
the beginning of the window;
or their representatives shall not act as interpreters.
• auditors presenting the correct credentials during the audit
Individual Interview should last at least 15 minutes and will
window should be allowed full access to the employment site;
AUDIT REQUEST
typically be expected to last 30 minutes.

• the necessary records should be kept at the employment
Longer interviews will be required in some circumstances,
site during the window.
including group interviews.
> Announced audits The challenges in identifying a representative sample makes
The right to perform an announced audit should be a normal it difficult to identify any hard and fast rule on audit length.
part of the commercial relationship. However there is a risk The minimum number of person days required for an audit is
PREPARATION
that employment sites may make special preparations for shown in the table below, however, a longer audit should be
the audit and best practice is to use a mix of announced, used if this guidance does not allow time for meaningful and
semi-announced and unannounced audits to mitigate this useful interviews to be carried out with the representative
risk. Buying companies should clearly communicate their sample outlined above or in the case of:
policy on announced audits to suppliers and employment • particularly large facilities;
sites. The policy should include the following points:
AUDIT EXECUTION
• multiple languages;
• the buying company will agree an audit date with the
employment site in advance; • off-site interviews;
• the employment site is required to provide up-to-date • issues requiring special investigation (e.g. discrimination);
and accurate pre-audit and self assessment information in • other unexpected issues.
advance of the audit;
In the case of agricultural businesses, consideration should
• auditors presenting the correct credentials on the date of the be given to the size and geographical spread of the business
AUDIT OUTPUTS
audit should be allowed full access to the employment site; and the number of growing locations to ascertain person
• the necessary records and the concerned personnel should days required.
be available at the employment site on the day of the audit. The auditor should interview a proportion of the workers
in each category of contract type. The number of workers
3.2.2 Audit length interviewed should, as a minimum, be equal to the square
root of the total number of workers in each category. This will
The number of auditor days at the employment site should
GLOSSARY
help to ensure that a more representative sample is picked.
be based on the size of the workforce. This will enable
sufficient time to interview a representative sample of the An example of how this would work is shown below:
size of the workforce and to check documents relating to the
sample. Sample size and composition is probably the most e.g. Site A - Workforce – 2,500 workers
controversial aspect of auditing methodology. The sample
APPENDICES
should reflect, as a minimum: CONTRACT NUMBER INTERVIEW

TYPE OF WORKERS SAMPLE SIZE
• the gender balance of the workforce. Where either men or
women workers form a very small minority it is important Permanent 2,225 48
that the audit team includes the minority in the sample;
Temporary 115 11
• the spectrum of ethnic, national, linguistic, migrant or
religious groups; Agency 160 13
• different contract types, for example permanent, temporary, Total 2,500 72
agency workers;
• different departments, including security and canteen
workers as well as production workers;
• different designations, for example rank and file workers
and supervisors.

INTRODUCTION

When selecting the worker interview sample for each category workers should be interviewed and the 48 workers that are
of workers, it is essential to ensure that it is representative of selected should be representative of all permanent workers.
Audit organisation
the make-up of the population it is being drawn from. For example if the permanent workforce is largely made up
of males and workers who speak a particular language then
This includes ensuring that samples are representative of
the sample should reflect this.
the gender, ethnic, national and linguistic balance of the
workforce as well as being representative of migrant or The minimum sample sizes and number of person days on-
religious groups, different department types and different site for audits is set out in the table below.
designations. In the demonstration above, 48 permanent
AUDIT REQUEST
Minimum worker interview sample size and person day requirements:
TOTAL MINIMUM INTERVIEW PERSON DAYS ON-SITE*

NO. EMPLOYEES SAMPLE SIZE
PREPARATION
1-20 4 1
40 6 1
60 7 1
80 9 1
AUDIT EXECUTION
100 10 1
200 14 2
300 17 2
400 20 2
500 22 3
600 24 3
AUDIT OUTPUTS
700 26 3
800 28 3
900 30 3
1,000 31 3
2,000 44 4
GLOSSARY
3,000 54 4
4,000 63 4
5,000 70 4
APPENDICES
6,000 77 5
7,000 83 5
8,000 89 5
9,000 94 5
10,000 100 5
*does not include preparation time, travel or report writing.

INTRODUCTION

3.2.3 Audit team
Audit organisation
The audit should be conducted by a competent social auditor, • reputation;
who may be self-employed or be employed by a commercial
• integrity;
organisation, NGO, Trade Union or industry body3.
• commitment to improving social compliance.
Auditors and auditing bodies should be chosen based on:
To prevent any conflict of interest, the auditor must not have
• audit training and skills1;
any connection with the employment site.

• audit experience;
AUDIT REQUEST
It is best practice for the audit team to be made up of at
• local and industry knowledge; least two people, one of whom is dedicated to conducting
worker interviews and carries out interviews throughout the
• language skills;
duration of the audit.
• gender and ethnic/national background reflecting that of
the workforce;
PREPARATION
3.3 Communicating the audit arrangements
3.3.1 Information for the employment site
AUDIT EXECUTION
The buying company and/or auditor should communicate • List of documents that the employment site will need to make
the following information at least 2 weeks before the audit. available to the audit team on the day of the audit, including:
This should be communicated in writing and in the relevant / employment site layout / floor plan;
local language.
/ company policies (including but not limited to child
• Confirmation of receipt of the Pre-Audit Employment Site labour, discipline, discrimination and harassment, Health
Profile and any further information required from the & Safety etc.);
employment site. / government inspection reports, e.g. sanitation, fire
AUDIT OUTPUTS
• Identity of audit requestor. safety, structural safety, environmental compliance, etc.;
/ procedures (e.g. grievance/complaints and disciplinary
• Information about the audit requestor’s approach towards
procedures);
social compliance and the code of conduct against which
the employment site is being audited. / evidence that procedures are followed;
/ collective Bargaining Agreements (CBA);
• Introduction of the audit team.
/ employment contracts;
• The audit agenda including:
GLOSSARY
/ recruitment procedure;
/ timetable;
/ personnel records;
/ topics to be covered.
/ employee handbook;
• Key personnel invited to participate in the audit, including / training records;
but not limited to:
APPENDICES
/ health and safety documents:

/ management; - hazardous chemicals list;
/ HR and Payroll personnel; - accident book;
/ health & Safety personnel; - chemical log;
- machinery inspection/service logs;
/ workers’ representatives.
- accident and injury log;
• Information which the employment site must communicate - emergency action procedures;
to workers before the audit covering workers’ rights and - evacuation plan;
entitlements, the audit process, purpose, ground-rules for - fire drill log;
worker interviews, confidentiality of worker interviews. - minutes of joint committees on health and safety;
3. GSCP has launched an Expert Working Group that works exclusively on auditor competence. Its role is to identify and gather best practice in that area in order to build reference
requirements for recognition of auditors and auditing bodies.

INTRODUCTION

/ payroll records for past 12 months: / minutes of meeting with workers representatives/unions;
- pay records for high and low points of the season; / minutes of meetings on disciplinary matters;
Audit organisation
- hours and/or attendance records;

/ insurance, tax and other required receipts;
- evidence that payments have been made;
/ permits, operating licences, Certificates of Operations,
/ piece rate records for the past 12 months (if applicable);
etc.;
/ time records for the past 12 months;
/ previous social audit reports/Corrective Action Plan Report.
/ production records;
AUDIT REQUEST
3.3.2 Sample audit agenda

CLIENT NAME AUDIT DATE(S) JOB N O
Employment site name and address

PREPARATION
DAY 1 – DATE
DURATION TEAM A - MEMBER: X TEAM B - LEADER: Y
Morning Opening meeting & plant tour

AUDIT EXECUTION
• Focus group interviews • Accounts Department

1. Child Labour and forced labour; - Document review: Time records,

2. Health & Safety, freedom daily job record, payroll records.
of association, discrimination. • Kitchen & canteen and dormitory
• One-to-one Interviews - Hygiene issues;
- Working hours, compensation; - Health and safety.
- Include workers’ representative
AUDIT OUTPUTS
if available.
Lunch time Lunch break / Auditors’ meeting
Afternoon • Employment site Tour • Administration Department

- Workshops, clinic & worker - Document review: Personnel record,
accommodation; Employment contracts, H&S records,
- Health and safety Employment site rules, Disciplinary
GLOSSARY
- Child labour and forced labour. practices.

• One to one interviews • Management Representative
- Security guard and workers. - Social accountability systems/policy;
- Control of suppliers/ subcontractors.
Clarification / Auditor meeting

APPENDICES
Closing meeting / End of the audit

INTRODUCTION

3.4 Supplier preparation
Audit organisation
Employment site management should ensure that: 3.4.1 Information for workers
• all documentation is available on the day of the audit. This Clear information about the audit should be communicated by
includes information and documents that are usually stored the employment site to workers explaining the purpose of the
at another location (e.g. a central office where payroll data visit and the process. This information should be available in the
is processed); principal languages spoken by workers and should include:
AUDIT REQUEST
• relevant personnel are at the employment site; • purpose and scope of the audit;
• supervisors and managers are instructed to allow • introduction to auditors and their role (emphasising they
unobstructed access to auditors. are independent and external);
• process including confidentiality of worker interviews;
• contact details for the auditor and for any whistle-blowing
facility supported by the audit requestor.
PREPARATION
Sample communication
On (insert date), representatives from (insert audit company) The visit will consist of meetings with management, a facility
will be visiting (insert employment site name) to assess inspection, document reviews, and worker interviews.
AUDIT EXECUTION
working conditions.
The purpose of the worker interviews is to help identify any
The representatives will be looking at the following areas: issues or good practice on-site. The interviews are strictly
confidential and the identity of workers who participate will
• management systems;
remain anonymous.
• forced, bonded, indentured and prison labour;
You may be selected by the audit team for individual and/
• child labour and young workers; or group interviews, or you may be asked questions by the
AUDIT OUTPUTS
representatives from (insert audit company) as they walk
• freedom of Association and the right to collective bargaining;
around (insert employment site name). The selection of
• discrimination, harassment and abuse; workers is based on a representative sample and you are not
required to participate in interviews.
• health and safety;
If you would like to get in touch with the representatives
• wages, benefits, terms of employment;
from (insert audit company) to discuss the audit or any other
• working hours. issues, please do not hesitate:
GLOSSARY
(Insert contact details of audit company)
APPENDICES

INTRODUCTION
Opening meeting

Employment site tour
4. AUDIT EXECUTION
The audit should include the following: • agreement of findings;
Interviews
• opening meeting; • off-site visits when necessary (e.g. to interview homeworkers;

in case a site has part of its operation carried on by a
• employment site tour (and optional perimeter survey);
AUDIT REQUEST
subcontractor or if there is no guarantee of anonymity for

• management and worker interviews; workers interviewed).
Document review
• document review; This chapter sets out best practice for each step of the audit.
• audit team pre-closing meeting; As a general principle, the conduct of the audit team at all
times must be in the best interest of the workers.
• closing meeting, including summary of findings;
PREPARATION
Alert notifications
4.1 Opening meeting

The opening meeting must be conducted in the language • request a list of workers who are scheduled to work that day
AUDIT EXECUTION
spoken by management. It should be attended by relevant together with any details that may be required to ensure a
people including: representative sample can be chosen for interview (such as
Audit team pre-closing meeting
gender, nationality, contract type);

• senior management;
• confirm the structure of the worker interviews and the
• managers responsible for key functions;
availability of an appropriate space where they will be
• Trade Union or worker representatives. conducted;
This should be formally presented in a format agreed with the • confirm any special arrangements/ precautions required
AUDIT OUTPUTS
audit requestor to ensure the audit requestor’s perspective for the employment site tour;
is clearly communicated in an appropriate tone.
• confirm permission to take photographs;
In the opening meeting, the audit team should:
• agree process for communicating issues as they arise during
Closing meeting
• introduce the audit team; the audit. It is best practice to communicate issues as they
arise to build consensus around findings and corrective
• explain the purpose and scope of the audit, including:
actions and allow management to:
GLOSSARY
/ potential benefits to the employment site (opportunity

/ provide additional evidence where necessary;
for management to identify and manage risk, opportunity
to engage in continuous improvement, opportunity to / address issues immediately;
meet customer needs etc); • confirm the importance of attendance at the closing meeting
/ clarify that the purpose of an audit is continuous and ensure that all key personnel can attend;
APPENDICES
improvement;
• provide an opportunity for questions and to address concerns.
/ the standard against which the audit will be conducted
(code of conduct, applicable law, international law, Note: If employment site management does not agree to
collective agreement when relevant, whichever affords the participation of worker representatives, auditors should
the highest level of protection); note this and arrange a separate meeting with worker
representatives.
• explain that the minimum requirement is transparency;
• outline the audit process;
• review the information provided in the pre-audit employment
site profile (including previous corrective action report and
follow-up actions);

INTRODUCTION
Opening meeting

4.2 Employment site tour
4.2.1 Process • cross-check whether all processes necessary for the
production of finished produce are carried out in-house, at
The purpose of the employment site tour is to enable the
the employment site or whether there are indications that
audit team to observe the physical conditions and current
some operations may be sub-contracted to other units;
practices in all areas of the employment site and to form
Interviews
a view of how physical conditions measure up to the audit • observe management systems and practices, including
requestor’s policy, applicable codes of conduct, legal and atmosphere between management and workers.
AUDIT REQUEST
regulatory requirements and any other requirements.
The team should raise issues as they arise during the
Document review
The findings from the tour are triangulated with evidence employment site tour, giving managers the opportunity
from management and worker interviews and document to seek clarification, respond, and provide explanations or
review. further evidence.
As a general principle, the auditor should be able to visit all The auditor should focus on:
the areas of the employment site and should set the pace
PREPARATION
• work environment (space, temperature, tidiness, etc.);
of the tour. However, in some cases, employment sites
Alert notifications
may prohibit visitors from walking unaccompanied through • work stations (space provided, chairs for pregnant workers,
employment site production areas or forbid photography for etc.);
reasons of safety or commercial confidentiality.
• fire equipment and emergency equipment;
The auditor should note restrictions on access or photography
• machine protection and maintenance;
AUDIT EXECUTION
in the audit report, and if restrictions seem unreasonable
should escalate according to the audit requestor’s policy. • emergency procedures;

Auditors should make every effort to ensure production is not • personal protective equipment;
disrupted during the employment site tour, whilst ensuring
• first aid equipment;
that they are able to view the production area during busy
production periods. It should be possible to move around • hazardous substances storage, handling and disposal;
the site without delaying or halting production.
• waste management;
AUDIT OUTPUTS
The ability of management to continue production at the site
during a visit is crucial to gaining an accurate idea of working • toilets and sanitation;
conditions and to securing management co-operation for • potable water;
the remainder of the visit. Auditors should keep this in mind
Closing meeting
during the site tour. • canteen hygiene and safety when applicable;
In order to achieve this, the auditor should for example: • dormitory hygiene and safety when applicable;
GLOSSARY
• ask that they be accompanied by only one or two people; • young-looking workers;
usually the site or H&S manager; • indications of restrictions of workers’ freedom of movement;
• be aware of site traffic; • indications of infringements of workers’ dignity;
• avoid walking where workers are trying to move or • selection of individual workers for interviews on the spot,
APPENDICES
transport product from one area to another. at the production location or close-by, or for subsequent
The audit team should walk around the employment site, interview sessions;
production areas, storage rooms, despatch areas, workers’ • quality records;
canteen, kitchen, and if present housing, crèche and medical
facilities and all other areas with managers in order to: • production records;
• understand the work done at the employment site; • time records;
• evaluate health and safety practice; • display of codes of conduct or labour law;
• identify potentially vulnerable groups of workers; • display of information relating to Trade Union or workers
committee meetings;
• note other physically observable evidence that relate to
other areas of the standards; • any indications of discrepancies between employment site
operations and the protection of workers’ rights.

INTRODUCTION
Opening meeting

4.2.2 Optional perimeter survey

A perimeter survey can be useful to provide supplementary • local perceptions of the employment site (e.g. work
information about the employment site and its local context hours, labour issues, support for local community, waste
and to identify specific risk issues [see Section 3.1]. discharge, etc.);
Interviews
The perimeter survey should focus on: • other facilities located on the employment site property
(e.g. dorms, canteen, clinic, water treatment vs. external
• the surrounding environment (e.g. industrial park,
water discharge);
neighbourhood, business district, etc.) and its advantages/
AUDIT REQUEST
constraints; • the physical construction and layout of the employment

site (e.g. structures on the property, access to employment
Document review
• neighbouring facilities (e.g. hospitals, clinics, restaurants,

site via fences or gates, worker transport, exits off the
shops, recreation, fire protection, police, waste disposal,
grounds, etc.);
etc.);
• other production units within the employment site property
which are not part of the scope of the audit.
PREPARATION
Alert notifications
4.3 Interviews
Interviews with managers, Trade Union representatives • the interviewer should aim to talk to a wide range of workers
AUDIT EXECUTION
(and/or other workers’ representatives) and workers will including potentially vulnerable workers and those in less
take place on-site. However, it may be appropriate to carry skilled positions, taking into account:
out additional worker interviews off-site. / the gender balance of the workforce;
/ the spectrum of ethnic, national, linguistic, migrant or
4.3.1 Worker interviews religious groups;
Points raised by workers should be fed back as early as / youngest and oldest workers;
possible to members of the team carrying out management / different departments, including security and canteen
AUDIT OUTPUTS
interviews or document review to facilitate verification. workers as well as production workers;

Audit team members carrying out worker interviews / different designations, for example rank and file
must have the skills to make workers feel at ease. It is workers and supervisors;
Closing meeting
best practice to use interviewing techniques to encourage / worker representatives;

interviewees to identify the issues of most importance to / health and safety committee representative(s);
them, and to uncover hidden issues such as discrimination
/ new employees / trainees (to evaluate training quality);
and intimidation. In any case, the interviewer should use
GLOSSARY
appropriate body language (e.g. avoid sitting behind a desk, / workers in all pay grades (i.e. lowest pay grades, highest
make regular eye contact, smile, etc.). pay grades) in order to evaluate wages and working hours;
/ pregnant women;
Selection:
/ employees from different shifts;
• the worker interview sample size should be based on the
APPENDICES
/ workers not wearing uniform;

different numbers of permanent, temporary and agency
workers as outlined in the methodology in section 3.2.2; / workers who have taken leave recently.
• workers within the three contract type categories should Location:

be randomly selected by the audit team only and never
• formal interviews should take place in a quiet, private area
by management, from various locations around the
away from management offices with no representatives of
employment site, and, if possible, during various shifts;
management present;
• the audit team must keep control of the selection of
• informal interviews may also take place during the physical
workers, using a variety of selection techniques throughout
tour of the employment site, at lunch time or in breaks.
the audit;
Workers should be interviewed individually and in groups;
• the selection of workers should be done as late as possible
• other suitable locations, e.g. in workers homes or in local
i.e. just before the interview is due to take place, in order
shops and cafes used by workers;
to minimise the risk of workers being coached;
• interview approach and language;
• workers selected must be representative of worker type
and departments within the employment site;

INTRODUCTION
Opening meeting

• interview approaches should be appropriate for the local • confidentiality: No manager or representative of the
situation, ideally semi-structured interviews, focus groups, employment site, apart from the workers concerned,
ranking and/or other participatory tools should be used; should be present during any worker interview.
• in cases where there is a multi-lingual workforce, worker 4.3.1.1 Individual interviews
interviewers may work through a translator to access the
Interviews
views of workers from minority groups; Individual interviews are the most effective method for
gathering specific details about the work environment and
• translators should not be used to support interviews for discussing issues such as pay rates, management style,
with language groups which make up 50% or more of the
AUDIT REQUEST
discrimination, harassment, etc. Some workers feel more
workforce. In these cases, the worker interviewer must be comfortable talking about these issues on a one-to-one basis.
Document review
a native speaker of the language concerned;
Auditors should respond to any signals (verbal and non
•
translators must be independent of employment site verbal) from workers and may choose to convert an
management and must speak the language concerned. individual interview to a group interview or vice versa in
Prioritisation of workers: order to accommodate workers’ needs.
PREPARATION
• auditors must prioritise the protection of the workers 4.3.1.2 Group interviews
Alert notifications
interviewed;
Group interviews enable more rapid consultation with a
• auditors should ensure that problems raised by workers larger number of people. Some workers may be encouraged
are discussed with management in a non-attributable way. to talk more freely in the presence of colleagues. Group
Auditors must ensure that the comments they report cannot interviews can be useful at the beginning of an audit to
be traced back to an individual worker; gather information quickly to inform the audit process.
AUDIT EXECUTION
Group interviews are also effective for gathering data on

• auditors/worker interviewers should leave a contact
specific issues, and exploring the nature or scope of a finding
telephone number, preferably their mobile number and
in greater depth. Auditors should never use group interviews
their local office phone number, with all workers interviewed
to discuss personal issues such as an individual’s wages.
so that workers can alert the worker interviewer if there are
reprisals or intimidation;
• the auditor should keep a confidential note of who is being
4.3.2 Management interviews
AUDIT OUTPUTS
interviewed; The audit team should work through the relevant code
talking in depth to the managers concerned on each issue
• when workers raise issues which could be directly
area. Open questions and discursive interview techniques
attributable to one particular worker and/or could result in
should be used. It is important to talk to the senior managers,
reprisals against workers, these should be reported directly
Closing meeting
but also less senior managers who may have a different
to the audit requestor (where this is not the employment
perspective.
site itself) for advice on how best to handle the issue at
the closing meeting. If the audit requestor is not able to
GLOSSARY
give guidance before the closing meeting, the issue should 4.3.3 Administrative/clerical staff interviews
not be raised at the closing meeting [see Appendix 4
"Reference Alert Notification"]. The audit team should work with administration staff (such
as payroll clerks and welfare officers) combining interviews
In order to protect workers from retaliation, the names with document review. Management should not be present.
of workers involved in identifying an issue must never be
APPENDICES
divulged to the employment site, supplier or audit requestor.

However, in circumstances where the best interests of the 4.3.4 Union and workers representative
worker cannot be met without disclosure of information (for interviews
example, names of child workers who need to be removed The audit team should discuss with union and/or worker
from hazardous employment) the auditor will ensure that representatives their role at the employment site. Specific
such details as may be required to identify workers who attention should be paid to any training and support given
require immediate remediation are made known to the by the Trade Union, as well as the union representatives’
relevant parties, including customers of the site where knowledge of collective bargaining agreements and union
appropriate. procedures for worker participation. The auditor should gain
Interview Structure: an understanding how the Trade Union is organised at a local
level, its relationships with workers and management.
• introduction: The audit team should introduce themselves
and communicate the purpose of the audit. They should
assure interviewees that all information shared during the
interview will remain unattributed;

INTRODUCTION
Opening meeting

4.3.5 Homeworkers
Where an audit or a pre-audit employment site profile has where this is not possible, for example due to location
indicated that production processes are undertaken by constraints, then a separate audit of homeworkers and their
homeworkers, then the auditor should aim to ensure that working conditions should be conducted.
these workers are included in the audit process. In cases
Interviews
AUDIT REQUEST
4.4 Document review

Document review
In countries where there are data protection requirements interviews. Workers should be assured that they are able to
(e.g. all EU countries), auditors should obtain the written refuse permission to view their files if they so wish.
permission of workers to view personnel files during the
PREPARATION
Example data protection consent form:

Alert notifications
In order to administer your employment, your employer standards. As part of this review, (Insert Audit Company
collects and uses certain personal information (such as your Name) will need access to your personnel file.
contact details and pay records). This information constitutes
You have confirmed that you are happy for (Insert Audit
your personnel file.
AUDIT EXECUTION
Company Name) to have access to your personnel file for

(Insert Audit Company Name) has been engaged to review the purposes of the review.
the working practices of your employer for the purposes of

Please sign below to give your permission.
ensuring compliance with the (Insert Code(s)) about labour
4.4.1 Document sampling

AUDIT OUTPUTS
The documentation requested by the auditor should be • collective Bargaining Agreements (CBA);
available on-site, including payroll and records of time,
• employment contracts;
safety trainings, machinery maintenance, fire equipment
and hazardous materials. Auditors should request time • personnel records;
Closing meeting
and payroll records for 12 consecutive months [see Section

• employee handbook;
3.3.1]. If records for the previous 12 months are not available,
the employment site should explain why this is the case. • training records;
GLOSSARY
For example, the employment site has been operational • health and safety documents:
for less than twelve months. From the 12-month set of / hazardous chemicals list;
data, auditors should review at least three months’ worth
of consecutive records and should include records for the / accident book;
/ chemical log;
APPENDICES
low season, the peak season, holiday periods and the most
recent period available. / machinery inspection/service logs;
The auditor should go through a comprehensive document / accident and injury log;
trail including the following (this is not an exhaustive list): / emergency action procedures;
• employment site layout / floor plan; / evacuation plan;
• company policies (including but not limited to child labour,
/ fire log drill;
discipline, discrimination and harassment, Health & Safety / minutes of joint committees on health and safety;
etc.); • payroll records:
• government Inspection Reports, e.g. sanitation, fire safety, / pay records for high and low points of the season;
structural safety, environmental compliance, etc.; / hours and/or attendance records;
• procedures (e.g. grievance/complaints and disciplinary / evidence that payments have been made;
procedures);
• piece rate records (if applicable);
• evidence that procedures are followed;

INTRODUCTION
Opening meeting

• time records; 4.4.2 Document inconsistencies
• production records; Inconsistencies between different types of documents
• minutes of meeting with workers representatives/unions; and worker testimony should be considered a critical non-
compliance and raised with the employment site management
• minutes of meetings on disciplinary matters; as early as possible during the audit. Management should be
Interviews
• insurance, tax and other required receipts; encouraged to provide accurate records which present the full
picture of the employment site’s operations for review prior
• permits, operating licences, Certificates of Operations, etc.; to the closing meeting.
AUDIT REQUEST
Document review
• previous social trade audit reports/Corrective Action logs. If a non-compliance related to working hours or compensation
Particular emphasis should be placed on evidence that there requirements is identified, the audit team should identify
is a systematic approach to managing all aspects of the the context of the issue, and its frequency, the number of
relevant code. people impacted and the department(s) concerned both at
the closing meeting and in the audit report.
PREPARATION
Alert notifications
4.5 Alert notifications
Where a ‘critical’ non-compliance is identified, the auditor Auditors should prioritise the welfare of workers when
should, wherever possible, inform the audit requestor within deciding how to inform employment site management of
AUDIT EXECUTION
24 hours. If the audit requestor is on site, the auditor should any critical non-compliance. Auditors should follow the
communicate the critical non-compliance immediately. This escalation policies of the audit requestor to minimise any

will enable the audit requestor and the employment site to risk to workers.
work together to plan an appropriate and timely resolution
A description of how to evaluate non-compliances can be
to the issue.
found in paragraph “4.6.1 Non-compliances, Observations
If an auditor believes they might be at risk as a result of and Good Practices Evaluation”
communicating a critical non-compliance, the audit team
Examples of critical non-compliances can be found in the
should wait until it is removed from that situation before
AUDIT OUTPUTS
tables in “4.6.1.1 Categorisation Examples”.
issuing the alert notification.
A reference alert notification is available in Appendix 4.
4.6 Audit team pre-closing meeting

Closing meeting
GLOSSARY
The audit team should meet before the closing meeting • good practice examples;
to discuss the findings of the audit (interviews, document
• a prioritisation of issues;
checks, employment site tour) and identify inconsistencies,
non-compliances, observations, and good practice. The • any requests for additional information or evidence.
APPENDICES
analysis of evidence gathered is a pre-requisite to the closing

The reference Summary of Findings and Corrective Actions
meeting. It must be completed even if the auditor is alone at
(Appendix 7) has been designed to provide a structure to
the employment site.
the audit team’s findings and help the audit team develop a
The audit team should prepare for the closing meeting by corrective action plan and structure a closing meeting.
identifying and agreeing:
The reference Summary of Findings and Corrective Actions
• non-compliances found including: includes:
/ their status/severity (critical, major, minor); • audit findings: Summary of non-compliances, good practice,
/ specific evidence found; and evidence found;
/ recommended corrective actions, how these can be • classification of non-compliances;
verified, and a suggested timeframe for completion;
• reference to the applicable code of conduct and/or law
• systematic problems and issues from one-off, isolated, non- which has been contravened;
systematic issues;
• recommended corrective actions: Auditors suggestion on
• the root cause of problems, where possible; how the audit findings can be resolved;

INTRODUCTION
Opening meeting

• person/party responsible for corrective action; Non-compliances and observations should be classified
according to:
• verification method:
/ a desk-based follow up may be used to verify corrective • the frequency of the problem and whether the issue is an
actions for minor non-compliances but provide isolated occurrence;
less assurance than a follow-up audit. Desk-based
Interviews
• the potential severity of the problem;

verification should check corrective actions through
photos, copies of certificates, invoices, etc. submitted • the probability of recurrence;
by the employment site. Desk-based follow-up cannot
• the management system in place;
AUDIT REQUEST
be used where actions need to be verified through

Document review
worker testimony; • the response of the management.

/ follow-up audit are recommended for critical or major A minor non-compliance is:
non-compliances or when corrective actions can be
evaluated only through interviews and extensive • an occasional or isolated problem;
documentation reviews [see Section 5.4.1 for guidance • an issue which presents a low risk to workers/those on-site;
on conducting follow-up audits];
Alert notifications
PREPARATION
• a policy issue or misunderstanding where there is no

• timescale for completion: the amount of time required for evidence of a material breach.
the issue to be closed. The time allocated for corrective
actions to be completed should be appropriate, realistic and A major non-compliance is:
timely. • a breach which represents a danger to workers/those on-site;
The Summary of Findings and Corrective Actions should: • a material breach of a code requirement/law. A systematic
AUDIT EXECUTION
• be clearly described and presented in both English and the violation of a code requirement/law.
language spoken by the employment site management; A critical non-compliance is:
• be distributed as follows: • an issue which presents imminent risk to workers’ safety/
/ one original, signed copy for the employment site risk to life and limb or constitutes a significant breach of
manager; workers’ human rights, and/or;
/ a second original, signed copy retained by the auditor • a major non-compliance that has not been addressed or for
AUDIT OUTPUTS
together with other audit documentation; which no significant improvement has been made by the
/ a hard or soft copy to the audit requestor. time of a follow up audit, in spite of supplier commitment
to resolve the issue;
4.6.1 Non-compliances, observations • an attempt to pervert the course of the audit through fraud,
Closing meeting
and good practice evaluation coercion, deception or interference.
Auditors should classify non-compliances, observations and Critical non-compliances include:

GLOSSARY
good practice examples to indicate the relative importance • inconsistencies between different types of documents and
of each. worker testimony [see Section 4.4.2];
Follow-up audits are recommended for critical or major non- • child labour (reported or confirmed through documentation);
compliances or when corrective actions can be evaluated
APPENDICES
only through interviews and extensive documentation • involuntary, indentured, or involuntary prison labour
reviews [see Section 5.4.1 for guidance on conducting (including forced overtime and absence of payment);
follow-up audits]. • workers subjected to physical abuse;
Non-compliance can be categorised as: • workers subjected to sexual harassment or abuse;
• minor non-compliance; • workers in immediate danger;
• major non-compliance; • workers not being paid at all;
• critical non-compliance. • workers subjected to discriminatory practices (e.g. during
Auditors can also note Observations and instances of Good recruitment, workers are tested for medical conditions
Practice. not required by law or product safety requirements, e.g.
pregnancy, HIV/AIDS, hepatitis etc.);

INTRODUCTION
Opening meeting

• union members, union or worker representatives are A good practice example is:
actively harassed, penalised or discriminated (directly or
• an issue that the auditor feels is over and above the standard
indirectly) against;
against which the employment site was audited.
• attempted bribery;
The auditor must be able to justify his/her classification with
Interviews
• auditors denied access or obstructed from conducted from detailed evidence.
conducting a proper audit;
4.6.1.1 Categorisation examples
• evidence of the deliberate provision of false information to
AUDIT REQUEST
auditors so as to disguise unfair labour conditions. The below provides guidance on how to categorise different
Document review
issues as good practice or minor, major or critical non-
Critical non-compliances should trigger an alert notification compliances. The list is not exhaustive but should give an
[see Section 4.5]. indication of how various issues should be considered in
An observation is: light of the Reference guidelines and the Reference code.
These examples are for illustration only; auditors should still
• the identification of an opportunity for improvement; use their discretion when classifying non-compliances.
Alert notifications
PREPARATION
• a possible issue which may develop into a non-compliance
without further action;
• an issue which the auditor has some evidence to indicate may
be present, but is not confirmed by more than one data point.
AUDIT EXECUTION
Management systems
Good Practice Employment site policies and procedures are regularly reviewed, in consultation with internal
and external stakeholders, to ensure that they meet international fair labour standards.
Management communicates the requirements of international labour standards to subcontractors,

and requires them to work to adhere to them.
AUDIT OUTPUTS
Management have implemented an auditing programme and audit all suppliers, subcontractors
and labour providers.
Minor Non-Compliance The employment site’s fair labour policies and procedures have not been communicated to workers.
Closing meeting
There are no relevant written policies or procedures at the employment site, but working
practices are in line with international standards.
GLOSSARY
Major Non-Compliance Management does not keep a list of and the contracts with sub-contractors and suppliers.
There are no policies and procedures at the employment site, and conditions are not in line with
international standards.
APPENDICES
Critical Non-Compliance Management openly flouts the law despite knowledge of their responsibilities.
Management attempted to bribe the auditors.
False records were provided to the auditors or management refuse to give true records to auditors.

INTRODUCTION
Opening meeting

Forced, bonded, indentured and prison labour
Good Practice The employment site works with the government on a scheme for the rehabilitation of offenders,
employing prisoners to build their skills before release.
Employee handbooks explain the process for workers to give notice if they wish to leave employment.
Interviews
Workers interviewed are able to describe the process for giving notice.
Workers have access to no-interest loans. Where used, workers have agreed loan amounts and
AUDIT REQUEST
repayment terms in writing, have a copy of their agreement, and workers clearly understand the
Document review
repayment terms and conditions.
Minor Non-Compliance The process for workers to give notice is not effectively communicated in a language workers
understand or a mechanism they can access.
A handful of personnel files do not contain evidence of workers’ written consent to deductions.
Alert notifications
PREPARATION
Monetary deposits are taken from workers (e.g. for accommodation or PPE).
Major Non-Compliance Prisoners work voluntarily, but are not paid at least the legally applicable wage for all hours worked.
The employment site restricts the movement of workers (e.g. workers cannot go to the toilets
freely; workers cannot take their rest breaks; gate passes, toilet cards, aggressive prevention
AUDIT EXECUTION
of movement, intimidation). This is valid for both the employment site and/or dormitory areas.
Unreasonable notice requirements or financial penalties for leaving. (e.g. the final payment
for workers who leave employment is withheld for one month before being paid).
Deductions not stipulated in law take workers below the legal minimum wage.
Critical Non-Compliance Prison workers (or any other worker) have no choice about whether they work or not.
AUDIT OUTPUTS
Workers are working to pay off a debt to their employer and have no choice about their work
and/or feel unable to leave.
Workers are unable to leave employment because their deposits or other money they are owed
are withheld, or because management refuses to give workers their original identity papers.
Closing meeting
Workers are not paid at all.

GLOSSARY
APPENDICES

INTRODUCTION
Opening meeting

Child labour
Good Practice The employment site has a robust age verification process, including stringent checks
on the validity of documentation and a requirement for two forms of photo ID.
Young workers are registered with local authority where required by local legal requirements.
Interviews
Management takes steps to ensure suppliers are aware of child labour policies and carries out
regular checks on supplier sites to ensure that there are no children employed.
AUDIT REQUEST
The employment site has a robust young worker management system in place, which ensures
Document review
that young workers do not work in hazardous positions, at night or longer than they are supposed
to as specified by the law.
Minor Non-Compliance A handful of personnel files do not contain a copy of country appropriate age verification
documentation.
Alert notifications
PREPARATION
The personnel files of young workers do not contain written consent from a parent or guardian
(if required by law).
The employment site has no formal policy on child labour.
Major Non-Compliance Management do not know the minimum legal working age in their country and/or how to verify
age of workers.
AUDIT EXECUTION
The employment site does not have any age verification process when recruiting new workers.
Critical Non-Compliance The employment site consciously employs child labour and is complicit in forging documents.
Child workers have presented fake ID cards during the recruitment process and employment site
failed to spot them.
AUDIT OUTPUTS
There are one or more children working at the employment site.
Young workers engage in hazardous, night or overtime work.
The employment site refuses to engage in a proper remediation programme for child labourers.
Closing meeting
GLOSSARY
APPENDICES

INTRODUCTION
Opening meeting

Freedom of association and the effective recognition of the right to collective bargaining
Good Practice Management pays representatives for the time they spend carrying out their representative
functions.
Worker representatives are allocated time every month to discuss union matters with union
Interviews
members. This is over and above normal union commitments.
Management actively engages in day to day conversations with workers to understand their needs
and suggestions.
AUDIT REQUEST
Document review
The union (or parallel means) has been effective in defusing disagreement between workers
and management. They have successfully negotiated conditions that are over and above legal
and industry norms.
Minor Non-Compliance Workers do not have a copy of their union dues deduction agreements but workers report knowing
about these deductions and have given their written consent for these deductions to be taken.
Alert notifications
PREPARATION
Management sometimes postpones Trade Union meetings during peak production periods.
The employment site does not provide union representatives with adequate facilities for them
to carry out their activities.
Workers are unaware of how to raise issues with management or they are unaware of who their
AUDIT EXECUTION
representatives are.
Major Non-Compliance Information relating to collective bargaining agreements is not circulated to workers. Management
does not permit union/committee notices to be posted publicly on notice boards.
Management does not restrict the activities of Trade Union representatives, but do not pay them
for reasonable time spent on union activities.
Management does not allow regular Trade Union meetings to be held.

AUDIT OUTPUTS
The employment site does not comply with collective agreements.
Collective Bargaining Agreements are not confirmed in writing.

Closing meeting
Critical Non-Compliance Management prevents workers from organising themselves.
Membership of Trade Unions is prohibited and/or workers are prevented from becoming members
GLOSSARY
of a union.
Management actively harasses, penalises or discriminates (directly or indirectly) against union

members, union or worker representatives.
APPENDICES

INTRODUCTION
Opening meeting

Discrimination, harassment and abuse
Good Practice Workers’ contracts of employment confirm that all workers in the same roles are engaged under
the same terms and conditions. (e.g. equal pay for roles of equal value).
Full explanations of all policies are available to all workers in relevant language(s).
Interviews
Workers understand the discipline and grievance procedures of the employment site and report
that they are fair and easy to access.
AUDIT REQUEST
When observing interaction between workers and workers and management, there is a supportive
Document review
atmosphere. Workers are supported to improve their performance in a helpful manner.
Workers think that promotion is possible and open to all. They can provide examples of where
this has happened in the past.
Minor Non-Compliance The employment site does not have written policies on discrimination, harassment, or abuse.
Alert notifications
PREPARATION
Discipline and/or grievance procedures are not communicated to workforce.
Management and/or supervisors do not understand/follow the discipline and/or grievance procedures.
Major Non-Compliance Workers feel discriminated against by management and/or other workers.
AUDIT EXECUTION
Workers are shouted at by management.

Management uses fines as a disciplinary measure.
Critical Non-Compliance There is evidence of sexual, physical or verbal abuse.
Discrimination in recruitment is practiced e.g .age, caste, disability, ethnic and/or national origin,
gender, membership in unions, political affiliation, race, religion, sexual orientation, marital status,
family responsibilities, social background.
AUDIT OUTPUTS
During recruitment, workers are tested for medical conditions not required by law or product safety
requirements, e.g. pregnancy, HIV/AIDS, hepatitis etc.
Workers are dismissed when they become pregnant.
Closing meeting
Workers are subject to different treatment and/or terms and conditions and/or different working
conditions based on criteria which do not relate to skill or merit e.g. age, caste, disability, ethnic and/
GLOSSARY
or national origin, gender, membership in unions, political affiliation, race, religion, sexual orientation,
marital status, family responsibilities, social background or other personal characteristics.
APPENDICES

INTRODUCTION
Opening meeting

Health and safety
Good Practice Management provide health and safety training for all workers both on the employment site
and those engaged in work on other sites on behalf of the employment site.
Management takes steps to prevent accidents before they happen. Use H&S information to refine
Interviews
systems and take action to improve overall process.
The employment site has a functioning H&S committee with a high proportion of workers, which
meets regularly with management and is very effective in managing H&S on site.
AUDIT REQUEST
Document review
Health and Safety training is conducted for all new workers, and repeated periodically for all
workers to ensure that they are aware of risks, changes to their working environment or new
requirements.
Minor Non-Compliance Fire/Emergency Evacuation

• Evacuation plans are not posted for workers to see.
Alert notifications
PREPARATION
• Incomplete/absent records from fire evacuation drills in factory and/or accommodation.

• Fire extinguishers are not installed at correct height/other non-functional requirements are
not met.
Housekeeping
• Poor or inadequate lighting in production or other areas.
AUDIT EXECUTION
• Inadequate and/or unhygienic facilities for washing and/or drying hands.

• No testing of water potability.
• Isolated failures to carry out medical examinations.
Accommodation / Canteen
• Isolated failures in maintenance in accommodation.
• Insufficient seating in canteen/dining area.
AUDIT OUTPUTS
…
Closing meeting
GLOSSARY
APPENDICES

INTRODUCTION
Opening meeting

…
Major Non-Compliance Chemical Handling
• No training on safe use and/or safe handling of chemicals.
• Unsafe practice when handling chemicals.
Interviews
• No process in place to ensure vulnerable workers such as young workers or pregnant women
are not working with or in vicinity of chemicals.
PPE
AUDIT REQUEST
Document review
• Management do not provide the correct PPE to workers.
• Workers do not have or do not always wear the correct PPE for the work, chemicals and machines
that they are using.
Fire/Evacuation
• Emergency escape routes are not clearly signalled.
Alert notifications
PREPARATION
Housekeeping
• Inadequate extraction in areas where chemicals are used.
• Extremely bad ventilation, air conditioning or lighting in any part of the production area.
• Toilets are not hygienic and/or are not cleaned on at least a daily basis.
Canteen
AUDIT EXECUTION
• Canteen and/or food storage is unhygienic.
• Canteen/kitchen employees have not had appropriate health checks and/or obtained appropriate
hygiene certificates.
First aid
• First Aid boxes not freely accessible and/or not appropriately/adequately stocked.
• There is no member of staff trained in administering basic first aid.
AUDIT OUTPUTS
Training
• Lack of appropriate training on safe use of equipment or handling of loads.
• No senior manager designated with responsibility for health and safety.
Closing meeting
Critical Non-Compliance Fire/Emergency Evacuation
• There are less than 2 accessible, unlocked and unblocked fire exits on each floor.
GLOSSARY
PPE/Machinery
• Machinery / equipment do not have the required safety guards and pose a direct threat to workers’
lives or limbs.
• The employment site requires non-refundable monetary deposits from workers to get their job,
APPENDICES
protective equipment, training or other items.
Canteen
• Accommodation is unsafe and poses immediate risk to workers’ lives or limb.
Housekeeping
• Dangerous storage of production materials causing any risks to workers’ lives or health.
• No access to potable water.
Others
• Premises are not structurally safe.

INTRODUCTION
Opening meeting

Wages, benefits and terms of employment
Good Practice Workers are paid regularly, at least once per month and in line with their contract of employment.
Work outside normal hours (e.g. at night or at weekend) is paid a premium over and above local
law and/or industry requirements.
Interviews
Workers are paid above legal requirements and industry standards.

Workers are able to significantly increase their earning potential through a production bonus
AUDIT REQUEST
or other bonus scheme.

Document review
All workers have a signed copy of their contract of employment and this reflects how their terms
and conditions operate in the place of employment.
The contract is written in their native language and details their regular hours, remuneration,
notice period and all other applicable terms and conditions.
Alert notifications
PREPARATION
Minor Non-Compliance Workers are dependent on overtime pay to achieve total take-home pay that allows them to meet
their basic needs and provides some discretionary income.
Workers have a copy of their contract, but do not understand some of the key applicable terms
and condition.
Individual payroll records are missing or incomplete (assuming this is due to human error rather
than falsification or hiding of records).
AUDIT EXECUTION
Workers report that mistakes in their pay packages are common, but they are rectified quickly.
Major Non-Compliance Workers on probation or trainees are kept in these positions for prolonged periods to prevent them
being paid the same as their permanent or qualified counterparts.
Workers are fired and re-hired, or kept on temporary or agency contracts in order to avoid
providing them with employment rights under the relevant national law.
AUDIT OUTPUTS
The employment site requires monetary deposits from workers to get their job, protective
equipment, training or other items.
Workers were not provided with a copy of their contract of employment or are not clear on what
their terms and conditions are.
Closing meeting
Wage slips do not detail rates payable, number of hours worked (standard and overtime) and any
deductions.
GLOSSARY
Wage slips are not in a language workers understand.

Legal overtime premiums are not paid to workers.
Workers are not participating in all benefits schemes required by law.
APPENDICES
Late payment of wages for some or all workers.

Workers report that mistakes in their pay packet are common, and they are difficult to rectify
and/or it takes a long time.
Workers are underpaid for the time that they have worked (i.e. overtime).
Critical Non-Compliance Workers have unauthorised or illegal deductions made from their wages.
Money is deducted from workers for payment of social insurance premiums, but the company
does not pay the premiums into the workers’ fund.
Workers are not paid at all.
There is verifiable evidence that records have been falsified.

INTRODUCTION
Opening meeting

Working hours
Good Practice The employment site has a robust system for recording working hours and uses this information
to monitor and control overtime.
Workers always receive the legally mandated number of rest days in a period.
Interviews
Workers are able to earn above minimum and/or industry standards whilst hours are controlled
within legal requirements.
AUDIT REQUEST
Though there are still challenges with controlling overtime within legal limits, management
Document review
are improving productivity and HR systems to begin to reduce working hours.
Minor Non-Compliance Rest days are occasionally cancelled due to production back-logs.
There are minor gaps in time records.
There is no clear policy on overtime working.
Alert notifications
PREPARATION
Overtime exceeds 12 hours per week, or relevant legal limit, in isolated cases.
Major Non-Compliance Workers ability to take paid leave is restricted or non-existent.

Workers do not receive the legally mandated breaks during their working shift.
Workers are required to use a toilet card system or other restrictions are imposed on them in order
AUDIT EXECUTION
to take a toilet or other kind of break.
Working hours (including all applicable overtime) regularly exceed the legal limit or the code
of conduct maximum (whichever provides the greater protection).
Workers are not able to take public or national holidays off work and are not provided with
compensatory rest.
AUDIT OUTPUTS
Critical Non-Compliance Management refuses access to true hours records.
There is verifiable evidence that records have been falsified.
Closing meeting
Overtime is compulsory.
Workers work excessive hours that pose a direct risk to their health and safety.
Workers do not consistently receive at least one rest day in seven.
GLOSSARY
4.7 Closing meeting
APPENDICES
The purpose of the closing meeting is to go through the • answer any questions management have;
findings, agree them and agree the corrective action
• explain when the full report will be completed and who it
plan which sets out areas for improvement, actions and
will be sent to;
timeframes. Corrective actions should focus on long term
sustainable solutions which take account of the root cause of • get sign-off on the Summary of Findings and Corrective
any problem. This meeting should involve all those attending Actions by both auditor and factory;
the opening meeting and should: / a copy should be left with management leave a copy of
• reconfirm the purpose of the assessment; the corrective action plan;
/ the corrective actions should include a timeframe for
• recognise good practices;
completion and the type of verification needed;
• agree any non-compliances;
• if the Summary of Findings and Corrective Actions is not
• suggest corrective actions, timing, and responsibility (with agreed, the auditor should leave a copy with the factory
management); and report disputed points to the audit requestor, copying
the factory.
• record non-compliances which can be corrected immediately;

INTRODUCTION
Audit report

Supplementary audit information
5. AUDIT OUTPUTS
5.1 Audit report
The context, findings, issues and actions against each area The report should include photos of the employment site
Information management
AUDIT REQUEST
of the audit standard used should be reported to the audit such as:
requestor. A reference audit report is provided in Appendix 5.
• outside general overview;
The report should be available in English to ensure that it
• inside general overview;
can be shared with various stakeholders, as well as in the
language of the management wherever this is possible. The • various stages of the manufacturing process;
report should be delivered to the audit requestor within 10
• safety equipment;
business days of the audit.
PREPARATION
• machines guards;
Audit follow-up
For each provision of the audit standard, the report should

set out: • drinking water;
• description of the current situation, including how specific • first aid equipment;
requirements are managed by the employment site;
• break room / staff room;
AUDIT EXECUTION
• provide evidence and information to substantiate the findings;

• toilets and showers as applicable;
• for each non-compliance or observation, the report should
• dormitories where applicable;
provide a:
/ description of the non-compliance or observation, its • canteen where applicable;
frequency and the number of people concerned; • kitchen where applicable;
/ evidence found to substantiate it;
• best practices which can be photographed;
/ classification to applicable law, code of conduct, etc.;
AUDIT OUTPUTS
/ recommended corrective action with a timeframe for • non-compliances which can be photographed.
completion, responsibility and verification method
required. A Reference Audit Report is available in Appendix 5.
The report should not include any information that could Unless agreed by all parties in writing, the audit organisation
be used to identify specific workers – such as names, ID will not distribute the report to any entities except the audit
numbers, job descriptions and/or work location. However requestor.
GLOSSARY
the exception to this requirement is where the best interests

of affected workers (i.e. working children) are served through However, the audit requestor should share the report
disclosing their identities. with the employment site/customer/supplier as soon as
possible in order to facilitate co-operation on continuous
Where it is imperative to pass on the identity of a worker in improvement.
APPENDICES
order to guarantee their welfare, this should be done using the

Reference Supplementary Audit Information, Appendix 6.

INTRODUCTION
Audit report

5.2 Supplementary audit information
Auditors may feel the need to produce a separate, • if management was obstructive or reluctant to accept
supplementary report for the audit requestor containing: findings and the need for remediation;
• information too sensitive for the audit report; • where the auditor has concerns about the possibility of
double books or falsified records;
• concerns which cannot be substantiated through evidence
and/or interviews; • where sensitive issues could not be discussed during the
AUDIT REQUEST
closing meeting because of a potential risk to workers’
• attitude of management towards the non-compliances or
wellbeing.
the audit process as a whole.
This type of report may not be appropriate where the audit
Supplementary reports may be appropriate:
requestor is the employment site itself.
• if workers appear to be under undue pressure from
management on the day of audit; A Reference Supplementary Audit Information is available
in Appendix 6.
PREPARATION
• if workers appear to have been coached;
Audit follow-up
5.3 Information management
AUDIT EXECUTION
Within 10 days of the completion of each audit, the auditor 5.3.1 Audit records
should provide the following documents to the audit
All documents, hand written notes, signed Summary of
requestor:
Findings and Corrective Actions and audit report should be
• the Pre-Audit Employment Site Profile; retained by the auditor for reference for at least five years.
• the completed audit report, including photos; It is recommended that the auditor retain copies of at least
the following documents:
• summary of findings and corrective actions;
AUDIT OUTPUTS
• official documents on legal status of the company (business
• supplementary audit information where applicable;
licence);
• copies of any alert notification that were issued during the
• insurance policies/certificates (relating to buildings and
audit.
people);
The auditor or audit organisation should:
• blank Employment contracts (at least in blank format);
• be available after the audit to further clarify or explain
• payroll sample (at least in blank format);
GLOSSARY
decisions and ratings to the employment site and/ or audit
requestor as needed; • risk assessments employment site;
• have an appeals procedure should the employment site or • collective bargaining agreement;
audit requestor challenge one of the findings and in case of
• evidence relating to non-compliances, wherever possible.
any complaint by the employment site against the auditor.
APPENDICES
If copying facilities are not available, auditors may photograph

these documents.
Data and privacy laws in some countries prohibit copies
being made of certain documents; in such cases, auditors
should respect these restrictions.

INTRODUCTION
Audit report

5.4 Audit follow-up

The audit follow-up focuses on the corrective actions agreed Follow-up Audit Guidance:
during the audit and closing meeting.
• the audit should be carried out once the deadline for
• the auditor will be responsible for verifying whether actions addressing all of the issues has passed;
have been taken and recording verification of actions;
• follow-up audits generally take place within six months of
• for corrective actions where desk-based verification is the date of the initial audit;
AUDIT REQUEST
adequate, the auditor will review evidence submitted [see

• a follow-up report should be issued. This is an updated
Section 4.6];
version of the original report, with all new issues and
• where a follow-up audit is required, for example on issues updates to previous issues clearly highlighted;
surrounding working hours and wages or where the original / for all sections where non-compliances have previously
issue was raised by workers, the length of time taken at the been raised there should be a clear explanation of the
follow-up should be related to the number and severity of evidence reviewed, comments on applicability and
issues to be verified.
PREPARATION
effectiveness and whether the issue is now considered

Audit follow-up
If one person is carrying out both the auditor and worker closed or remains open;
interviewer roles at the follow-up audit, person must be of / improvements should be mentioned even if the non-
the same gender as the majority of the workforce. compliances are not fully corrected;
/ if new non-compliances are found these should be
5.4.1 Follow-up audits recorded and marked as “new” and should be reported
AUDIT EXECUTION
in as much detail as they would have been in the initial

Follow-up audits are recommended for critical or major non- report;
compliances or when corrective actions can be evaluated
/ a desk-based follow up may be used to verify corrective
only through interviews and extensive documentation
actions for minor non-compliances but provide
reviews.
• a full follow-up audit should include a full review of all verification should check corrective actions through
areas of the standard audit process, including the complete photos, copies of certificates, invoices, submitted by
the employment site. Desk-based verification cannot
AUDIT OUTPUTS
re-sampling of documents, conducting interviews and

the employment site tour. The auditor should focus on be used where actions need to be verified through
identifying changes which would address issues raised in worker testimony.
the initial report, but also investigate potential additional
issues;
• a partial follow-up audit does not include a full review
but only focuses on the issues identified in the corrective
GLOSSARY
action plan.
APPENDICES

INTRODUCTION
Glossary
of Terms
AUDIT REQUEST
A
PREPARATION
Agency worker Code of conduct
Agency workers are workers that are employed by an A set of standards concerning labour practices adopted by a
employment agency but that undertake work for one of company and applied to its suppliers, employment sites and
the employment agency’s clients (e.g. an employment subcontractors.
AUDIT EXECUTION
site). Agency workers are paid by the employment agency
and the labour user (e.g. the employment site) will pay the Comply / compliance
employment agency a fee for the use of its workers.
To meet local labour laws and regulations, applicable codes
Announced audit of conduct and international labour standards requirements.
An audit which is undertaken on a specified date that is Corrective action

chosen in agreement with the employment site.
AUDIT OUTPUTS
Measures taken to eliminate a non-compliance identified
Audit requestor during an audit.
Generic term referring to any entity that has requested and Corrective Action Plan
commissioned an audit, including the requesting entity’s
customers (where known) where agreements allowing such A plan of action drawn up at the end of an audit that records
disclosure are in place.
GLOSSARY
what measures have to be taken and within what time limit
to remedy the non-compliance.
C
Casual worker E
APPENDICES
Employment site
A worker who are not part of the permanent workforce, but
who supply services on an irregular or flexible basis, often to An individual/specific production site, farm, winery, quarry,
meet a fluctuating demand for work. mine, service site etc. (including where applicable selected
sub-contractors/homeworkers).
Civil Society Organisation
Non-governmental and not-for-profit organisations that have a F

presence in public life, expressing the interests and values of
their members or others, based on ethical, cultural, political, Follow-up audit
scientific, religious or philanthropic considerations. These
organisations include community groups, non-governmental An audit to assess the effectiveness of corrective actions,
organisations (NGOs), Trade Unions, indigenous groups, undertaken to address issues from a previous audit. A follow-
charitable organizations, faith-based organisations, professional up audit can be either a full or a partial follow-up audit (see
associations and foundations. definitions below).

INTRODUCTION

Full follow-up audit

M
An audit to assess the effectiveness of corrective actions, Migrant worker
undertaken to address issues from a previous audit. The audit
should include a full review of all areas of the standard audit
A person who is engaged in a remunerated activity, who has
process, including the complete re-sampling of documents,
moved to a country, province or region of which he or she
conducting interviews and the employment site tour.
is not a native, where he/she is not eligible to or does not
intend to become permanent residents.
AUDIT REQUEST
H
Homeworker P
Partial follow-up audit
A homeworker can be defined as someone who, for a fixed
rate of remuneration, carries out work in his or her home for
An audit to assess the effectiveness of corrective actions,
PREPARATION
an employer who is not the final consumer of the product or

undertaken to address issues from a previous audit. The
service provided.
audit does not include a full review, but only focuses on the
issues identified in the corrective action plan.
I Permanent worker
International Labour Organization (ILO)
AUDIT EXECUTION
Permanent workers are workers who are employed directly

The ILO is a United Nations specialised agency which seeks to by the employment site and have a contract of employment
promote labour rights internationally. It defines international that is not limited by time.
minimum labour standards in the form of ‘Conventions’ and
‘Recommendations’ which are negotiated and developed by
government, employers’ and workers’ organisations. R
Re-audit
AUDIT OUTPUTS
Initial audit
A new audit which is performed on an employment site that
The first audit undertaken on an employment site which
has already been audited under the same code of conduct or
assesses compliance against a specific code of conduct, or is
by the same customer.
requested by a specific customer.
S
GLOSSARY
L
Semi-announced audit
Labour law
An audit which is undertaken on an un-specified date,
Legal requirements developed by governments that
scheduled within a set period,, (between 2 weeks and 2
APPENDICES
constitute minimum requirements which must be met by

months) which is agreed with the employment site. The
employers and workers within the employment relationship.
employment site will be informed that an audit will take place
Labour laws can also be developed through collective or
during this period but will not be informed of the exact date.
contractual agreements.
Social audit (hereafter referred to as ‘audit’)

Labour standards
Systematic, independent and documented process for
Rules and principles defined by international organisations,
obtaining evidence and evaluating it objectively to determine
governments and corporations which determine the
the extent to which ethical/ labour standards criteria are met.
conditions under which people should work.

INTRODUCTION

Stakeholder
U
Any person, company, organisation or other party that is Unannounced audit
affected by the activity and / or operations of a company.
An audit carried out without prior warning to the
Subcontractor employment site.
An individual or a group of individuals to whom a contractor
AUDIT REQUEST
outsources the manufacture of a product or part-product. V
Summary of Findings and Corrective Actions Verification
A summary document which provides information about all Examination of claims made about the actual observance of
issues and other findings from an audit, as well as corrective code or standard provisions by suppliers or of claims made
actions and time frames for completing these. about the activities that a company undertakes to give effect
PREPARATION
to its code. Verification implies that participating companies
Supplier must have internal auditing or monitoring systems in place.
Any contract partner which supplies the retailer/ brand with

goods or services. W
AUDIT EXECUTION
Worker
T A person working on an employment site, in any capacity.
Temporary worker
A temporary worker is a worker who is employed directly by

the employer, but on a contract that is for a specified period
AUDIT OUTPUTS
of time. When the contract ends there is no obligation for
the employer to continue the employment agreement.
Trade Union
A membership organisation of workers which seeks to

represent the views of workers and promote/ enforce their
GLOSSARY
rights within the workplace and the society as a whole. The
organisation must conform to local legal requirements, and
be able to engage in collective bargaining with employers
and employers’ organisations.
APPENDICES

INTRODUCTION

APPENDIX 1
GSCP Reference
Self-Assessment
Questionnaire
AUDIT REQUEST
This tool is part of the broader set of Reference Tools Companies should communicate the following to
designed to provide a common interpretation of fair labour employment sites when requesting this information:
PREPARATION
requirements and their implementation. They will enable

• reason for the information request;
buying companies around the world to work towards mutual
recognition of audit results. • how the risk assessment fits within the audit process;
The GSCP Reference tools are based on the GSCP Reference • to whom to send the completed self assessment (or how to
Code but can be adopted and tailored to other codes of upload the self assessment on to a database);
AUDIT EXECUTION
conduct.
• timeframe for completion;
Note: The GSCP Reference Code gathers, in a single

• process and timeframe for updating the self-assessment.
framework, the main international standards for fair
labour conditions and fundamental labour rights. The GSCP A Self-Assessment Questionnaire may be based on a specific
Reference Code is not a substitute for existing codes or code of conduct thus allowing companies to identify
existing systems but brings together the standards and best potential risks more easily. The Reference tool below is
practices that could be applied. structured according to the GSCP Reference Code.
AUDIT OUTPUTS
A Self-Assessment Questionnaire enables a supplier Employment sites should be encouraged to answer the self
or employment site to provide information about the assessment questionnaire in full and add commentary and/
employment site, how it manages social compliance and its or evidence against each point rather than just marking Yes
performance against local and international labour standards. or No.

The employment site is asked to respond to a series of
questions and provide supporting documentation. The
buying company may then use this information as the basis
GLOSSARY
of a risk assessment.
The auditor may also use information from the self-
assessment questionnaire to focus on-site investigation on
high risk areas.
APPENDICES

INTRODUCTION
APPENDIX 1: GSCP REFERENCE SELF ASSESSMENT QUESTIONNAIRE

REFERENCE SELF-ASSESSMENT
QUESTIONNAIRE

COMPANY OVERVIEW
AUDIT REQUEST
Name of company which owns the employment
site to be audited
Mailing address

(if different to that of the employment site)
PREPARATION
Telephone Number: Fax Number:
Ownership type (e.g. Joint Venture, Partnership,

Corporation, Foreign Investment, Other)
AUDIT EXECUTION
Year company formed

Legal status
Business Licence No.
Is the Company part of a group? Yes No

If Yes, name of parent company
AUDIT OUTPUTS
Does the company own any other employment
sites?
If yes, how many?
GLOSSARY
Annual turnover (USD)
Company Capital (USD)
Does the Company have any management Yes No

APPENDICES
systems certifications?
E.g. ISO 9001
If yes, please detail certifications and validity

Please append copies of all current certificates
to the completed self assessment questionnaire

INTRODUCTION


EMPLOYMENT SITE CONTACT DETAILS
Employment site name

Full address
Full address
AUDIT REQUEST
(in local language, if applicable)
Country
Is this site in an Export Processing Yes No

Zone (EPZ)?
PREPARATION
Employment site telephone number: Employment site fax number: Employment site email address:
Employment site manager:

AUDIT EXECUTION
Languages of the employment site

management:
Please list the main languages spoken

by employment site managers
Key contact: Key contact job title: Key contact telephone number:
AUDIT OUTPUTS
Employment site website (if available)
Closest Airport/railway station

Distance from the above:

please specify time and distance
plus traffic conditions if relevant
GLOSSARY
Regular shift times:
Does this employment site require Yes No

any permits or certificates in order to
APPENDICES
undertake any of its functions?

If Yes, then please provide details:

INTRODUCTION

WORKFORCE DETAILS
PEAK SEASON LOW SEASON

WORKFORCE NUMBERS
Male Female Male Female

TOTAL WORKERS
AT THIS EMPLOYMENT SITE
No. permanent workers
AUDIT REQUEST
No. temporary workers
No. of agency workers

No. of piece rate workers
No. salaried workers
PREPARATION
No. of hourly paid workers
No. of homeworkers
No. of young workers
No. part time workers
AUDIT EXECUTION
No. night workers

No. of workers in
accommodation provided
by the employment site
Percentage of migrant* workers
AUDIT OUTPUTS
Percentage of migrant workers
working at night

YOUNG WORKER DETAILS
GLOSSARY
Age of youngest worker
No. of workers under 18
Language(s) spoken
APPENDICES
Detail the different native

languages of the workforce,
together with the proportion
of workers who speak that
language as their first

language.
Nationality of workers
Detail the different nationalities
of the workforce, together
with the proportion of workers
of that nationality
* The term ‘migrant worker’ refers to, a person who is engaged in a remunerated activity in a country, province or region of which he or she is not a native and where he or she is
not eligible or does not intend to become permanent resident.

INTRODUCTION


0. MANAGEMENT SYSTEMS
0.1 Do you have a policy defining your approach to labour standards Yes No
and ethical trading?
If yes, please attach
0.2 Are you committed to any Codes of Conduct? Yes No

If yes, please detail:
AUDIT REQUEST
0.3 Do you have a dedicated manager in charge of ensuring Yes No

that the requirements of the policy are met?
if yes, please specify exact title and name Name:
Title:
0.4 Do you have a system in place that will alert you to changes Yes No
in any applicable labour laws?
PREPARATION
0.5 Do you have a procedure in place to evaluate and select your suppliers Yes No
based on their ability to meet your defined standards?
AUDIT EXECUTION
1. FORCED, BONDED, INDENTURED & PRISON LABOUR
1.1 Are all workers free to leave the employment site during non-working hours Yes No
or at the end of their shift? (including workers who live on-site)
Please explain any restrictions or how this freedom is assured
AUDIT OUTPUTS
1.2 Are all workers free to leave their employment upon giving reasonable Yes No
notice?
Please define the notice period required
1.3 Do you hold workers’ ID Cards/Passports? Yes No

GLOSSARY
If yes, please specify whether this is an original or a copy Original Copy
If Originals, then is holding original ID papers a legal requirement

Yes No
in your country?
APPENDICES
1.4 Are workers required to lodge deposits? Yes No

If yes, please specify how much and the reasons for these
1.5 Do you use prison labour? Yes No

If yes, please specify:
• how many workers are prisoners;
• whether prisoners are paid, and if so, how much;
• whether prisoners have a choice of whether to work or not;
• the name of any specific government prison work scheme.
1.6 Do you have a signed contract of employment for every directly employed Yes No
worker?
If Yes, do all workers have a copy?
Yes No

INTRODUCTION

2. CHILD LABOUR
2.1 What is the legal minimum age for work in your country?

2.2 What is the date of birth of the youngest worker and when did they start Date of birth:
working in the company?
Date of recruitment:
AUDIT REQUEST
2.3 Do you ask for a proof of age when recruiting workers? Yes No
If yes, please detail all checks you make
(e.g. ID card, birth certificate, medical checks, etc.)
PREPARATION
2.4 Do you have copies of proof of age documentation in workers’ personnel files? Yes No
2.5 Have you ever found child workers* on your employment site? Yes No
If yes, what did you do?
AUDIT EXECUTION
2.6 Do you have any workers below the age of 18, or do you have any Yes No

apprentices in the employment site?
If yes, please specify how many
Young workers:
Apprentices:
2.7 Do you make sure that young workers are exempt from overtime, Yes No
night work and hazardous work?
AUDIT OUTPUTS
If Yes, Describe your systems for doing this:

2.8 Do you participate in any apprenticeship schemes? Yes No
If yes, please provide the following information:
• Number of apprentices working
GLOSSARY
• Name(s) of the apprenticeship scheme
• Name(s) of the educational institutions involved
* Child workers are workers under the age of 15 or under the legal minimum working age, whichever is higher. If however, local minimum age law is set at 14 years of age in
APPENDICES
accordance with developing country exceptions under ILO Convention 138, then a child worker may be considered to be a worker below the age of 14.

INTRODUCTION


3. FREEDOM OF ASSOCIATION AND RIGHT TO COLLECTIVE BARGAINING
3.1 Do you recognise any Trade Unions in your workplace? Yes No

If yes, please specify which Trade Unions
3.2 Are any workers in your workplace members of a Trade Union? Yes No
AUDIT REQUEST
3.3 Are workers free to join Trade Unions? Yes No


PREPARATION
3.4 Are workers free to join other types of workers’ organisation? (other than Yes No
Trade Unions)
If yes, please specify which organisations
AUDIT EXECUTION
3.5 Do you have any workers’ committees or other worker representative bodies Yes No
in your workplace?
If yes, please specify the committees or bodies represented
AUDIT OUTPUTS
3.6 Are workers’ representatives on workers’ committees/other worker Yes No

representative bodies elected by the workforce?
If no, how are they selected?
3.7 Are all workers’ representatives permitted to carry out their duty within Yes No
working hours without sacrificing pay to do so?
GLOSSARY
3.8 Do you have regular meetings with the main Trade Union or workers’ Yes No
committee representatives in your workplace?
If yes, please specify how often
APPENDICES

INTRODUCTION

4. DISCRIMINATION, HARASSMENT AND GRIEVANCE PROCEDURES
4.1 Do you have an equal opportunities policy? Yes No

If yes, please attach

4.2 Do workers receive equal pay for equal work, regardless of gender, age, Yes No
religion, marital status, race, caste, social background, diseases, disability,
pregnancy, ethnic and national origin, nationality, membership in worker
organisations including unions, political affiliation, sexual orientation, or any
AUDIT REQUEST
other personal characteristics?
4.3 Are union representatives treated in the same way as other workers? Yes No
4.4 Do you use pregnancy testing for current/prospective workers? Yes No

4.5 Do you dismiss workers who become pregnant? Yes No
PREPARATION
4.6 Do you clearly and strictly forbid any form of verbal, physical or Yes No
psychological threats, abuse or harassment in your company
4.7 Do you have a formal, documented disciplinary procedure? Yes No
4.8 Do you have a formal, documented grievance procedure? Yes No
AUDIT EXECUTION
4.9 Do you record all disciplinary actions taken and any grievance procedures? Yes No
4.10 Do you conduct physical searches of workers? Yes No
AUDIT OUTPUTS
GLOSSARY
APPENDICES

INTRODUCTION


5. HEALTH AND SAFETY
5.1 Is there a senior manager responsible for health and safety? Yes No
If yes, specify their exact title and name Title:
Name:
5.2 Is there a health and safety committee on which workers are represented? Yes No
AUDIT REQUEST
5.3 Do you carry out health and safety risk assessments? Yes No
If yes, please specify any high risk areas identified
through the risk assessment process
5.4 Do you implement action plans for all risk areas identified? Yes No
PREPARATION
If yes please provide an example
5.5 When was the last health and safety risk assessment carried out?
5.6 Do you have a written evacuation procedure for emergencies? Yes No

AUDIT EXECUTION
5.7 Are all workers (including temporary workers) trained on health, safety Yes No
and hygiene?
5.8 Is this training repeated on a regular basis? Yes No

If yes, how often does this occur?
AUDIT OUTPUTS
5.9 Do you have records of the names of all personnel trained and the dates Yes No
they were trained?
5.10 Are all workers provided with appropriate personal protective equipment? Yes No
If yes, is this provided free of charge to workers?
GLOSSARY
5.11 Do you have an accident book where all accidents are recorded? Yes No
5.12 Is each shift covered by a trained first aider? Yes No

APPENDICES
5.13 Do you have a fire alarm that can be heard in all areas of the employment Yes No
site?
If Yes, how often is this alarm tested?
5.14 Do you conduct regular evacuation drills? Yes No
5.15 Are there enough fire exits for all workers to leave all buildings safely
in an emergency?

INTRODUCTION

5. HEALTH AND SAFETY
5.16 Are all fire exits unobstructed and unlocked?

5.17 Do all machines have appropriate safety guards?
5.18 Do you have a material safety data sheet (MSDS) for each chemical Yes No
in a language workers understand?
AUDIT REQUEST
5.19 Do you have written procedures for the safe storage, use and disposal Yes No
of hazardous materials in a language workers understand?
5.20 Do you provide unlimited access to clean drinking water during working Yes No
hours?

5.21 Do you provide proper sanitary facilities? Yes No
PREPARATION
5.22 Is any accommodation provided? Yes No
If yes, what is their location in relation to the employment site?
If no, please go to section 6
AUDIT EXECUTION
5.23 Is all accommodation in a separate building to production areas? Yes No

5.24 Are there at least 2 fire exits from each floor of the accommodation areas? Yes No
5.25 Does all accommodation have fire alarms? Yes No
AUDIT OUTPUTS
GLOSSARY
APPENDICES

INTRODUCTION


6. WAGES AND BENEFITS
Young* Young* Adult Adult

male female male female
workers workers workers workers
6.1 What is the legal minimum wage per month

applicable to your industry? (in local currency)
6.2 How much does the lowest paid permanent
AUDIT REQUEST
worker earn in standard working hours

per month? (in local currency)
6.3 How much does the lowest paid temporary

6.4 How much does the lowest paid piece-rate
PREPARATION

6.5 How much does the lowest paid
subcontractor/home-worker earn in standard
working hours per month? (in local currency)
6.6 Do you pay a premium rate for overtime? Yes No
AUDIT EXECUTION
If yes, please specify the rate

6.7 Do you make any deductions from Yes No

workers’ pay?
If yes, please provide details of:
• Legally Required Deductions
• Other Deductions
AUDIT OUTPUTS
6.8 After deductions are made, do any workers Yes No

receive less than the legally applicable
minimum wage* ?
6.9 Do workers receive payslips clearly setting Yes No
out how their wages are calculated and any
deductions made?
GLOSSARY
6.10 How often do workers receive their wages? Frequency:

(please specify the frequency and exact date, Exact date, if any:
if any)
6.11 How are workers paid? Cash Cheque
APPENDICES
If other please provide details Bank transfer Other
6.12 Do you provide any social benefits to the Yes No

workers (e.g. health insurance, pension fund,

child care, education, accommodation etc.)?
If yes, please describe what is provided
6.13 Do all workers receive paid annual leave i Yes No

n accordance with the law?
If yes, please describe how much paid annual
leave is provided
* Young workers are workers younger than 18 years of age, but older than the legal minimum working age

INTRODUCTION

7. WORKING HOURS
7.1 What is the legal maximum number of working hours per week
(including overtime) in your country?

7.2 Are any exceptions to this maximum allowed? Yes No
If yes, please describe
AUDIT REQUEST
7.3 What are your employees’ standard weekly working hours? Per week:
7.4 What is the average number of weekly overtime hours per person? Per week:
7.5 What is the maximum number of overtime hours that employees work per Per week:

week in peak season?
PREPARATION
7.6 Is overtime compulsory? Yes No
7.7 Do workers have at least one day off per week? Yes No
7.8 How are working hours recorded?
AUDIT EXECUTION
END OF QUESTIONNAIRE
AUDIT OUTPUTS
GLOSSARY
APPENDICES

INTRODUCTION

APPENDIX 2
GSCP Reference
Pre-Audit Employment
Site Profile
AUDIT REQUEST
This tool is part of the broader set of Reference tools • timeframe for completion of the pre-audit employment
designed to provide a common interpretation of fair labour site profile;
PREPARATION
requirements and their implementation. They will enable

• to whom to send the completed pre-audit employment
buying companies around the world to work towards mutual
site profile.
recognition of audit results.
Recommended timeframe:
The GSCP Reference tools are based on the GSCP Reference
Code but can be adopted and tailored to other codes of • the auditor should supply the pre-audit employment site
AUDIT EXECUTION
conduct. profile questionnaire to the employment site within five

working days of the audit being confirmed;

framework, the main international standards for fair • the pre-audit employment site profile questionnaire should
labour conditions and fundamental labour rights. The GSCP be completed and returned to the auditor two weeks from
Reference Code is not a substitute for existing codes or the date of the request being made;
existing systems but brings together the standards and best
• if an audit is requested and scheduled in less than two
practices that could be applied.
weeks, the auditor and employment site should work
AUDIT OUTPUTS
When an audit request is made, the auditor should send together to ensure the pre-audit employment site profile
the employment site a Pre-Audit Employment Site Profile is returned as soon as possible and in any event before the
questionnaire asking for general information about location, audit is carried out.
size, workforce profile and production processes. This

A Pre-Audit Employment Site Profile should have four main
information allows auditors to:
areas:
• prepare relevant briefing materials (industry or country-
1. company overview;
specific);
GLOSSARY
2. supplier overview;
• plan the assessment, for example the gender and language
capabilities of the audit team members and the required 3. employment site details;
number of audit days.
4. subcontracting activities.
Each employment site to be audited should complete a pre-
APPENDICES
audit employment site profile. The information provided Where the employment site itself is the audit requestor, the
should be used by the auditor to make the necessary auditor should ensure that an agreement is in place with the
preparations for the audit and may also be used during employment site to allow the auditor to communicate audit
findings and any alert notifications to any buyers, brands or
audits to focus the auditor on high risk areas.

retailers concerned.
The audit company should communicate the following to
each employment site to be audited and any relevant parties,
such as agents, in the supply chain:
• the importance of accuracy in completing in the pre-audit
employment site profile;

INTRODUCTION
APPENDIX 2: GSCP REFERENCE PRE-AUDIT EMPLOYMENT SITE PROFILE

1. COMPANY OVERVIEW

Where possible, the pre-audit employment site profile should detail the following overview of the company.
1. COMPANY OVERVIEW
AUDIT REQUEST
Name of company which owns the employment
site to be audited

Mailing address
(if different to that of the employment site)
Telephone Number: Fax Number:
PREPARATION
Ownership type (e.g. Joint Venture, Partnership,
Corporation, Foreign Investment, Other)
Year company formed
AUDIT EXECUTION
Legal status

Business licence no. (if applicable)
Is the company part of a group? Yes No

If Yes, name of parent company
AUDIT OUTPUTS
Does the company own any other employment

sites?
If yes, how many?
GLOSSARY
Annual turnover (USD)
Company capital (USD)
Does the company have any management Yes No

APPENDICES
systems certifications?
If yes, please detail certifications and validity

Please append copies of all current certificates

to the completed self assessment questionnaire

INTRODUCTION


2. SUPPLIER OVERVIEW
Where relevant, the pre-audit employment site profile should detail the following information concerning any intermediate supplier.
2. SUPPLIER OVERVIEW
AUDIT REQUEST
Supplier name:
Full address:
Country:
PREPARATION
Supplier telephone number: Supplier fax number: Supplier email address:
Key contact: Key contact telephone number:

AUDIT EXECUTION
Supplier website (if available):

Supplier website (if available):

AUDIT OUTPUTS

GLOSSARY
APPENDICES

INTRODUCTION

3. EMPLOYMENT SITE DETAILS

3.1 Employment Site Contact Details
The pre-audit employment site profile questionnaire should request the following contact information:
AUDIT REQUEST
3.1 EMPLOYMENT SITE CONTACT DETAILS
Employment site name:
Full address:
PREPARATION
Full address
(in local language, if applicable):
Country
AUDIT EXECUTION
Is this site in an Export processing Yes No
zone (EPZ)?

Employment site telephone number: Employment site fax number: Employment site email address:
Employment site manager:
AUDIT OUTPUTS
Languages of the employment site
management.

Please list the main languages spoken
by employment site managers:
Key contact: Key contact job title: Key contact telephone number:
GLOSSARY
Employment site website (if available)
Closest airport/railway station

APPENDICES
Distance from the above.

Please specify time and distance
plus traffic conditions if relevant
Regular shift times:
Does this employment site require Yes No

any permits or certificates in order to
undertake any of its functions?
If Yes, then please provide details:

INTRODUCTION


3.2 Employment Site Management

The following information is requested to understand internal management systems and processes regarding social compliance.
3.2 EMPLOYMENT SITE MANAGEMENT
Name and position of person responsible

for Social Compliance Issues:
AUDIT REQUEST

for health & safety:

for recruitment and personnel issues:
PREPARATION

for production planning:

for payroll issues:
AUDIT EXECUTION
Names, position and responsibilities of other

management personnel:
Are any workers represented by a Trade Union? Yes No

If yes, then please name the union(s) and worker
representative(s):
AUDIT OUTPUTS
Is there a workers committee or health and safety Yes No

committee?
If yes, name the committee(s) and workers’

representative(s)
GLOSSARY
APPENDICES

INTRODUCTION

3.3 Employment Site area & Facilities
The pre-audit employment site profile questionnaire should detail the following information concerning the size and facilities
of the employment site area. Depending on the nature of the employment site, some of the headings may need to be changed

(e.g. to differentiate between farms and factories).
Where relevant, the employment site should be asked to submit a floor plan.
3.3 EMPLOYMENT SITE AREA & FACILITIES
AUDIT REQUEST
Employment site size: Production area (m2):
Administration area (m2):
Storage area (m2):
Total area (m2):
PREPARATION
Do you provide canteen facilities? Yes No
If yes, size of canteen facilities (m2):
Are canteen facilities located on or off site? On-site Off-site N/A
AUDIT EXECUTION
Do you provide dormitory or other living Yes No
accommodation facilities?

If Yes, size of dormitories
or other accommodation (m2):
Is accommodation located on or off site? On-site Off-site

If off-site, then please detail the street address
AUDIT OUTPUTS
of ALL accommodation and the distance from
the employment site:
GLOSSARY
APPENDICES

INTRODUCTION


3.4 Employment Site Production and Processes Overview

The pre-audit employment site profile should detail the following information concerning the employment site’s production
systems and production processes. Some employment sites may not be willing to provide some of the information requested
because of confidentiality agreements with other customers.
3.4 EMPLOYMENT SITE PRODUCTION SYSTEMS AND PROCESSES

AUDIT REQUEST
Industry sector:
Principal products:
Main export markets:
Proportion of output supplied to audit requestor:

PREPARATION
Other major customers:
Peak & low seasons: Peak season:

Low season:
AUDIT EXECUTION
Maximum capacity per month*:

Typical production level as a percentage of total Jan Feb Mar Apr May June
capacity (by month):
July Aug Sept Oct Nov Dec

AUDIT OUTPUTS
Main production processes

(e.g. Stitching, labelling, injection, moulding,

baking, harvesting, dyeing etc.):
Main production equipment:

GLOSSARY
Main raw materials used:
List of hazardous chemicals used employment

site:
APPENDICES
Shift times (broken down by section):
Regular overtime hours:

* Auditor should check if an appropriate unit has been communicated (tonnes, number of pieces, containers…).

INTRODUCTION

3.5 Employment Site Workforce
The following information is an essential requirement, both to understand potential risks posed by the employment site’s
operations and to plan for the audit. Any missing details should be clarified with the employment site directly.

3.5 EMPLOYMENT SITE WORKFORCE

WORKFORCE NUMBERS
AUDIT REQUEST

TOTAL WORKERS
AT THIS EMPLOYMENT SITE:
No. permanent workers:
No. temporary workers:
PREPARATION
No. of agency workers:
No. of piece rate workers:
No. salaried workers:
No. of hourly paid workers:
AUDIT EXECUTION
No. of homeworkers:
No. of young workers:
No. part time workers:
No. night workers:
AUDIT OUTPUTS
No. of workers in
accommodation provided
by the employment site:

Percentage of migrant workers:
Percentage of migrant workers

working at night:
PEAK SEASON LOW SEASON GLOSSARY

YOUNG WORKER DETAILS
APPENDICES
Age of youngest worker:
No. of workers under 18:

Language(s) spoken
Detail the different native
languages of the workforce,
together with the proportion
of workers who speak that
language as their first
language:
Nationality of workers
Detail the different nationalities
of the workforce, together
with the proportion of workers
of that nationality:

INTRODUCTION


3.6 Details of Previous Social Audits and Outcomes

This section provides the audit history of the employment site. This information helps determine the type of audit required (i.e a
full audit, a verification audit, etc.) and if a current audit report can be shared instead of conducting a new audit.
3.6 EMPLOYMENT SITE PREVIOUS SOCIAL AUDITS AND OUTCOMES
Are you a participant in any social initiative(s)? Yes No

AUDIT REQUEST
e.g. BSCI, ICS, ICTI, FLA, Fair Trade

If Yes, which initiatives and please provide

evidence:
Are you a member of any social reporting

systems?
PREPARATION
If yes, please specify which ones:
Do you have your own social policy or code of Yes No

conduct?
If Yes, please supply a copy.
AUDIT EXECUTION
Are you operating to any other codes of conduct? Yes No

If Yes, please list Codes you are using:
Has your employment site previously been Yes No

audited for social compliance?
AUDIT OUTPUTS
If yes, please provide details of previous audits: Date of Audit Code audited Auditing company/
against organisation
GLOSSARY
Would you be prepared to share previous Yes No

audit reports and, improvement/action plans
conducted for other customers?
APPENDICES
Have any previous corrective actions been Yes No

completed?
Please detail outstanding corrective actions and Issue found Corrective Timescale Person
your expected completion date? action responsible

INTRODUCTION

4. SUBCONTRACTING

4.1 Products / Processes Subcontracted Overview
The pre-audit employment site profile should detail the following information on the products and/or processes that are
AUDIT REQUEST
subcontracted by the employment site:

4.1 PRODUCTS/PROCESSES SUBCONTRACTED
List any production or processes sub-contracted:
Are any processes sub-contracted to Yes No
PREPARATION
homeworkers? If yes, please complete Section 3.4.2
Subcontractor details: please complete the table below for each process subcontracted. Add more tables as required.
Subcontracted Process:
Process 1
AUDIT EXECUTION
Products involved:

No. of subcontracting companies:
Names and ranking by volume of business:
Have you audited these contractors? Yes No
AUDIT OUTPUTS
Subcontracted Product:

Process 2
Process:
GLOSSARY

APPENDICES
Subcontracted Product:
Process 3
Process:

INTRODUCTION


4.2 Homeworking
The following information is required if an employment site has stated that they use homeworkers. This is an essential
requirement of the pre-audit employment site profile, both to understand potential risks and to plan the audit.
4.2 HOMEWORKING
Are any processes undertaken by homeworkers? Yes No

AUDIT REQUEST
What processes are undertaken by homeworkers?
Names and addresses of any ‘middlemen’

or homeworking contractors used:
PREPARATION
Number of homeworkers used:
Location(s) of homeworkers and approximate

distance of their homes from the employment
site:
AUDIT EXECUTION
Describe how you select homeworkers

and or ‘middlemen’ if used?
How are homeworkers paid?

Describe how rates are set, how payment is made
and detail any middle-men in the process:
AUDIT OUTPUTS
Are working conditions monitored? Yes No

If so, please outline how:
If yes, describe how they are monitored

GLOSSARY
and outline your findings:
Do you have written contracts, policies

APPENDICES
or procedures relating to the conditions

of homeworkers?
If yes, please provide a copy of all relevant
documentation

INTRODUCTION

APPENDIX 3
GSCP Reference

Audit Checks
AUDIT REQUEST
This tool part of the broader set of Reference tools The Reference Audit Checks have been designed to provide
designed to provide a common interpretation of fair labour auditors with the minimum requirements regarding audit
PREPARATION
requirements and their implementation. They will enable methodology and evidence gathering. The audit checks are
buying companies around the world to work towards mutual structured around the eight areas of the GSCP Reference
recognition of audit results. Code and include guidance on:
The GSCP Reference tools are based on the GSCP Reference • documents checks;
Code but can be adopted and tailored to other codes of
• worker interviews;
AUDIT EXECUTION
conduct.
• management Interviews, Employment site Procedures and

Processes;
labour conditions and fundamental labour rights. The GSCP • physical employment site inspection.
Reference Code is not a substitute for existing codes or
The list of checks should be used as guidance by auditors,
and should not limit audit activities.
AUDIT OUTPUTS
GLOSSARY
APPENDICES

APPENDICES GLOSSARY AUDIT OUTPUTS AUDIT EXECUTION PREPARATION AUDIT REQUEST RISK ASSESSMENT SYSTEM INTRODUCTION
Appendix 4: GSCP Reference Alert Notification Appendix 3: GSCP Reference Audit Checks Appendix 2: GSCP Reference Pre-Audit Employment Site Profile Appendix 1: GSCP Reference Self Assessment Questionnaire
Appendix 7: GSCP Reference Summary of Findings and Corrective Actions Appendix 6: GSCP Reference Supplementary Audit Information Appendix 5: GSCP Reference Audit Report
AUDIT CHECKS
0. Management Processes
Employment site Requirements:
1. the employment site has clearly defined, documented and supervised policy and procedures for the implementation and the management of fair labour conditions;
2. the employment site management ensures an effective communication of the policy and procedures for the implementation and the management of fair labour
conditions;
3. the employment site has a method of assessing the risk in terms of fair labour conditions at subcontractor employment sites.
The following checks are intended as guidance and should not limit audit activities.

EVIDENCE GATHERING ON MANAGEMENT PROCESSES COMMENTS
0.1 Document Checks
❒P
olicies and procedures for the implementation and the management of fair labour conditions should meet
recognised international standards, including those detailed in the relevant code of conduct.
❒A
member of the senior management team with responsibility for the application of fair labour requirements
should have signed and dated any policies and procedures detailing the implementation and the management
of fair labour conditions.
❒ T here are financial and human resources allocated to implement the procedures.
❒P
olicies and procedures include a clear definition of how they apply and to which personnel at the worksite.
❒P
olicies and procedures assign responsibilities and timescales for each stage of implementation.
❒P
olicies and procedures state the employment site’s intentions to work with partners that meet its fair labour
requirements, or who show commitment to work towards these requirements.
❒P
olicies and procedures are regularly reviewed, in consultation with internal and external stakeholders, to ensure
that they meet international fair labour standards.
…
APPENDIX 3: GSCP REFERENCE AUDIT CHECKS
…
0.2 Worker Interviews
During worker interviews, corroborate worker testimony with document checks and management interviews. Ask workers:
❒W
hether the employment site’s fair labour policies and procedures have been communicated to workers, and through
what means.
❒W
hether the fair labour policies and procedures are available in the language of the workers.
❒W
hether workers have received written communications or training on the fair labour policies and procedures,
and if so, when this happened.
❒W
hether any workers who are not able to read, have had the fair labour policies and procedures communicated
in an alternative means, and if so, what those means were.
0.3 Management Interviews, Employment site Procedures and Processes
❒ T he employment site takes all reasonable steps to extend its knowledge of the provenance of all products
and materials produced or sourced.
For example, this could be done through recording the country/region of manufacture/production, or through training
of suppliers of raw materials, ingredients, etc.
❒C
heck whether the employment site has a list of subcontractors.
❒ T he employment site holds contracts and records of arrangements made with any subcontractor(s).
❒M
anagers at supplying sites should have communicated the relevant labour standard requirements to their
subcontractors, and that they are aware of the situation on sub-contractor sites (for example through discussions
and visit histories).
❒O
verall audit history of the subcontractor(s) and review any non-compliances which have been raised.
Where possible, the employment site should hold records of audits conducted on any subcontractor.
❒R
isk assessments should include such sources of information as provided by Trade Unions (local, national
and international), NGOs, the ILO, local legal records, etc.
❒R
isk assessments and agreements with subcontractors are held centrally, are readily accessible and are regularly
updated.

1. Forced, Bonded, Indentured and Prison Labour

1. all work is conducted on a voluntary basis, and not under threat of any penalty or sanction;
2. the use of forced or compulsory labour in all its forms, including prison labour when not in accordance with ILO Convention 29, is prohibited;
3. employment sites do not request workers to make deposits/ financial guarantees and do not retain identity documents;
4. bonded labour is prohibited;
5. indentured labour is prohibited.
EVIDENCE GATHERING ON FORCED, BONDED, INDENTURE, PRISON LABOUR COMMENTS

1.1 Document Checks
1.1.1 Contracts
❒ T here is a process in place for workers to give notice if they wish to leave employment.
❒W
orkers can voluntarily end their employment.
❒W
orkers are not fined and/or do not lose their residency papers if they leave the employer.
❒W
orkers receive their final salary payment when they leave employment.
❒ J ob descriptions / tasks of the security guards do not mention restrictions on worker movements.
❒A
ll workers (including prison labourers) have a contract of employment which details their rights and obligations,
as well as notice periods and grievance procedures.
❒W
orker contracts do not have any clauses that would effectively restrict the ability of workers to leave
their employment.
❒ L oans or other financial agreements between the worker and the employer are not included in the contract
of employment.
…
…
1.1.2 Personnel Files
❒M
anagement retain copies only of ID and right to work documentation.
❒M
anagement returns all original documentation to workers, within a reasonable time, once it has been copied.
Management should not retain original documentation longer than is required for the purpose of copying it.
❒ If employers must retain workers’ original ID because of local legal requirements, check that:
• signed and informed consent letters from workers authorise employers to hold their ID;
• there is a system whereby workers can retrieve their ID at any time;
• employers inform workers of these procedures.
❒M
anagement must have signed agreement between worker and management relating to any loans made by the
company to the worker, stipulating repayment terms and conditions.
❒ If the employer makes any deductions (including repayment of loans) from workers’ pay, except mandatory
deductions, check that:
• deductions are legally permitted;
• workers have signed a document setting out the amount of the deduction and giving their consent;
• workers have a copy of this document;
• deductions are reasonable and neither reduce pay below legal minimum wage levels for hours worked nor breach local
legal limits;
• no deductions are made for disciplinary reasons;
• no deductions are made for essential items such as protective equipment and/or clock-in cards.
❒ If workers pay deposits or deposits are withheld from salaries, check that:
• deposits are legally permitted;
• workers have signed a document setting out the amount of the deposit, the terms of its return and the worker’s
consent;
• amounts are reasonable and neither reduce pay below legal minimum wage levels for hours worked nor breach local
legal limits;
• there is evidence of deposits being returned to workers as set out in the agreement;
• deposits are not a compulsory condition for workers to gain employment.

…
❒W
hat the procedures are for giving notice and leaving their employment.
❒W
hether there are any restrictions in their ability to move around or leave the employment site.
❒W
hether they are in possession of their identity documents (or, if the employer must keep original documents by law,
that workers are aware of the procedure for retrieving documents and that this procedure is operational)
❒W
hether they are comfortable with security measures, whether they feel that their movements are unreasonably
restricted in any way.
❒W
hether any deductions are made from their salaries, if so whether they have agreed the amount and have a copy
of their agreement

❒W
hether they have been given any loans by the company management, and if so whether they have agreed the
amount, have a copy of their agreement, and understand the repayment terms and conditions.
❒W
hether any deposits have been taken from the workers, if so what the deposits are for, and when the deposits will
be repaid and under what circumstances. Whether workers have a copy of the agreement relating to the deposit.
❒ F or all deductions, loans or deposits, workers:

• have agreed the amount;
• are aware of the terms;
• state that the amounts are reasonable.
❒W
hether all workers, including prison labourers, are voluntarily employed and can end their employment at any time.
❒W
hether workers are able to leave accommodation without leaving their employment.
❒ T he employment site is aware of local law and fair labour conditions regarding the use of deposits, loans, deductions,
prison labour, and the retention of ID papers.
❒C
heck that a worker to whom loans have been made is not tied to the employer for the duration of the loan (this can
include procedures for re-assigning the loan to a new employer or for early repayment).
❒ S ecurity procedures do not unreasonably restrict the free movement of workers.

…
…
❒M
anagement does not permit or encourage workers to incur debt through recruitment fees, fines or other means,
before during or after employment.
❒P
rison labour:
• the relevant documentation is in place which allows / authorises the use of prison labour on the employment site;
• activities are under the supervision and control of the public authority;
• management has a list of any prison labourers who are present on the employment site at any one time;
• pay and hours are in line with legal regulations;
• prisoners work voluntarily.
1.4 Physical Employment site Inspection
❒ F ire exits, all doors and windows are unlocked during working hours.
❒W
orkers are able to leave the employment site freely during breaks and rest-time.
❒D
ormitories are secure, but workers are able to leave them when they wish.
❒A
ny restrictions (e.g. curfews) are reasonable.
❒W
orkers are not restricted from leaving or moving around the employment site.
❒D
ormitory accommodation (if provided) has individual secured lockers to store documents and other personal
possessions.
❒ S ecurity guards are not able to restrict the free movement of workers or their right to leave the workplace at the end
of their shift.
❒ S ecurity guards are not threatening to workers
❒W
orking conditions of prison labourers are in line with legal regulations.

2. Child Labour and Young Workers

1. no children are employed;
2. sensitive and appropriate solutions are sought in case of child labour;
3. specific conditions are applied to protect young workers.
NB: Child workers are workers under the age of 15 or under the legal minimum working age, whichever is higher. If however, local minimum age law is set at 14 years
of age in accordance with developing country exceptions under ILO Convention 138, then a child worker may be considered to be a worker below the age of 14.
Young workers are workers younger than 18 years of age, but older than the legal minimum working age.
EVIDENCE GATHERING ON CHILD LABOUR COMMENTS

2.1 Document Checks
❒ T he employer holds an individual personnel record for each worker.
❒P
ersonnel records specify the date of birth of each worker; the following documentation may be permissible:
• voter identity cards with photo;
• birth certificate;
• notary or medical certificate;
• national / social insurance number;
• medical examination prior to employment;
• ration cards, etc.;
• multiple written documents and affidavits;
• school leaving certificate;
• school diploma.
❒A
ll documentation provided is valid and genuine.
❒N
o worker is under the age of 15 or under the legal minimum working age, whichever is higher. If, however, local
minimum age law is set at 14 years of age in accordance with developing country exceptions under ILO Convention
138, this lower age may apply.
❒A
ll young workers on the employment site are registered with local authority where required by local legal requirements.
❒C
heck if young workers have consent of a parent or guardian, where required by law and/or where possible.
❒ E ach young worker’s personnel file should contain reports of medical examinations.
…
…
❒C
ontracts and job descriptions for young workers state the limitations on the nature of work permitted.
❒Y
oung workers engaged under a vocational or other training course have information pertaining to that course within
their personnel files.
2.1.2 Policy Documents
❒ T he employment site has a robust system for age verification.
❒ T he employment site holds documentation regarding training and apprenticeship schemes where applicable.
❒ T he employment site maintains a list of young workers and their roles on-site.
❒ T he employment site has a procedure for the remediation of any child labour found on the employment site.
❒ T he remediation procedure was developed in conjunction with local partner organisations.
❒C
hild labour remediation policies and procedures are in line with local legal regulations, and established international
requirements.
❒V
erify the success of any remediation programmes and any subsequent changes to the systems at the employment site:
• ensure that children are in education and are supported by the factory or other stakeholder to ensure that they are
able to continue in education until they reach the legal working age. The programme should be driven by the best
interests of the child in question.
❒C
heck the risk assessment policy to ensure that young workers and the risks associated with employing them are
specifically covered.
❒C
heck that there is a policy regarding the use of vocational training schemes.
❒C
heck that there is a written agreement between the school and the employment site regarding all workers who are
engaged on a vocational training programme.
2.1.3 Sub-contracting Documents
❒ T he employment site holds a list of sub-contractors or suppliers of all products and materials.
❒ T he employment site has a written contract with the sub-supplier which includes commitments to prevent and
prohibit the use of child labour.
❒P
rocedures for the prohibition of child labour at sub-suppliers employment sites are in place, and are in line with local
legal regulations, and established international requirements.
❒R
eview audit history of sub-suppliers employment sites to gain visibility of conditions at sub-supplier employment
sites. It is important to ensure that the employment site is aware of their role in ensuring that their sub-suppliers
are committed to the prohibition of child labour, and are able to review their practices. Checks should therefore be
made to increase transparency and knowledge of these units to ensure that sub-suppliers are adhering to child labour
requirements.

…
…
During worker interviews, corroborate worker testimony with document checks and management interviews.
Ensure that young workers are included in the interview pool. Ask workers:
❒W
hether there are any children working on the employment site.
❒W
hether young workers are engaged on the employment site in hazardous, night or overtime work or work that
would interfere with their education.
❒W
hether young workers are happy / comfortable with their employment conditions.
❒W
hether young workers’ employment conditions are in line with local and international requirements.
2.3 Management Interviews, Site Procedures and Processes

❒ T he employment site should be aware of local laws regarding the minimum age of employment and regulations
concerning young workers.
❒ T he employment site should be aware of established international requirements regarding the minimum age of

employment and regulations concerning young workers, such as those detailed in the relevant code of conduct:
• employment sites shall not employ any person under the age of 15 or under the legal minimum working age,
whichever is the higher. If, however, local minimum age law is set at 14 years of age in accordance with developing
country exceptions under ILO Convention 138, this lower age may apply.
❒ T he age verification systems at sub-supplier employment sites are robust.
❒C
heck recruitment and dismissal records to determine whether any children or young workers have been hired or
fired by the employment site in the past 12 months.
2.3.1 Child Labour Remediation

❒R
eview documentation on the implementation of policies and procedures concerning the remediation of child labour.
❒D
etermine whether local organisations were involved in the development of the policies and procedures.
❒C
heck if local organisations have been involved in the remediation of any child labour found on the employment site;
supporting them or providing them with education / vocational training.
❒C
heck whether there have been any remediation plans or written statements within the past 12 months.
❒ E stablish the commitment of the employment site to engage in a remediation plan for all underage workers.
❒ E nsure that the employment site signs a written agreement / commitment for the remediation programme required,
which includes:
• ensuring the child no longer works;
• establishing a method of keeping the child protected and safe without them being at risk or required to work;
• contact details of the child and their parents;
• payment of a stipend;
• identification of education programmes for the child.

…
…
❒A
ssign or ask the management to assign a contact with whom the audit requestor / auditor / Civil society organisation
can liaise regarding the programme.
❒ E nsure that the employment site agrees to meet the requirements of industry best practice in the development and
management of the remediation programme.
2.3.2 Young Workers
❒M
anagement verify fitness of young workers to work through regular (at least once per year) medical check-ups by a
qualified physician.
❒R
egisters of young workers must:
• be up-to-date;
• record names, ages and dates of birth;
• indicate the job roles of young workers.
❒C
heck whether the ability of young workers to attend school or perform school-related responsibilities is preserved.
❒O
vertime work is prohibited for young workers.
❒ T he production processes in which young workers are involved conform to local and international regulations.
❒ T here is a minimum of 12 hours’ night rest between shifts for young workers.
❒Y
oung workers’ holidays are at least equal to those of adults and / or in line with local legal requirements.
❒ S ocial security applied to young workers is equal to that of adults.
❒ S ufficient night rest is given to young workers.
❒ T he working conditions of young workers should be carefully monitored to ensure they meet local and international
legal requirements.
❒Y
oung workers receiving vocational orientation or training should be allocated to suitable tasks (i.e. not in contact
with hazardous chemicals or operating heavy machinery) and to suitable shifts (i.e. not night work).
2.4 Physical Employment Site Inspection
❒Y
oung-looking workers on-site.
❒A
ccommodation on-site dedicated to child care, if any, is appropriately staffed, equipped and safe. There should be
sufficient protection and/or distance from the workplace to ensure that workers’ children cannot enter the workplace
or be exposed to any hazards.
❒Y
oung workers only seen to be working in low risk roles and areas which are not hazardous.

3. Freedom of Association and the Right to Collective Bargaining

1. workers have the right to join or form Trade Unions and to bargain collectively without prior authorisation from employment site management;
2. when needed, alternative forms of independent and free worker representation and negotiation are not hindered;
3. there is no discrimination against worker representatives or Trade Union members;
4. workers representatives are given access to the workplace in order to carry out their representative functions.
EVIDENCE GATHERING ON FREEDOM OF ASSOCIATION AND THE RIGHT TO COLLECTIVE BARGAINING COMMENTS
3.1 Document Checks

❒ If the employer takes deductions for union fees, ensure:
• deductions are legally permitted;
• workers have signed a document setting out the amount of the deduction and giving their consent;
• payslips record the deductions;
• deductions are paid to the union.
❒ Personnel files of union representatives contain:
• any disciplinary records issued by management;
• evidence of union members being dismissed;
• any evidence of differential treatment.
❒ Management pays representatives for the time they spend carrying out their representative function.
3.1.2 Union Documentation

❒ T rade union meeting minutes record any discussions and all agreed actions and the responsibilities and deadlines
relating to these actions.
❒ Communications from employers respond to any proposals or concerns arising from meetings with Trade Unions.
❒ Look for evidence that unions are active at the employment site, which may include:
• notices about joining unions;
• meeting reports;
• election reports;
• list of union representatives and their functions;
• strike history in the employment site;
• the union constitution.
…
…
❒C
ollective bargaining agreements (if in place) are fair and reasonable (read the agreements to assess the effectiveness
of the union).
3.1.3 Other Forms of Worker Representation
❒ If no Trade Union is active at the employment site, management should instigate an alternative form of worker
representation (e.g. informal workers groups, committees).
❒A
ssess the effectiveness of worker representation through meeting minutes, reports, and notices that have been
communicated to the workforce.
❒A
ny group intended to represent workers’ views should be representative of the workforce, independent
of management and able to represent the views of workers effectively.
❒W
orkers’ committees / organisations must not be used to prevent workers from seeking the right to collectively
bargain with their employers.

❒W
hether workers have joined a Trade Union or are aware of a Trade Union operating on the employment site.
❒W
hether workers are aware of their rights to organise and bargain collectively.
❒ If they are aware of any union fee deductions.
❒W
hether Trade Union members can conduct their activities without unreasonable restrictions and/or interference
by the employment site or management.
❒W
orker representation:
• whether workers are aware who their representatives are;
• if workers are aware of the function of each representative and how representation works;
• whether workers are able to elect their representatives freely;
• whether workers are satisfied with their representatives and feel that the representative function on-site is effective.
❒W
hether workers can have reasonable time off to engage in union activities, and if this time is paid (where legally
required).
❒W
hether policies and procedures have been effectively communicated to workers (written policy, employee
handbook, other), and if so in which languages:
• if some workers are unable to read, ask workers if efforts are made to communicate policies, procedures,
decisions and minutes to workers through an alternative method.

…
❒W
hether information relating to collective bargaining agreements is circulated to workers.
❒W
hether homeworkers are covered by collective bargaining agreements and enjoy the same rights as workers
on the employment site.
❒W
hether workers are aware of any alternative forms of worker representation (e.g. informal workers groups,
committees).
❒W
hether workers believe that any existing committees or councils represent a genuine means by which workers
can raise their concerns and discuss solutions with management.
3.2.1 Union and Workers Representative Interviews
During interviews with union and worker representatives, corroborate their testimony with document checks and
management interviews. Ask them:
❒ If they are free from management interference and are able to represent workers’ views independently.
❒H
ow workers’ representatives are elected by the workforce, and whether this process is free and democratic.

❒W
hether workers’ representatives feel that their role is effective at representing and promoting the views of workers.
❒ If facilities are provided for workers’ representative to carry out their functions.
❒W
hether representatives are paid for the time they spend carrying out their representative function.
❒W
hether Trade Union notices can be posted on notice boards on the premises.
❒W
hether there is any recourse in place for workers' representatives who consider that their employment has been
unjustifiably terminated, or that they have been subjected unfair treatment or an unfavourable change in their
conditions of employment.
❒W
hether there have been any instances where the employment of a workers' representative has been terminated,
that there was a valid reason for this action.
❒W
hether there has been any evidence of workers’ representatives being discriminated against, or facing redundancy
before other workers.
❒W
hether workers’ representatives are able to contact all of the workers that are working for the employment site,
including homeworkers.
❒W
hether representatives are provided with training on how to negotiate effectively with management.
❒W
hether representatives are able to communicate grievances to management, including through documented
communication systems for resolving disputes between co-workers, supervisors, etc.
❒W
hether workers’ representatives are able to negotiate and collectively bargain with management. This may involve
reviewing documents and meeting notes from union or committee meetings.
…
…
❒M
anagement is aware of local laws / regulations concerning freedom of association and collective bargaining.
❒M
anagement is aware of established international requirements concerning freedom of association and collective
bargaining, such as those detailed in the relevant code of conduct.
❒ T he employment site has effective policies and provisions for the recognition of Trade Unions.
❒M
anagement has a list of relevant unions which are established in the country / region.
❒ If management has had any contact / dealings with any Trade Unions, and previous dealings with any of these unions,
and the status of their union collaboration at the time of the assessment.
❒M
anagement is supportive of worker representatives and local unions and do not try to reduce the effectiveness
or presence of unions / worker representatives on-site.
❒ Independent third parties are used to mediate any disputes over unfair treatment, including for workers’ representatives.
❒M
anagement does not place restrictions on the establishment and growth, on a voluntary basis, of free, independent
and representative workers’ organisations.
❒M
anagement does not permit interference with, obstruction or prevention of Trade Union activities.
❒ T rade union policies and procedures apply to homeworkers as well as workers on-site.
❒U
nions have access to homeworkers as well as workers on-site.
❒P
olicies and procedures regarding worker representation are effectively communicated to all workers (written policy,
employee handbook, other).
❒C
heck for evidence such as:
• notices about Trade Unions and other forms of worker representation;
• communications on notice boards;
• meeting reports/minutes are displayed for all workers to see (i.e. on notice boards) in relevant languages;
• election reports;
• list of union representatives and their functions.

4. Discrimination, Harassment and Abuse

1. equal opportunities are thoroughly respected;
2. there is no discrimination in any form and workers are treated with respect and dignity;
3. all recruitment and promotional activities are determined by ability to do the job;
4. no bullying, harassment or abuse of any kind exists;
5. disciplinary procedures are available, comprehensible, publicised and recorded.
EVIDENCE GATHERING ON DISCRIMINATION, HARASSMENT AND ABUSE COMMENTS

4.1 Document Checks
4.1.1 Payroll Records
❒ There is no pay inequality based on unfair or unlawful discrimination.
❒ All workers receive the benefits and other rewards to which they are entitled.
❒ No deductions are made for disciplinary reasons.
4.1.2 Personnel Records
❒ Workers records’ include:

• training Records;
• employment contract or letters of engagement;
• attendance records;
• termination records;
• records of disciplinary action and grievances.
❒ Management retains workers’ signed and dated training records of:

• discrimination policy;
• fair treatment policy;
• disciplinary and grievance procedures;
• equal opportunities policy;
• equality of treatments policy;
• treatment of workers;
• security procedures.
…
…
❒ Interview notes and application forms do not indicate discrimination in hiring workers practices (e.g. female workers
asked if they are likely to marry / have a family, older people turned away, relatively low proportion of migrant or
particular nationality of workers).
❒W
orkers’ contracts of employment confirm that all workers in the same roles are engaged under the same terms
and conditions.
❒P
regnant Workers. Check personnel records for:
• maternity leave records;
• cases of workers returning to their job after maternity leave;
• evidence that post-natal benefits are provided;
• evidence of other maternity or parental benefits being provided to workers;
• evidence of paternity leave and benefits being provided to male workers where required by law;
• cases of workers being moved from hazardous work whilst pregnant or breastfeeding.
4.1.3 Policy Documents

❒ T here are policy documents in place covering the following:

• recruitment & employment;
• compensation;
• access to training;
• promotion;
• termination and retirement;
• equal opportunities;
• discrimination ;
• health & safety;
• physical abuse and discipline;
• sexual or other harassment;
• abusive tone or language;
• other forms of intimidation;
• periods of notice before termination.
❒ F ull explanations of all policies are available to all workers in relevant language(s). Where literacy is an issue, policies
should be communicated by other means to ensure that workers are aware of them. Reference should be made to
appropriate policies within a worker’s contract of employment.

…
❒ Whether they are aware of all of the relevant procedures that are in place on the employment site.
❒ Whether workers have used the grievance procedures, and if so:

• if they think the procedures are effective;
• if they feel able to utilise the grievance procedures to raise issues with management;
• if management deal with any grievances openly and fairly.
❒ Whether workers think the disciplinary rules and procedures are fair.
❒ Whether workers feel discriminated against with regard to any aspect of their employment.
❒W
hether workers are subject to verbal or physical abuse. [Please Note: this is a sensitive subject and should be

approached cautiously and with respect for the feelings of workers.]
❒W
hether workers are subject to any unfair treatment or harassment. [Note: this is a sensitive subject and should be
approached cautiously and with respect for the feelings of workers.]
❒W
hether workers are aware of maternity or paternity benefits, and whether they have knowledge of any workers
being provided with maternity leave, other parental benefits and being able to return to work after maternity leave.
4.3 Management Interviews, Employment site Processes and Procedures
❒ T he employment site is fully aware of legal requirements on discrimination, harassment and abuse.
❒ T he employment site is aware of established international requirements concerning discrimination, harassment

and abuse, such as those detailed in the relevant code of conduct.
❒M
anagement have implemented an effective system (e.g. suggestions box, anonymous phone line, etc.) which allows
workers to leave anonymous comments for the employment site management.
❒ T he employment site’s recruitment advertising is compliant with the law and the requirements of relevant codes of conduct.
❒P
regnancy tests do not form part of the recruitment process.
…
…
❒M
anagement follow established policies and procedures regarding the following:
• recruitment & employment;
• compensation;
• access to training;
• promotion;
• termination and retirement;
• discrimination;
• health & safety;
• physical abuse and discipline;
• sexual or other harassment;
• abusive tone or language;
• other forms of intimidation;
• periods of notice before termination;
• worker appeals against unfair dismissal;
• disciplinary/Grievance procedures.
❒M
anagement are able to track pay rates across different groups, to ensure that policies on equal pay are being
adhered to and enforced.
❒M
anagement have an open attitude to managing the workforce, and are committed to the principles
of non-discrimination, equality and fair treatment.
❒W
here appropriate, notice boards are used to communicate the following:
• anonymous help-line numbers for workers to use if they want to raise an issue;
• grievance procedures detailing the employment site’s commitment to confidentiality;
• a right of appeal for workers;
• disciplinary procedures.
❒A
ny occurrences of verbal or physical abuse should be noted.
❒A
ny evidence that workers are anxious or fearful of managers/supervisors should be noted.

5. Health and Safety

1. all work and residential facilities provide safe and clean conditions for workers;
2. adequate steps are taken by management to prevent accidents and injuries;
3. workers are provided with access to adequate medical assistance and facilities;
4. workers are provided with access to clean toilet facilities, drinkable water and sanitary facilities;
5. residential facilities for workers, where provided, are clean and safe;
6. responsibility for health and safety is assigned to a senior management representative;
7. workers and management are provided with regular health and safety training;
8. adequate safeguards against fire are provided, plus stability and safety of buildings and equipment;
9. sufficient training of workers and management is undertaken in waste management, handling and disposal of chemicals and other dangerous materials.

EVIDENCE GATHERING ON HEALTH AND SAFETY COMMENTS

5.1 Document Checks
5.1.1 Records
❒ E vidence of the following documentation should be seen:
• valid equipment inspection certificates as per any applicable local regulations;
• machine maintenance reports;
• fire drill reports;
• appropriate building licences or production unit construction approval given by the local authorities;
• safety committee reports and any minutes from committee meetings, including issues raised and actions undertaken;
• employment site safety certificates;
• safety training reports;
• accident / injury / sickness register;
• risk assessment documents (e.g. reports and records) for work, residential and home working facilities;
• corrective action plans for eliminating or reducing the effect of the risks identified in the risk assessment;
• hazardous waste inventory and tracking records (e.g. disposal certificates, waste manifests, etc.);
• blood policy and procedures (linked to First Aid);
• needle and blade control policies;
• workers’ training certification;
• electrical safety policies and maintenance checks;
• water test records to ensure that water is consistently safe to drink;
• employment site waste management systems, processes, procedures and controls;
• PPE distribution records.

…
…
❒ T he employment site must have insurance for:
• workplace structure and contents;
• employers’ liability;
• worker accidents;
• fire.
❒M
anagement should provide health and safety training for all workers both on-site and engaged in work on other sites
on behalf of the employment site (i.e. homeworkers etc).
❒H
ealth and safety training should be appropriate to the tasks performed by the workers including demonstrations
and information about:
• machinery;
• chemicals;
• first aid and safety;
• housekeeping;
• PPE;
• other job-related training.
❒A
ll new or reassigned workers should be given a refresher training course on health and safety.
❒R
elevant workers should be given appropriate training on the use of hazardous materials.
In the following areas, the documentation should be checked as indicated:
❒ F ood hygiene:
• hygiene certificates of the food preparation area (if required by law) must be up to date;
• conformance with relevant food hygiene law and regulations;
• current records of kitchen staff’s training and certification demonstrate workers are adequately trained.
❒M
achinery:
• machinery safety certification (if required) present for each piece of machinery;
• machinery / equipment inspection and maintenance records kept up to date, and demonstrating that all machines
are working adequately.
❒C
hemicals and hazardous materials:
• a Material Safety Data Sheet (MSDS) must be held on record for each hazardous chemical held on-site;
• check availability of risk assessment reports for information on chemicals exposure;
• check availability of waste management records for hazardous materials.
❒V
entilation:
• review assessment report and action plan to ensure adequate ventilation on-site;
• check system inspection records are up to date;
• air quality tests should have been carried out should demonstrate that the air quality is sufficient.

…
❒ L ighting:
• check records of lighting tests to ensure that lighting is consistently of a reasonable standard.
❒ T emperature:
• review thermal stress assessment report and action plan to ensure appropriate temperature on-site;
• check temperature test records for the past year to ensure that the temperature remains comfortable even
at the hottest and coldest time of year.
❒N
oise and vibrations:
• review the noise and vibration risk assessment report to identify whether any risks exist to workers;
• review any employment site action plans on noise and vibrations.
❒ F ire:
• review evacuation plans for all areas of the employment site and any accommodation to ensure they are detailed and
appropriate;
• all buildings must have evacuation plans posted in prevalent areas and notice boards;
• all workers must receive fire prevention and evacuation training; records should be kept for all workers;

• review fire risk assessments and ensure they are up to date and actions are being followed to minimise risk;
• review fire safety certification for the employment site and accommodation where possible;
• every employment site must have an emergency plan / procedure / arrangements (e.g. fire wardens, coordination
with local fire brigade, etc.);
• review records of any fire evacuation drills to ensure time taken to evacuate building is within legal limits;
• fire evacuation drills must be conducted on a regular and frequent basis.
❒A
ll workers must have received health and safety training and records should be kept in their personnel files.
❒A
ny worker (worker or homeworker) using heavy machinery must have received training, and records should be kept.
❒A
ll workers should have received fire safety training.
❒ S afety instructions and fire evacuation routes must be communicated to all workers (e.g. through posters).
❒ S afety instructions are fully understandable, and displayed in workers’ native language(s).
❒W
here some workers are not able to read, instructions should be communicated in an alternative manner.
❒A
ny worker named as a first aider must receive adequate training, and records should be kept in their personnel file.
❒W
hether there is any worker representation on the Health & Safety committee.
…
…
❒W
hether they are aware of any of the following:
• H&S procedures (and have been trained on);
• accidents and injuries that have occurred on-site;
• what to do in the case of an accident;
• the H&S committee, how to use it and who the representatives are;
• fire evacuation procedures;
• the requirements for PPE and confirm that they use it on days when auditors or customers are not present.
❒W
hether workers have been involved in a fire drill in the past 12 months.
❒W
hether workers feel safe and secure in the workplace.
❒W
hether workers are happy with the general working conditions on-site, including:
• canteen, food storage and hygiene facilities;
• housekeeping;
• lighting;
• temperature;
• ventilation and air quality;
❒W
hat information has been provided to homeworkers on health and safety hazards and personal protective equipment?
❒ In relation to chemicals and hazardous materials:

• whether that the health of workers who handle hazardous materials is monitored. And if so, how?
• whether workers are aware of the hazards associated with exposure to the chemicals used;
• whether workers have received training on how to obtain and use the information provided on labels and MSDS.
❒M
anagement is aware of the national / local laws on health and safety including:
• accidents;
• medical assistance and first aid;
• worker facilities and resources (accommodation, toilets, canteens etc);
• management;
• waste and dangerous materials;
• machinery and transport;
• protective equipment.
❒ T he employment site has H&S policy and procedures in place, covering:

• occupational health and safety;
• both work and residential facilities.

…

❒ Management should ensure that steps are taken to minimise accidents and injuries on-site.
❒M
anagement should undertake appropriate health and safety risk assessments on a regular basis, to include:
• working environment;
• machinery, chemicals and other hazards;
• workers in hazardous roles;
• young workers, the disabled, women and other potentially vulnerable workers;
• night workers;
• fire risks;
• worker facilities and resources.
❒M
anagement must ensure that appropriate and effective personal protective equipment is provided to workers
(see PPE below, for more detailed information).
❒C
hemical handling and disposal procedures must be in place (see below for more detailed information).
❒ E quipment and maintenance procedures for machinery and tools must be in place (see below for more detailed

information).
❒V
entilation, lighting, temperature, noise and vibration monitoring procedures must be in place (see below for more
detailed information).
❒R
eview emergency and accident procedures. Specifically:
• fire evacuation procedures;
• accidents procedures;
• first aid arrangements.
❒ T here should be a Health and safety Committee on-site, and there must be worker representation on the committee.
❒A
ppropriate H&S training should be available for all workers.
❒ F irst aid risk assessments and records of injuries and accidents should be checked to ensure that risks are minimised
and accidents are investigated to prevent similar occurrences in the future.
❒ T here are at least 2 unlocked/unblocked fire exits on each floor of the employment site.
❒ T here are a sufficient number of fire extinguishers, fire hydrants and sprinklers to provide sufficient coverage
for the whole employment site.
❒A
ll fire safety equipment should be appropriate and have been checked within the past year.
❒A
ll fire exit signage should be clearly visible and fire exits must not be blocked.
…
…
❒ T here are Material Safety Data Sheets (MSDS) for all hazardous materials / chemicals.
❒R
eview safety arrangements at work stations.
❒M
SDS should be present in all areas where chemicals are stored and handled.
❒A
ll hazardous chemicals must be appropriately labelled.
❒C
heck machinery and/or tools to ensure that safety devices are in place and that staff use PPE correctly.
❒R
eview ventilation, lighting; temperature, noise and vibration to ensure all are appropriate
(see below for more detailed information).
5.4.1 Accommodation
❒ T he accommodation building (if provided) is not attached to the production area.

❒A
ny accommodation building should be stable and safe.
❒M
anagement must provide sufficient toilet facilities and washing facilities for all workers living in the accommodation.
❒ T he employment site should have local fire safety certification.

❒ T here are at least 2 unlocked/unblocked fire exits on each floor.
❒M
anagement should ensure that they provide a comfortable and safe living environment for workers.
❒ T he cooking area should be safe and hygienic.
5.4.2 Personal Protective Equipment
❒ E nsure PPE is freely available in the workplace (e.g. distribution points).
❒ E nsure PPE is freely available for homeworkers.
❒R
eview workers’ use of PPE in the workplace and at home (for homeworkers).
❒ E nsure that all workers are using PPE where it is necessary.
5.4.3 Machinery and Tools
❒M
achinery should be in good condition, with break downs kept to a minimum.
❒R
eview machinery handbooks to understand frequency of breakdowns.

…
5.4.4 Chemicals
❒M
anagement should keep a hazardous chemicals inventory.
❒M
anagement should ensure that chemicals handling & storage practices in the workplace (included labelling
and disposal) are well defined and communicated to all workers.
❒W
here necessary, information relating to the use of hazardous chemicals should be provided in alternative language(s).
5.4.5 Ventilation
❒ E nsure the ventilation system is sufficient and suitable.
❒C
heck whether ventilation is natural or artificial or both.
❒V
entilation is supplying fresh or purified air.

5.4.6 Lighting
❒ T he lighting system is sufficient and suitable.
❒W
hether it is natural lighting.
❒R
eview lighting distribution and usage conditions.
5.4.7 Temperature
❒ T he temperature of the employment site is comfortable and does not fluctuate.
❒A
ir conditioning and heating units are in use to ensure that the temperature is reasonable at all times.
5.4.8 Noise and Vibrations
❒W
hether noise and vibration levels are likely to have harmful effects on workers.
❒P
PE is provided to prevent harmful effects on workers as a result of noise or vibration.
5.4.9 First Aid
❒R
eview availability of appropriate first aid/medical facilities on-site:
• check dispensary or first-aid posts, cupboards, boxes or kits;
• expiration date of first aid supplies.

…
…
5.4.10 Manufacturing Hygiene Management (food and non food)
❒ E mployment site should have procedures for the following:

• crawling and flying pest controls;
• control of foreign bodies.
5.4.11 Drinking Water
❒P
otable water must be made freely available for all workers.
❒W
orkers have free access to potable water within accommodation.
❒W
orkers are able to leave their work stations at will for the purpose of accessing drinking water.
5.4.12 Toilet Facilities

❒ T here are sufficient numbers of clean and hygienic toilets, which are separated by gender.
There may be legal regulations re: the number of toilets which are required depending on the size of the workforce.
❒ E nsure the cleaning arrangements (e.g.: external or internal cleaners, cleaning frequency, etc.) are sufficient and
frequent enough to maintain clean toilet facilities.
❒A
ll workers have free access to toilets and are able to leave their work stations at will in order to access these facilities.
5.4.13 Food Preparation and Storage
❒M
anagement should ensure hygienic conditions of the food preparation and food storage areas.
5.4.14 Fire Safety Precautions
❒ S afeguards against fire are provided, including:

• fire extinguishers and / or hoses;
• fire and smoke detectors;
• emergency exits which open outwards and are unlocked / unblocked at all times;
• fire exit and warning signage;
• hazard / emergency lighting which runs in the event of a power cut or emergency;
• fire alarms which can be activated by detectors or workers and can be heard throughout the employment site.
❒ F ire safety equipment is regularly maintained with written documentation and that it is in good conditions.
❒ T here are at least 2 unlocked/unblocked fire exits on each floor in the employment site and any accommodation.

6. Wages, Benefits and Terms of Employment

1. work performed is on the basis of a recognised employment relationship;
2. obligations to workers and management are met;
3. wages, overtime pay, benefits and paid leaves are duly provided to workers and meet or exceed legal minimum and/or industry benchmark standards and/or
collective agreements, whichever is higher. Compensation should also meet basic needs and provide some discretionary income to workers and their family;
4. workers are provided with written and comprehensible information about their employment conditions, including wages, before they enter into employment; and
they receive details of their wages for the pay period concerned each time they are paid;
5. no deductions are made from wages for unauthorised reasons or reasons not provided for by national law and that such deductions are not used as a disciplinary measure;
6. all workers are provided with all legally required benefits, including paid leave;
7. workers are compensated for all overtime at a premium rate.

EVIDENCE GATHERING ON WAGES, BENEFITS AND TERMS OF EMPLOYMENT COMMENTS
6.1 Document Checks
6.1.1 Payroll and Attendance
❒A
ll workers (including part-time, home, agency and casual workers) receive at least the legal minimum wage for
all standard working hours. (Where there are legal minimum wages grades, for example based on skill, the auditor
should check that workers receive the applicable legal minimum wage).
❒W
orkers are not dependent on overtime pay to achieve a wage that allows workers to meet basic needs and provides
them with some discretionary income.
❒W
orkers are paid regularly, at least once per month and in line with their contract of employment.
❒W
orkers are paid by cash, cheque or bank transfer and not in kind.
❒N
ight workers are paid a premium which is at least in line with local law.
❒R
ecords pertaining to ex-workers should be checked to ensure that they have received:
• final salary payments;
• pay for unused leave or other outstanding payments;
• all required benefits;
• any severance pay due to them.
❒C
ross check attendance records, pay records and holiday records to ensure that they are consistent.
…
…
❒P
iece rate workers:
• check the wage calculation system applicable to piece rates;
• piece rate workers should be paid at least the legal minimum wage for all hours worked;
• check the mode and frequency of payments to piece rate workers;
• check that wage records clearly demonstrate how overtime rates are calculated.
❒O
vertime should be paid at a premium (there may be legal requirements which have to be met. In any case the
premium should be significant enough for it to be considered a ‘premium’ e.g. 125% of the normal rate).
❒M
inimum legal requirements for overtime premiums should be paid to all workers for:
• work over normal daily working hours;
• work over normal weekly working hours;
• work on weekly rest days;
• work on public holidays;
• work during annual leave days;
• night work.
❒ F or hourly paid workers, overtime pay should be calculated using the correct multiples of each worker’s basic wage.
❒D
eductions:
• deductions should be clear, legal and in proportion to the total wage (there may be legal restrictions on the maximum
amount which can be taken for one single deduction, and the total amount which can be deducted from wages for
each pay period);
• where deductions are for the reimbursement of loss of or damage to the employer’s property, check that they
only occur where it is legally permissible to do so and when it can be clearly shown that the worker concerned
was responsible. In such situations, deductions should be fair and should not exceed the amount of loss or damage
caused.
❒P
art-time workers:
• check the number of hours worked by part-time workers to ensure that they are truly part time
(there may be legal regulations on the maximum number of hours they can work.
6.1.2 Payslips
❒R
eview a sample of workers’ payslips [having sought permission]; the following information should be included on
wage or payslips:
• rates payable (based on hours worked: standard and overtime);
• the number of hours worked (standard and overtime) and any deductions;
• the method of calculating wages;
• the frequency of wage payments;
• the pay period concerned;
• the method of payment;
• any deductions from wages (e.g. tax, social / national insurance, rent, transport etc) and the conditions under which
deductions have been made.

…
…
❒G
uidance should be available to workers to help them understand their pay slips.
❒P
ayslips should be presented in a language that workers can understand.
6.1.3 Contracts
❒A
written and signed contract or letter of engagement is available.
❒W
orkers have a signed copy of their contract in their possession.
❒C
ontract should be written in a language that workers understand. Where literacy is an issue efforts must be made
to explain terms and conditions to workers.
❒C
ontracts or letters of engagement, for all types of worker, should include:
• job description;
• clear terms and conditions of employment;
• name of worker and employer;
• length of employment (should state if it is indefinite);
• presence and length of any probationary period;

• leave;
• notice periods;
• discipline and grievance procedures;
• pay;
• working hours.
❒P
robationary periods do not exceed the maximum specified by national law.
❒C
heck any special contractual arrangement for homeworkers.
❒C
heck any special contractual arrangements for migrant workers.
❒C
heck the contractual terms and conditions and working arrangements of homeworkers and part-time workers. Including:
• hours of work;
• contributions and other financial compensation in addition to basic wages;
• wages;
• social security benefits;
• frequency of work;
• notice periods.

❒ E ntitlement to work can be evidenced by:
• copies of legal documents for migrant workers;
• copies of applicable work permits;
• copies of ID documentation.
❒ L eave and benefits to which workers are contractually entitled should be recorded in personnel files.
…
…
❒ S igned copies of contracts or other required documentation should be held in personnel files.
❒R
eview application forms and interview notes to ensure that they are consistent with other documentation
and worker testimony.
❒D
eductions from wages require there to be a signed consent forms within the personnel files.
❒D
isciplinary records for any fines that have been levied against workers should be held on file.
❒ T ermination records within personnel files for all workers (including homeworkers, casual workers, agency workers
and part time workers) should show that the termination process followed was consistent with the contractual terms
and conditions.
6.1.5 Policies
❒ T he employment site should have clear written policies on the following:
• the use of fixed-term contracts, part-time work, casual work and homework (to ensure no excessive use of these
types of contract);
• the use of agency or contract labourers;
• the legal minimum wage;

• wage calculations;
• mode and frequency of payment;
• the applicable standards for workers’ compensation (basic needs must be met for all workers after applicable
company deductions have been taken out, such as payments for accommodation and food);
• benefits and insurance;

• equal pay for work of equal value;
• the prohibition of punitive fines;
• deductions;
• workers’ right of appeal regarding fines;
• payment for public holidays;
• social insurance (including the payment of monies deducted from wages to the appropriate authorities);
• sick leave;
• casual leave;
• maternity and paternity leave and benefits;
• workers’ ability to appeal decisions regarding deductions made from their wages;
• payment of overtime;
• the coverage of the health, safety and welfare of workers, in particular through:
- annual leave;
- sick leave entitlements and pay;
- maternity and paternity benefits;
- part time worker conditions;
• night work provisions.
…

…
❒C
heck that staff handbooks cover the following employment aspects:
• job description;
• performance targets;
• annual and sick leave;
• standard working hours;
• overtime regulations including the right to refuse overtime;
• applicable wage rates;
• holidays;
• benefits;
• promotion process;
• discipline;
• grievance procedures and termination policies.
6.1.6 Agency Agreements
❒ T here is an agreement between the employment site and the agency / labour provider.

❒ T here are agreements between the agency / labour provider and each worker on-site.
❒ T he charge rates of agencies are sufficient to pay workers all wages and other entitlements as well as agency costs
and an amount for profit (there may be regional or national guidance on how much this should be).
6.1.7 Production Records
❒P
roduction records of part-time workers and homeworkers should be referenced as a cross-check against working
hours records.
6.1.8 Worker Records
❒ T he employment site should have an up to date list of workers – including permanent, casual, temporary, seasonal,
agency, apprentices, vocational trainees.
❒W
hether workers (including agency, casual, part-time and home-workers) understand:
• how their wages are calculated, and their hourly and total pay rates;
• whether there are any deductions made from their wages, and if so, how much?
…
…
❒W
hether workers (including agency, casual, part-time and home-workers) are aware of:
• deductions or fines that come from their pay, and that they have agreed to them;
• their terms and conditions, and have a signed copy of their contract;
• all benefits and social security to which they are entitled.
❒W
hether they:
• receive a payslip each time they are paid, and that this is accurate;
• are financially stable and are able to earn enough to make ends meet and have some discretionary income;
• are permanent workers wherever possible, and that fixed term or agency workers are able to take permanent
positions where possible;
• are able to take paid maternity or paternity leave, as well as paid sick leave;
• have experience of any mistakes being made by payroll, and if so, how quickly any inaccuracies are corrected.
6.3 Management Interviews, Employment site Processes and Procedures
❒M anagement is aware of the national/local laws and international and industry guidelines on:
• employment;
• wages, overtime pay and benefits, workers’ basic needs and discretionary income;
• the communication of employment conditions;
• deductions;
• compensation for overtime.
[Note: When referring to industry benchmark standards, wages throughout the industry as a whole should be examined
to decide what “minimum wage” should be. This could be done in a multi-stakeholder forum that includes inter alia
governments, industry representatives, etc.]
❒M
anagement should ensure that employment is mutually beneficial for all workers – that there are no workers
treated differently or less favourably because of their employment status (including casual or part-time workers).
❒M
anagement should not engage ‘casual’ or part-time workers on a semi-permanent basis to avoid charges and other
obligations on the part of the employer.

7. Working Hours
1. working hours should comply with national laws, benchmarked industry standards or relevant international standards – whichever affords the greater protection to
the welfare of the workers;
2. the standard allowable working hours in a week are 48, excluding overtime. Workers shall not on a regular basis be required to work in excess of 48 hours per week;
3. overtime shall be voluntary, shall not exceed twelve hours per week and shall not be requested on a regular basis;
4. management should ensure that workers receive at least one free day following six consecutive days of working. This is given in addition to public and annual holidays;
EVIDENCE GATHERING ON WORKING HOURS COMMENTS

7.1 Document Checks
7.1.1 Records
❒ T he process for recording workers’ hours must be accurate.
❒P
roduction records separate standard time and overtime.
❒ T he employment site should have policies and procedures on working hours covering the following:
• terms of employment – regular working hours and days;
• overtime requirements and pay;
• non discrimination and equal opportunities;
• disciplinary and grievance procedures for lateness and other hours issues.
❒P
ay slips and payroll details should show the total number of hours worked.
❒C
heck the monthly working hours of selected employees for a minimum period of 3 months and note:
• the average;
• the highest;
• the lowest;
• days rest;
• days leave;
• days sick.
❒C
heck working hours against pay records to ensure there are no inconsistencies.
…
…
❒N
ormal hours of work for homeworkers are comparable to those workers performing similar or comparable work on-site.
❒Q
uality records and cross-check with the working hours records to establish whether quality issues and working hours
are linked.
❒ T he employment site has a copy of any required legal authorisations from local authorities giving dispensation
for working hours during peak seasons.
❒A
ny peak periods, when authorised, are clearly defined and limited in time.
❒C
heck workers’ contracts or letters of engagement for details on:
• workers’ standard working hours;
• workers’ entitlement to rest days;
• overtime requests and conditions;

• holiday allowances.
❒P
roduction and planning records, and records on working hours must be consistent.
❒C
heck the following details in workers’ personnel files:
• disciplinary and grievances relating to working hours/attendance;
• details of overtime requests.
❒W
orking hours should be included in any health and safety risk assessment to enable the employment site
to understand the implications of long hours on the safety and health of the workers.
❒W
orkers are offered the possibility of switching from full-time to part-time work (or vice versa) if work of that nature
becomes available.
• if such a change is requested by the employment site but rejected by the worker, this should not constitute a valid
reason for termination of employment.
❒A
ny measures that may limit or reduce the time spent by workers travelling between their residence and workplace,
such as:
• co-ordination of shift times (including night shifts) with local public transport timetables;
• provision of collective means of transport (such as buses);
• payment of appropriate compensation for additional travelling expenses;
• building of housing complexes within a reasonable distance of the workplace.

…
7.2 Worker Interview Checks
❒W
hat their standard working hours are.
❒W
hether they feel under pressure to work long hours.
❒W
hether any overtime hours they do are voluntary, and whether workers can refuse to work overtime without
experiencing any repercussions.
❒W
hether workers’ standard monthly salary is sufficient to meet their family’s cost of living, or whether it is necessary
for a worker to complete overtime to reach this level.
❒W
hen the breaks are during the day, and how long they last.

❒W
hether the breaks they are given are sufficient to rest and eat.
❒W
hether they have an entitlement to annual leave, when they can take it, and how they apply for that leave.
❒W
hether they are able to claim other types of paid and unpaid leave such as:
• maternity / paternity leave;
• sick leave;
• dependants / compassionate leave;
• marriage or wedding leave;
• other legally mandated leave (e.g. for state or religious holidays).
7.3 Management Interviews, Employment site procedures and Processes
❒ T he employment site is aware of local law regarding working hours, leave and breaks.
❒ T he employment site is aware of established international requirements on working hours, leave and breaks,
such as those detailed in the relevant code of conduct.
❒A
ll breaks and rest periods throughout the working day must be given in accordance with applicable laws.
❒ T he employment site must allow a period of rest between shifts that is in accordance with the law.
❒A
ll workers must receive the rest opportunities afforded to them by law.
…
…
❒R
est periods given to workers operating heavy machinery must be in accordance with the law.
❒P
regnant workers have the opportunity to switch from night shifts to day work with no change in pay.
❒N
ormal hours of work for night workers are comparable to the working hours of day workers.
❒R
eview notice boards to check whether the following information is communicated to workers:
• working hours (full time / part time / night/ overtime / peak periods);
• days off and rest periods;
• annual and other leave;
• arrangements regarding working hours for home workers, part-time workers, night workers or migrant workers.
❒ Information should be communicated in relevant worker languages.

❒ T here should be areas away from the production area where workers can rest or eat.
❒R
eview the facilities on offer in workers’ rest areas. For example, is there provision of food and beverages for workers?
❒O
bserve rest breaks and clocking in / out wherever possible.

introduction

Risk Assessment System
Appendix 4
GSCP Reference
Alert Notification
Audit Request
This tool is part of the broader set of Reference tools • a major non-compliance that has not been addressed or for
designed to provide a common interpretation of fair labour which no significant improvement has been made by the
Preparation
requirements and their implementation. They will enable time of a follow up audit, in spite of supplier commitment
buying companies around the world to work towards mutual to resolve the issue;
• an attempt to pervert the course of the audit through
The GSCP Reference tools are based on the GSCP Reference fraud, coercion, deception or interference.
Critical non-compliances include:
Audit Execution
conduct.
• inconsistencies between different types of documents and

worker testimony [see Section 4.4.2];
labour conditions and fundamental labour rights. The GSCP • child labour (reported or confirmed through documentation);
Reference Code is not a substitute for existing codes or
• involuntary, indentured, or involuntary prison labour
(including forced overtime and absence of payment);
• workers subjected to physical abuse;

Audit Outputs
Where a ‘critical’ non-compliance is identified, the auditor

should, wherever possible, inform the audit requestor within • workers subjected to sexual harassment or abuse;
24 hours. If the audit requestor is on site, the auditor should
• workers in immediate danger;
communicate the critical non-compliance immediately. This
will enable the audit requestor and the employment site to • workers not being paid at all;
work together to plan an appropriate and timely resolution
to the issue. • workers subjected to discriminatory practices (e.g. during
recruitment, workers are tested for medical conditions
Glossary
Please note, that if an auditor believes they might be at risk not required by law or product safety requirements, e.g.
as a result of communicating a critical non-compliance, the pregnancy, HIV/AIDS, hepatitis etc.);
audit team should wait until it is removed from that situation
before issuing the alert notification. • union members, union or worker representatives are
actively harassed, penalised or discriminated (directly or
Appendices
Auditors should prioritise the welfare of workers when indirectly) against;

deciding how to inform employment site management of any
critical non-compliance. Auditors should follow the escalation • attempted bribery;
policies of the audit requestor to minimise any risk to workers. • auditors denied access or obstructed from conducted from
A critical non-compliance is: conducting a proper audit;
• an issue which presents imminent risk to workers’ safety/ • evidence of the deliberate provision of false information to
risk to life and limb or constitutes a significant breach of auditors so as to disguise unfair labour conditions.
workers’ human rights, and/or;
01_Global Social Compliance Programme

INTRODUCTION
APPENDIX 4: GSCP REFERENCE ALERT NOTIFICATION

REFERENCE ALERT NOTIFICATION

1. Key Information
AUDIT REQUEST
EMPLOYMENT SITE AND AUDIT INFORMATION

Name of the audited company:
Supplier name:
PREPARATION
Country:
Audit date:
Date of alert:
AUDIT EXECUTION
Lead auditor:
Issue area(s):
AUDIT OUTPUTS
2. Details of critical non-compliance(s)
Critical non-compliances should be presented in a consistent format, with sufficient detail concerning the issue(s) and its
context to enable useful remediation discussions to begin. A table should be completed for each issue found.
CRITICAL NON-COMPLIANCE
GLOSSARY
Code or labour law provision in breach:
Description of critical non-compliance: APPENDICES

Auditor findings
(description, extent of issue, etc.):
Documentary, interview
and other evidence found:
Management response:
Proposed corrective actions:

INTRODUCTION

APPENDIX 5
GSCP Reference
Audit Report
AUDIT REQUEST
This tool is part of the broader set of Reference tools Note: The GSCP Reference Code gathers, in a single
designed to provide a common interpretation of fair labour framework, the main international standards for fair
PREPARATION
requirements and their implementation. They will enable labour conditions and fundamental labour rights. The GSCP
buying companies around the world to work towards mutual Reference Code is not a substitute for existing codes or
recognition of audit results. existing systems but brings together the standards and best
AUDIT EXECUTION
conduct.
The context, findings, issues and actions against each area

of the audit standard used should be reported to the audit requestor
AUDIT OUTPUTS
The report should be available in English to ensure that it • for each non-compliance or observation, the report should
can be shared with various stakeholders, as well as in the provide a:
language of the management wherever this is possible. The /d escription of the non-compliance or observation, its
report should be delivered to the audit requestor within 10 frequency and the number of people concerned;
business days of the audit.
/ e vidence found to substantiate it;
For each provision of the audit standard, the report should
GLOSSARY
/ classification to applicable law, code of conduct, etc.;

set out:
/ r ecommended corrective action with a timeframe for
• description of the current situation, including how specific completion, responsibility and verification method
requirements are managed by the employment site; required.
• provide evidence and information to substantiate the
APPENDICES
findings;

INTRODUCTION
APPENDIX 5: GSCP REFERENCE AUDIT REPORT

The report should include photos of the employment site Auditors may feel the need to produce a separate,
such as: supplementary report for the audit requestor containing:
• outside general overview; • information too sensitive for the audit report;
• inside general overview; • concerns which cannot be substantiated through evidence
and/or interviews;
• various stages of the manufacturing process;
• attitude of management towards the non-compliances or

• safety equipment;
the audit process as a whole.
AUDIT REQUEST
• machines guards;

• drinking water;
• first aid equipment; management on the day of audit;
• break room / staff room; • if workers appear to have been coached;
• toilets and showers as applicable; • if management was obstructive or reluctant to accept
PREPARATION
findings and the need for remediation;
• dormitories where applicable;
• where the auditor has concerns about the possibility of
• canteen where applicable;
double books or falsified records;
• kitchen where applicable;
• where sensitive issues could not be discussed during the
• best practices which can be photographed; closing meeting because of a potential risk to workers’
AUDIT EXECUTION
wellbeing.
• non-compliances which can be photographed.
Please refer to the Appendix 6, Reference Supplementary
Unless agreed by all parties in writing, the audit organisation Audit Information for guidance on communicating this type
will not distribute the report to any entities except the audit of information to the audit requestor.

requestor. However, the audit requestor should share the
report with the employment site/customer/supplier as soon
as possible in order to facilitate co-operation on continuous

improvement.
AUDIT OUTPUTS
GLOSSARY
APPENDICES

INTRODUCTION


1. GENERAL INFORMATION
1.0 Employment site contact Name:
details:
Address:
AUDIT REQUEST
Country:
Telephone:
Fax/email:
PREPARATION
GPS cordinates:
Is this site in an Export processing zone (EPZ)*? Yes ❒ No ❒
1.1 Audit date(s):
1.2 Report issue date:

AUDIT EXECUTION
1.3 Audit type: Initial Full audit Announced

Follow-up Partial audit Semi-announced
Unannounced
1.4 Audit conducted by: Auditing company (please provide name below)
Retailer
Brand Owner
AUDIT OUTPUTS
Purchaser
NGO
Union
Multiple parties. If yes, please list.
1.5 Audit personnel Name: Name:

GLOSSARY
(please specify the names Title: Title:

and titles of the auditors
and worker interviewers Name: Name:
who conducted the audit) Title: Title:
1.6 Time in and time out: In: Out:

APPENDICES
1.7 Previous audit details (if any): • Audited conducted by:
• Standard against which the audit was conducted:
• Audit date:
• Audit type:
…
* “Industrial zones with special incentives set up to attract foreign investors, in which imported materials undergo some degree of processing before being re-exported”
(ILO, 2007)

INTRODUCTION

…
1.8 Supplier name:
1.9 Main employment site contact: Name:

Position:
AUDIT REQUEST
Telephone:
1.10 Is the employment site involved Yes No

with any local Trade Unions
or NGOs?
If yes, provide nature
PREPARATION
of the involvement
1.11 Name and job title of Name:

employment site representative Title:
who signed the Summary of
Findings and Corrective Actions
1.12 Audits results reviewed by Yes No
AUDIT EXECUTION
employment site management?
1.13 Audit report author:
1.14 Audit report reviewer:

1.15 General remarks:
AUDIT OUTPUTS
GLOSSARY
APPENDICES

INTRODUCTION


2. EMPLOYMENT SITE INFORMATION

2.1 Production Systems and Processes
2.1.1 Industry sector:

AUDIT REQUEST
2.1.2 Principal products:
2.1.3 Main export markets:
2.1.4 Other major customers:

PREPARATION
2.1.5 Peak & low seasons: Peak season:

Low season:
2.1.6 Maximum capacity per month*:

AUDIT EXECUTION
2.1.7 Typical production level Jan Feb Mar Apr May June
as a percentage of total
capacity (by month):
July Aug Sept Oct Nov Dec

AUDIT OUTPUTS
2.1.8 Main production processes

(e.g. Stitching, labelling,
injection, moulding, baking,
harvesting, dyeing etc.):
2.1.9 Main production equipment:

GLOSSARY
2.1.10 Main raw materials used:
2.1.11 List of hazardous chemicals

used employment site:
APPENDICES
2.1.12 Shift times

(broken down by section):
2.1.13 Regular overtime hours:
* Auditor should check if an appropriate unit has been communicated (tonnes, number of pieces, containers…).

INTRODUCTION

2.2 Audit Overview and History

2.2.1 Applicable Code of conduct
AUDIT REQUEST
2.2.2 Did management display a positive attitude towards the applicable code Yes No
of conduct?
2.2.3 Were management co-operative during the audit? Yes No
PREPARATION
2.2.4 Were workers aware of the audit? Yes No
If yes, what was their attitude to the audit?
2.2.5 Were workers’ representatives involved during the audit? Yes No
AUDIT EXECUTION
2.2.6 Were workers’ representatives present at opening Opening meeting:
and closing meetings? Yes No
Closing meeting:

Yes No

2.2.7 Were any inconsistencies found? Yes No
AUDIT OUTPUTS
(If yes, please describe the nature of the inconsistencies – e.g. poor record
keeping, isolated incident, repeated occurrence, etc.
2.2.8 Was a perimeter survey undertaken? Yes No

(If Yes, please detail the results)
GLOSSARY
Result of Perimeter Survey:
2.2.9 Were any alert notifications issued as part of this audit? Yes No
APPENDICES
If yes, how many?

INTRODUCTION


2.3 Management Information

EMPLOYMENT SITE MANAGEMENT
2.3.1 Nationality of management:

2.3.2 Number of workers recruited in past year:

AUDIT REQUEST
2.3.3 Number of workers leaving in past year:
2.3.4 Worker turnover in past year

(no. leavers divided by the average total number of workers during the year)
2.3.5 Were management open and helpful? Yes No

PREPARATION
2.3.6 Were true records shown on first request? Yes No
2.3.7 Was documentation provided easily? Yes No
2.3.8 Were managers open to recommendations? Yes No

AUDIT EXECUTION
2.3.9 Do managers appear to have the capacity to implement changes? Yes No

AUDIT OUTPUTS
GLOSSARY
APPENDICES

INTRODUCTION

3. WORKFORCE
3.1 WORKFORCE SIZE
Male (#) Female (#) TOTAL (#)
AUDIT REQUEST
3.1.1 Permanent workers:

3.1.2 Temporary workers:
3.1.3 Agency workers
3.1.4 TOTAL WORKFORCE (sum of above)
PREPARATION
3.1.5 Piece rate workers:
3.1.6 Salaried workers:
3.1.7 Hourly paid workers:
AUDIT EXECUTION
3.1.8 Homeworkers:

3.1.9 Young workers:
3.1.10 Part-time workers:
AUDIT OUTPUTS
3.1.11 Night workers:
3.2 MIGRANT WORKFORCE
3.2.1 Percentage of migrant* workers!
3.2.2 Percentage of migrant* workers working at night:
GLOSSARY
3.3 YOUNG WORKER DETAILS
Peak Season Low Season

APPENDICES
3.3.1 Age of youngest worker: Male: Male:

Female: Female:
* The term ‘migrant worker’ refers to a person who is engaged in a remunerated activity, who has moved to a country, province or region of which he or she is not a native, where
they are not eligible or does not intend to become permanent residents.

INTRODUCTION


3.4 OTHER INFORMATION
3.4.1 Main languages spoken by workers:
3.4.2 Nationality of workers:

3.4.3 Average length of employment: Permanent workers Temporary/

(please specify period): agency workers
AUDIT REQUEST
(please specify period):

3.5 WORKER INTERVIEWS AND WORKER NUMBERS
Male (#) Female (#) TOTAL (#)

PREPARATION
3.5.1 Individual interviews (# of workers):
3.5.2 Group interviews (# of workers):
3.5.3 TOTAL NUMBER OF WORKERS INTERVIEWED:

AUDIT EXECUTION
3.5.4 Permanent workers interviewed:
3.5.5 Temporary workers interviewed:

3.5.6 Agency workers interviewed:

3.5.7 Piece rate workers interviewed:

AUDIT OUTPUTS
3.5.8 Salaried workers interviewed:
3.5.9 Hourly paid workers interviewed:
3.5.10 Homeworkers interviewed:

GLOSSARY
3.5.11 Young workers interviewed:
3.5.12 Part-time workers interviewed:

APPENDICES
3.5.13 Night workers interviewed:

4. SUMMARY OF GOOD PRACTICE, OBSERVATION
& NON-COMPLIANCES
NUMBER NON-COMPLIANCES
OF NON-COMPLIANCES. OBSERVED.
NUMBER NUMBER OF Please indicate if zero Please indicate if zero
TOPIC AREA OF GOOD OBSERVA-
PRACTICES TIONS
Code of Local
Critical Major Minor conduct Law
4.0 Management systems
4.1 Forced, bonded, indentured

& prison labour
4.2 Child labour and young workers

4.3 Freedom of association and right

to collective bargaining
4.4 Discrimination, harassment

and abuse
4.5 Health and safety
4.6 Wages and benefits
4.7 Working hours
OVERALL

5. REPORTING TEMPLATE
The audit report should include a table as per the example below for each section of the applicable code of conduct against which the audit was conducted. The tables
below refer to the GSCP Reference Code.
For follow-up audits, the report issued should be an updated version of the original report, with all new issues and updates to previous issues clearly highlighted.
An example of how to include follow-up information in the audit report template is shown below.
DESCRIPTION EVIDENCE
(Subject area [underlined], description of the finding, details (A description of the evidence observed and related to the audit
of the management position, any management involvement and element check guidelines. Please indicate the type of evidence listed e.g. worker
of the law/code that has been violated) interview, documentary, observational)
e.g. Policies and Procedures Documentary

Management had established a policy on the implementation of fair labour 0.1Policies seen were not signed by any manager.
standards, but no responsibility had been assigned and workers / management Management Interview
were not aware of the policy. 0.3 Managers reported that no individual had been given responsibility.
Follow up 01/06/09 – Follow-up 01/06/09 –

Management has allocated responsibility for the implementation of the policy. Documentary
This policy was communicated to all workers on 01/04/09 in the employment site’s Job description of Mr. Smith details responsibilities around fair labour standards
monthly meeting.
Management and worker interviews
Management and worker interviews confirmed communication at the meeting on
01/04/09.
Follow up 01/06/09 – New Issue Follow up 01/06/09 – New issue

Policies and Procedures Management Interviews
The employment site has not communicated revised compliance requirements to Management say that they are meeting with all subcontractors individually over
subcontractors the course of the next 3 months to detail changes to production methods and to
re-iterate compliance requirements.
INTRODUCTION

Definitions:
A non-compliance is a specific breach of the standard or code against which the employment site was audited.
Non-compliances may be Critical, Major or Minor
A minor non-compliance is:

• an occasional or isolated problem;
AUDIT REQUEST
• an issue which presents a low risk to workers/ those on-site;

• a policy issue or misunderstanding where there is no evidence of a material breach.
A major non-compliance is:

• a breach which represents a danger to workers/ those on-site;
• a material breach of a code requirement/ law;
• a systematic violation of a code requirement/ law.
PREPARATION
A critical non-compliance is:
• an issue which presents imminent risk to workers’ safety/risk to life and limb or constitutes a significant breach of workers’
human rights, and/or;
• a major non-compliance that has not been addressed or for which no significant improvement has been made by the time of
a follow up audit, in spite of supplier commitment to resolve the issue;
AUDIT EXECUTION
• an attempt to pervert the course of the audit through fraud, coercion, deception or interference.
An observation is:

• the identification of an opportunity for improvement;
• a possible issue which may develop into a non-compliance without further action;
• an issue which the auditor has some evidence to indicate may be present, but is not confirmed by more than one data point.
AUDIT OUTPUTS
A good practice example is:
• an issue that the auditor feels is over and above the standard against which the employment site was audited.
The auditor must be able to justify his/her classification with detailed evidence.
GLOSSARY
APPENDICES

MANAGEMENT PRACTICES
Report
Non-compliance Description Evidence Non-compliance

Type (Subject area [underlined], description of the finding, (A description of the evidence observed and violation
Good Obser-
details of the management position, any management related to the audit check guidelines. Please
Practice vation Critical Major Minor Code of Local
involvement and element of the law/code that has indicate the type of evidence listed e.g. worker
been violated) interview, documentary, observational) conduct Law
e.g. Policies and Procedures Documentary

Management had established a policy on the 0.1 Policies seen were not signed by any
implementation of fair labour standards, but no manager.
❒ ❒ ❒ ❒   ❒

responsibility had been assigned and workers / Management Interview
management were not aware of the policy. 0.3 Managers reported that no individual
had been given responsibility.
❒ ❒ ❒ ❒ ❒ ❒ ❒
❒ ❒ ❒ ❒ ❒ ❒ ❒
FORCED, BONDED, INDENTURED AND PRISON LABOUR
Report

Good Obser-
e.g. Bonded Labour Documentary

Original copies of worker passports are held by 1.2 Personnel files held original copies of
management. This is not a legal requirement in this passports.
❒ ❒  ❒ ❒ country.  ❒
Worker Interview
Violation of GSCP Reference Code 1.3 1.3 Worker interviews confirmed that they
cannot leave their jobs because they don’t
can’t retrieve passports
❒ ❒ ❒ ❒ ❒ ❒ ❒
❒ ❒ ❒ ❒ ❒ ❒ ❒

CHILD LABOUR AND YOUNG WORKERS
Report

Good Obser-
e.g. Young Workers Worker Interview

Young Workers were found to be working both 2.2 Worker interviews confirmed young
overtime and at night in some sections of the worker work night-shifts and overtime.

factory. Young workers interviewed said that there
❒ ❒  ❒ ❒  ❒
were no restrictions on their working hours, despite
management claims that overtime and night work
was restricted to workers over the age of 18.
Violation of GSCP Reference Code 2.3
❒ ❒ ❒ ❒ ❒ ❒ ❒
❒ ❒ ❒ ❒ ❒ ❒ ❒
FREEDOM OF ASSOCIATION AND EFFECTIVE RECOGNITION OF THE RIGHT TO COLLECTIVE BARGAINING
Report

Good Obser-
e.g. Collective Bargaining Documentary

Workers report instances where elements of 3.1.2 Documents show reference to
collective bargaining agreements have not been “appropriate overtime premiums”
upheld – in particular the payment of a premium but do not specify an amount.
❒ ❒ ❒  ❒ for weekday overtime work. Worker Interview  ❒
Management claim that this is due to 3.2 Workers report that they thought the
a misunderstanding during negotiations agreement reached was that overtime
and that this was never part of the agreement. would be paid at twice the hourly rate.
Freedom of Association Worker Interview

Worker representatives report that sometimes 3.2.1, 3.2 – Workers confirm that managers
❒  ❒ ❒ ❒ supervisors comment on their absence when they sometimes make comments, but have never  ❒
have been performing their representative duties tried to prevent a representative from
attending any meetings.
Freedom of Association Worker Interviews

Worker representatives are given 10 minutes 3.2 – Workers confirm that this is the case
at the end of every monthly production meeting Management Interviews
 ❒ ❒ ❒ ❒ to discuss union matters with union members. ❒ ❒
3.3 – Management say that they
Non-union members are not obliged to attend but implemented this initiative because it helped
can if they wish to. improve relations with the Trade Union.
❒ ❒ ❒ ❒ ❒ ❒ ❒
❒ ❒ ❒ ❒ ❒ ❒ ❒

DISCRIMINATION, HARASSMENT AND ABUSE
Report

Good Obser-
e.g. Discrimination Documentary

Some workers reported that workers of other 4.1.2 Attendance records show that workers
nationalities are given preferential treatment when of certain nationalities are more likely to

jobs are allocated at the beginning of the day. work in certain areas.
Violation of GSCP Reference Code 4.2 Worker Interview
❒ ❒ ❒  ❒ 4.2 Workers gave specific examples  ❒
of preferential treatment to workers
of a particular nationality.
Management Interview
4.3 Management were unable to explain
the reason for the allocation of jobs to
certain nationalities
❒ ❒ ❒ ❒ ❒ ❒ ❒
HEALTH AND SAFETY
Report

Good Obser-
e.g. Accommodation Observational

Workers’ accommodation has only one emergency 5.4.1 Auditor observed that there was only
exit. All accommodation requires at least one emergency exit from accommodation
❒ ❒  ❒ ❒ 2 emergency exits. Management reported that areas.  ❒
they were unaware of this regulation and will

make plans to add a second exit.
❒ ❒ ❒ ❒ ❒ ❒ ❒
❒ ❒ ❒ ❒ ❒ ❒ ❒

PRELIMINARY INFORMATION TO TOPICS 5.6 (Wages & Benefits) and 5.7 (Working Hours):
WORKING HOURS AND WAGES SUMMARY TABLE
Is there a legally applicable minimum wage? Yes No
If yes, are there different legal minimum wage grades? Yes No
Please indicate the legally applicable minimum wage.

Where applicable, please provide the details for all
of the different grades.
Where there are legally applicable minimum wage grades Yes No

in operation, are all workers graded correctly?
WAGES AND HOURS DATA Process Operator (Highest paid) Process Operator (Average paid) Process Operator (Lowest paid)
Pay Period (month/week)

Employee Identification / Staff ID# / Dept
Contract Hours (Monthly/Daily)
Regular Working Hours
Pay Rate for standard time
Regular Day OT (Hours)
Regular Day OT (Pay)
Rest Day OT (Hours)
Rest Day OT (Pay)
Statutory Holiday OT (Hours)
Statutory Holiday OT (Pay)
TOTAL OT HOURS IN PAY PERIOD
Incentives / Bonus / Allowances, etc.
Gross Wages
Social Insurance and Other Deductions
Actual Wage Paid after Deduction

WAGES, BENEFITS AND TERMS OF EMPLOYMENT
Report

Good Obser-
e.g. Terms of employment Documentary

Workers were not in possession of a copy of their 6.1.5 There is no procedure in place that
contract of employment. Management reported sets out when to give workers a signed copy
that copies were available on request, however of their contract.
❒ ❒ ❒  ❒ workers were unaware of this.  ❒

Worker Interview
Violation of GSCP Reference Code 6.1 6.2 Workers report that they have not
been given copies of their contract of
employment.
❒ ❒ ❒ ❒ ❒ ❒ ❒
❒ ❒ ❒ ❒ ❒ ❒ ❒

WORKING HOURS
Report

Good Obser-
e.g. Excessive Hours Documentary

Workers were found to be working more than 7.1.1 Working hours records show work
60 hours per week in some areas of the over 60 hours per week

employment site. Management said that this Worker Interview
❒ ❒ ❒  ❒  ❒
was due to the time of year, however records 7.2 Workers reported working over
show that this has been happening consistently 60 hours per week
over the past 4 months.
Violation of GSCP Reference Code 7.2 and 7.
❒ ❒ ❒ ❒ ❒ ❒ ❒
❒ ❒ ❒ ❒ ❒ ❒ ❒
INTRODUCTION

6. ON-SITE PICTURES
Auditors should include any relevant photos that were taken as part of the audit in this section of the audit report. Relevant
photos may include general pictures of the employment site – such as pictures of the employment site or pictures of the
production floor, or they may be specific to the details of the audit report – such as a picture of a non-compliance, observation

or best practice.
AUDIT REQUEST
The suggested photos below are examples, and the auditor should include all relevant photos.

Photo Photo Photo
PREPARATION
Outside view of employment site buildings Employment site entrance Processes
AUDIT EXECUTION
Photo Photo Photo

Sanitary Facilities Drinking water First aid box
AUDIT OUTPUTS
Photo Photo Photo
Non-compliance 1 Observation 1 Best Practice 1
GLOSSARY
Photo Photo Photo

APPENDICES
Photo Photo Photo
END OF TEMPLATE
INTRODUCTION

APPENDIX 6
GSCP Reference
Supplementary
Audit Information
AUDIT REQUEST
This tool is part of the broader set of Reference tools Note: The GSCP Reference Code gathers, in a single
designed to provide a common interpretation of fair labour framework, the main international standards for fair
PREPARATION
requirements and their implementation. They will enable labour conditions and fundamental labour rights. The GSCP
buying companies around the world to work towards mutual Reference Code is not a substitute for existing codes or
recognition of audit results. existing systems but brings together the standards and best
AUDIT EXECUTION
conduct.
SUPPLEMENTARY REPORT
AUDIT OUTPUTS
Auditors may feel the need to produce a separate, • if workers appear to have been coached;
supplementary report for the audit requestor containing:
• if management was obstructive or reluctant to accept
• information too sensitive for the audit report; findings and the need for remediation;
• concerns which cannot be substantiated through evidence • where the auditor has concerns about the possibility of
GLOSSARY
and/or interviews; double books or falsified records;

• attitude of management towards the non-compliances or • where sensitive issues could not be discussed during the
the audit process as a whole. closing meeting because of a potential risk to workers’
wellbeing.
APPENDICES
This type of report may not be appropriate where the audit

requestor is the employment site itself.
management on the day of audit;

INTRODUCTION RISK ASSESSMENT SYSTEM AUDIT REQUEST PREPARATION AUDIT EXECUTION AUDIT OUTPUTS GLOSSARY APPENDICES
Appendix 1: GSCP Reference Self Assessment Questionnaire Appendix 2: GSCP Reference Pre-Audit Employment Site Profile Appendix 3: GSCP Reference Audit Checks Appendix 4: GSCP Reference Alert Notification
Appendix 5: GSCP Reference Audit Report Appendix 6: GSCP Reference Supplementary Audit Information Appendix 7: GSCP Reference Summary of Findings and Corrective Actions

RELATED LABOUR
STANDARD(S)
EVIDENCE / OBSERVATIONS
(a description of the evidence
observed)
Reference supplementary audit information
APPENDIX 6: GSCP REFERENCE SUPPLEMENTARY AUDIT INFORMATION
(Description of the issue, who was involved or effected,
END OF TEMPLATE
and when this occurred)
AREA OF CONCERN
introduction

Appendix 7
Risk Assessment System
GSCP Reference
Summary of Findings
and Corrective Actions

Audit Request
This tool part of the broader set of Reference tools / follow-up audits are recommended for critical or
designed to provide a common interpretation of fair labour major non-compliances or when corrective actions can
Preparation
requirements and their implementation. They will enable be evaluated only through interviews and extensive
buying companies around the world to work towards mutual documentation reviews [see Section 5.4.1];
• timescale for completion: the amount of time required for
The GSCP Reference tools are based on the GSCP Reference the issue to be closed. The time allocated for corrective
Code but can be adopted and tailored to other codes of actions to be completed should be appropriate, realistic
Audit Execution
conduct. and timely.

Note: The GSCP Reference Code gathers, in a single framework, The Summary of Findings and Corrective Actions should:
the main international standards for fair labour conditions

• be clearly described and written in both English and the
and fundamental labour rights. The GSCP Reference Code
language spoken by the employment site management;
is not a substitute for existing codes or existing systems but
brings together the standards and best practices that could • be distributed as follows:
be applied. / a signed copy for the employment site manager;
Audit Outputs
The Reference Summary of Findings and Corrective Actions / a signed copy retained by the auditor together with
has been designed to provide a structure to the audit team’s other audit documentation;
findings and help the audit team develop a corrective action / a hard or soft copy to the audit requestor.
plan and structure a closing meeting.
NB: where employment site representatives are unwilling to
The Summary of Findings and Corrective Actions template sign an English language copy of the Summary of Findings
includes: and Corrective Actions, the auditor should still sign their
Glossary
• audit findings: Summary of non compliances, good practice, English language copy and should indicate that they have
and evidence found; witnessed the representative’s signature on the copy signed
by management.
• classification of non compliances;
• reference to the applicable code of conduct and/or law
Appendices
which has been contravened;

• recommended corrective actions: Auditors suggestion on
how the audit findings can be resolved;
• person/party responsible for corrective action;
• verification method:
/ a desk-based follow up may be used to verify corrective
actions for minor non-compliances but provide
verification should check corrective actions through
photos, copies of certificates, invoices, etc. submitted
by the employment site. Desk-based follow-up cannot
be used where actions need to be verified through
worker testimony;
01_Global Social Compliance Programme


REFERENCE SUMMARY OF FINDINGS
Auditor name and organisation:

APPENDIX 7: GSCP REFERENCE SUMMARY OF FINDINGS AND CORRECTIVE ACTIONS
Audit Date:
Time Out:
Time In:
AND CORRECTIVE ACTIONS
Client:
1. Employment site and auditor details
Employment site representative (name and position):

Employment site address:
2. Details of non-compliances and corrective actions

The audit findings are based upon on-site observation, interviews with employees, questionnaire data, and examination of company records:
Classification Reference
Audit findings (non Recommended corrective Person / party Verification Timescale for
of non- to applicable
compliance, observation) Actions responsible method completion
compliances code


(where required) required) (where required)

applicable code and observations)
completion method (where responsible Actions (where applicable)
Reference to Audit findings (good practices
Timescale for Verification Person / party Recommended corrective
3. Details of good practices and observations
4. Employment site comments or dispute of findings

Where an agreement cannot be reached between employment site management and auditors regarding findings and/or corrective actions, employment sites can
outline the disagreements in the box below:
Employment site representative

Comments Date
signature

5. Acceptance of findings and corrective actions
A closing meeting has been undertaken and the above findings and corrective actions were discussed and agreed:
Employment site representative name Signature - employment

Signature – auditor Date Date
And position site representative
Does the employment site Representative above have the authority to complete all actions listed? Yes No
If No, who would have the necessary authority to take decisions on these points?
(Please provide names, positions and contact details of additional managers):
END OF TEMPLATE

The GSCP is facilitated by
The Consumer Goods Forum
22/24 rue du Gouverneur Gal Eboué
92130 Issy-les-Moulineaux
France
www.gscpnet.com
gscp@theconsumergoodsforum.com

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// 1. Risk Assessment System 04

GLOBAL SOCIAL COMPLIANCE PROGRAMME_01

AUDIT PROCESS AND METHODOLOGY REFERENCE TOOLS - OCTOBER 2009

ABOUT THE GSCP REFERENCE TOOLS

from all sectors, categories and countries.

Overview of the audit process

The REFERENCE TOOL ON AUDIT PROCESS is designed to This can be done:

advice on ways to address common social compliance issues;

02_GLOBAL SOCIAL COMPLIANCE PROGRAMME

RISK ASSESSMENT SYSTEM

RISK ASSESSMENT SYSTEM

STEPS GSCP REFERENCE TOOL

 ollecting risk criteria. For example, by evaluating:

STEPS GSCP REFERENCE TOOL

STEPS GSCP REFERENCE TOOL

• Opening meeting • Reference Audit Checks (Appendix 3)

• Management and worker interviews

STEPS GSCP REFERENCE TOOL

• Audit reporting • Reference Audit Report (Appendix 5)

GLOBAL SOCIAL COMPLIANCE PROGRAMME_03

AUDIT PROCESS AND METHODOLOGY REFERENCE TOOLS - OCTOBER 2009

1. RISK ASSESSMENT SYSTEM

provided by the supplier or employment site either through

1.1 Self-assessment questionnaire

employment site, how it manages social compliance and

• process and timeframe for updating the self-assessment.

A Reference Self-Assessment Questionnaire is available in

04_GLOBAL SOCIAL COMPLIANCE PROGRAMME

RISK ASSESSMENT SYSTEM

• timeframe for completion of the pre-audit employment

GLOBAL SOCIAL COMPLIANCE PROGRAMME_05

Background and context review

AUDIT PROCESS AND METHODOLOGY REFERENCE TOOLS - OCTOBER 2009

3.1 Background and context review

3.2 Audit organisation

facility and that the necessary information and personnel may

• unannounced (the employment site has no prior warning

employment site). allowed full access to the employment site;

> Unannounced audits > Semi-announced audits

06_GLOBAL SOCIAL COMPLIANCE PROGRAMME

RISK ASSESSMENT SYSTEM

Communicating the audit arrangements

should reflect, as a minimum: CONTRACT NUMBER INTERVIEW

GLOBAL SOCIAL COMPLIANCE PROGRAMME_07

Background and context review

AUDIT PROCESS AND METHODOLOGY REFERENCE TOOLS - OCTOBER 2009

Communicating the audit arrangements

Minimum worker interview sample size and person day requirements:

TOTAL MINIMUM INTERVIEW PERSON DAYS ON-SITE*

08_GLOBAL SOCIAL COMPLIANCE PROGRAMME

RISK ASSESSMENT SYSTEM

Communicating the audit arrangements

/ health and safety documents:

GLOBAL SOCIAL COMPLIANCE PROGRAMME_09

ollecting risk criteria. For example, by evaluating:

• Opening meeting • Reference Audit Checks (Appendix 3)

• Audit reporting • Reference Audit Report (Appendix 5)

• timeframe for completion of the pre-audit employment

• unannounced (the employment site has no prior warning

1. Child Labour and forced labour; - Document review: Time records,

• opening meeting; • off-site visits when necessary (e.g. to interview homeworkers;

/ potential benefits to the employment site (opportunity

• understand the work done at the employment site; • time records;

constraints; • the physical construction and layout of the employment

• neighbouring facilities (e.g. hospitals, clinics, restaurants,

best practice to use interviewing techniques to encourage / worker representatives;

/ workers not wearing uniform;

• workers within the three contract type categories should Location:

• a policy issue or misunderstanding where there is no