Score Card Report

FACTORY AUDIT INFORMATION SUPPLIER

Location ID: M00088 Audit Form Name : JCP - ELEVATE - Audit Tool - V45 Supplier ID and Name: M00088 ELCATEX S. DE R. L.
Location Name: ELCATEX S. DE R. L. Assessment Type: 3. Cycle SA Audit
Address: Carretera A Puerto Cortes, Entrada Colonia Start Date: 11 Jul 2019 08:30 AM
La Mora Costado N.O. De Zip Choloma, Completed Date: 12 Jul 2019 03:30 PM
Complejo Zip Tex
Rating: Fair
City/State/Zip: Choloma, Cortes Honduras
Email:
Factory Contact Name: Juan Carlos Rivera
Factory Contact Email: jrivera@elcatex.com
Factory Contact Phone: (504) 2617-7700

Final Category
ID QUESTION TEXT RESPONSE PRIORITY
FC001 Auditor Name Ana Lucia
Fuentes
FC002 Performance Rating: Fair
FC004 Score (%): 84
(Note: enter number only, NO %-sign)
FC003 Audit Cycle: 12 months
FC004 Next Audit Date: 07/12/2020

LAWS AND REGULATIONS

ID QUESTION TEXT RESPONSE PRIORITY
1.1 1.1 Factory's policies, procedures and practices for obtaining, implementing, and retaining current information on local and national laws concerning all
aspects of the Code of Conduct are incomplete.(D)
1.2 1.2 New laws and/or revisions to existing laws and regulations are not maintained and communicated by facility on a timely basis (I D).
1.3 1.3 Employment contracts as required by law are missing or improper (D).
1.4 1.4 Employment contracts are not approved by the local authorities as required by law (D)
1.6 1.6 Apprenticeship/probationers/temporary contracts (seasonal or otherwise)/labour contracts are improperly used (I D)
1.7 1.7 Required government licenses, No Objection Certificates (NOC), permits, waivers and certificates, risk assessments for machinery, (other than
building and fire permits/license) are not all present on site as required by law (D)
1.8 1.8 Fire safety licenses and/or permits for all floors and buildings are not completely approved by the relevant authority as required by law (D)
1.9 1.9 Valid building design/construction approval documentation for brick-and-mortar/concrete structures is missing, but a third-party structural
assessment report is available.
1.10 1.10 Valid contracts/appointment letters/work permits for migrants and/or refugees as required by law are missing.
1.11 1.11 Only Copies of fire safety, plans or permits for all floors and building (including dormitory extension or deviation) are provided during audit
1.12 1.12 Other (I O D)

CHILD LABOR
ID QUESTION TEXT RESPONSE PRIORITY
2.1 2.1 Workers below 16 or the legal age of employment are found working (I O D)
2.2 2.2 Children present in the facility but not working (except in approved, separated childcare facilities) (I O)
2.3 2.3 Legal young workers missing proper documentation of authorization to work (I O D)
2.5 2.5 Legal young workers not working within the appropriate conditions of employment as required by law (I O D)
2.6 2.6 Record review indicates Historical Child Labor in the last 12 months (e.g. workers hired prior to legal working age) (I D)
2.7 2.7 Records verifying the age of all employees are incomplete, inappropriate, or missing (in the event no workers appear to be young within the
facility) (D)
2.8 2.8 Other (I O D)
2.9 2.9 The facility does not have a written hiring and age verification procedure in place.

FORCED LABOR
ID QUESTION TEXT RESPONSE PRIORITY
3.1 3.1 Workers are prohibited from leaving the facility or dormitory during certain times (I O D)

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 3.2 3.2 Government issued identification, passports, and/or work permits are withheld (I O D)
3.3 3.3 Excessive restrictions are placed on worker movement for basic liberties (e.g., bathroom, drinking water, use of infirmary, etc.) (I O D)
3.5 3.5 Personal leave for emergencies and other needs is systematically denied (I O D)
3.6 3.6 Employees not willing to work overtime are terminated or receive disciplinary action (I D)
3.7 3.7 Facility is using prison, bonded, and/or indentured labor (I O D)
3.8 3.8 Facility is using any kind of involuntary labor (I O D)
3.9 3.9 Other (I O D)
3.10 3.10 Workers consent for overtime or night shift is not taken by the facility as required by law

HARASSMENT AND ABUSE

ID QUESTION TEXT RESPONSE PRIORITY
4.1 4.1 Physical punishment or abuse (I O D)
4.2 4.2 Evidence of sexual harassment (I O D)
4.3 4.3 Evidence of verbal / emotional abuse, coercion, and/or harassment is observed (I O D)
4.4 4.4 Monetary fines are used as a form of discipline (I O D)
4.5 4.5 Employer does not document and communicate to all employees a progressive disciplinary policy (e.g., escalating disciplinary action steps such
as verbal warning, written warning, suspension and termination) (I O D)
4.6 4.6 Written records of disciplinary actions are not maintained by employer (D)
4.7 4.7 Other (I O D)

WAGES AND BENEFITS

ID QUESTION TEXT RESPONSE PRIORITY
5.1 5.1 Pay records are missing, incomplete, inconsistent and/or unreliable (I O D)
5.2 5.2 Wages are not being paid (I D)
5.3 5.3 Minimum wage violations (I D)
5.4 5.4 Overtime wage violations (I D)
5.5 5.5 Wages and/or benefits are systematically miscalculated (I D)
5.6 5.6 Wages are miscalculated in isolated occurrences (e.g., computer/human error) (I D)
5.7 5.7 Illegal wage deductions (I D)
5.8 5.8 Compensation is not directly issued to workers (I D)
5.9 5.9 Wage payments are late (I D)
5.10 5.10 Employee wages and/or certain parts of the salary are withheld as deposits, or deposits are required as condition of employment (I D)
5.11 5.11 Pay stubs are not provided to workers (I D)
5.12 5.12 Legally mandated benefits are not provided (I O D)
5.13 5.13 Employee mandated withholdings are not remitted to the appropriate government agency (I D)
5.14 5.14 Social insurance is insufficient as per local law.
5.15 5.15 Other (I O D)

HOURS OF WORK
ID QUESTION TEXT RESPONSE PRIORITY
6.1 6.1 No time records (I O D)
6.2 6.2 Time records are systematically inconsistent or unreliable (I O D)
6.3 6.3 Time records are systematically incomplete or missing (I O D)
6.4 6.4 Time record(s) is/are missing or incomplete in isolated occurrences (I O D)
6.5 6.5 Employees do not record time through an automated time recording system (I O D)
6.6 6.6 Time clock is not in working condition (I O D
6.7 6.7 Work is done off the clock (I O D)
6.8 6.8 Workers are systematically working excessive overtime (I O D)
6.9 6.9 Workers are working excessive overtime in isolated occurrences (I D)
6.10 6.10 Legally-mandated rest day is not provided (I D)
6.11 6.11 Legally mandated holidays and vacation days are systematically denied (I D)
6.12 6.12 Mandated meal and rest breaks are systematically denied (I O D)
6.13 6.13 Workers are not informed about updated timing of regular work hours, shift hours, and weekly off-time by writing, notice board, or other
communication (I O D)
6.14 6.14 Other (I O D)

HEALTH AND SAFETY : Clauses apply to both production areas and dormitories
ID QUESTION TEXT RESPONSE PRIORITY

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 7.1.1 7.1.1 Building design/construction approvals, licenses and/or permits for brick-and- mortar/concrete production or dormitory structures are missing,
invalid, or incomplete
7.1.2 7.1.2 Emergency evacuation plan is missing or inaccurate (O D)
7.1.3 7.1.3 Fire hazards are immediately present (O)
7.1.4 7.1.4 No emergency exit signs or lighting for all exits (O)
7.1.5 7.1.5 Emergency exit signs or lighting are missing in isolated occurrences (O)
7.1.6 7.1.6 Evacuation signs and lighting or evacuation markings on a floor are missing systematically (O)
7.1.7 7.1.7 Evacuation signs and lighting or evacuation markings on a floor are missing in isolated occurrences (O)
7.1.8 7.1.8 Number of exits is insufficient (O)
7.1.10 7.1.10 Designated emergency exit doors do not open in an outward direction (O)
7.1.11 7.1.11 Fire escape does not lead to the exterior of building (O)
7.1.12 7.1.12 Exit door width is not in compliance with law (O)
7.1.14 7.1.14 Main exits do not discharge directly to the exterior of the building (O)
7.1.15 7.1.15 Stairwells are not wide enough (O)
7.1.16 7.1.16 Handrails are not installed on both sides of stairwells or ramps if required by local law (O)
7.1.17 7.1.17 Aisle width is less than local law or in the absence of law 36 inch (0.91 meters) (O)
7.1.18 7.1.18 Aisles are fully blocked (O)
7.1.19 7.1.19 Aisles are partially blocked permanently (O)
7.1.20 7.1.20 Aisles are partially blocked temporarily (O)
7.1.21 7.1.21 Space between each workstation is inadequate to allow for free body movement and for emergency evacuation (O)
7.1.22 7.1.22 Areas in front of emergency exits, fire equipment, control panels and evacuation routes are not marked to indicate that they are to be kept
clear at all times (O)
7.1.23 7.1.23 Internal stairwells and mezzanine are made of wood, metal, and/or another material that conducts heat or is flammable (O)
7.1.24 7.1.24 Hydrant/Hose reel/ Stand pipe are not installed (O)
7.1.25 7.1.25 Water reserve for fire safety is missing based as per local law (O)
7.1.26 7.1.26 Warning signs indicating lift is not to be used in case of factory fire are not posted at each lift station (O)
7.1.27 7.1.27 Fire drills are not documented through digital pictures with, at minimum, a date stamp. (D)
7.1.28 7.1.28 Fire-fighting equipment including fire alarm switches are not accessible (O)
7.1.29 7.1.29 Fire fighting equipment is not functional (O)
7.1.30 7.1.30 No fire extinguishers (O)
7.1.31 7.1.31 Number of fire extinguishers is insufficient based on local law requirements (O)
7.1.33 7.1.33 Fire fighting equipment is not serviced or inspected according to local law or at minimum every six months with records kept (O D) Non-Compliant HIGH
Comments
• No checklist posted in hose stations.
• Detailed Finding:
It was noted no checklist posted in hose stations. Please note that during the audit management placed the checklist in all hose stations.

• Legal Requirement:
“According to JCPenney Guideline – English May 2018”
• Recommendation:
It is recommended to maintain an updated inspection checklist in all hose stations.

7.1.34 7.1.34 Fire extinguishers are not appropriate to the types of potential fires in the various areas of the factory and labeled according to the types of
fires they are to be used for (O)
7.1.35 7.1.35 Frequency of fire drills is insufficient (I D)
7.1.36 7.1.36 Fire drills are not conducted for any shift of work (I D)
7.1.37 7.1.37 No individuals are trained in fire safety as per local law or, in absence of law, at least twice per year.(I D)
7.1.38 7.1.38 Number of individuals trained in fire safety is insufficient per local law (I D)
7.1.39 7.1.39 Workers are exposed to hazardous chemicals or substances (I O)
7.1.40 7.1.40 Workers are not trained on proper use of chemicals (I D)

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 7.1.41 7.1.41 Eye wash/shower station is missing or not functional from chemical handling section, chemical storage section, and/or spot removing section Non-Compliant HIGH
(O)
Comments
• Missing eye wash station.
• Detailed Finding:
It was noted missing two eye wash station; one in the workshop of the new cutting building and the other in tanks for the storage and
distribution of peroxide, citric acid. Furthermore, the facility has installed saline bottles in all maintenance workshops and oil storage of knitting
area.

• Legal Requirement:
“According to JCPenney Guideline – English May 2018”
• Recommendation:
It is recommended to install automatic eyewash stations in cutting building and replace saline bottles with appropriate eyewash stations in all
areas where chemicals are stored and handled.

7.1.42 7.1.42 Chemical and hazardous materials are not stored in a well ventilated area designed for and dedicated to storage of such substances (O)
7.1.43 7.1.43 Bulk chemicals are not stored in appropriate secondary containers kept off the ground (O)
7.1.44 7.1.44 Chemicals are not labeled with appropriate safety precautions (O)
7.1.45 7.1.45 MSDS/CSDS for hazardous chemicals is missing or inadequate (O D)
7.1.46 7.1.46 ''No Smoking'' signs are not posted in production areas, boiler room, chemical room, transformer room, generator room, storage areas, waste
areas and power station room.
7.1.47 7.1.47 Electrical systems do not include circuit breakers or fuse boxes (O)
7.1.48 7.1.48 Electrical wiring is not in good and safe condition (O)
7.1.49 7.1.49 Electrical panels and switchboards are not properly marked, maintained, or insulated (O Non-Compliant HIGH
Comments
• No rubber mats in all electrical panels.
• Detailed Finding:
It was noted no rubber mats in all electrical panels of the production floor; nevertheless, during the audit management showed the rubber mats
and equipment used by the electricians when maintenance is conducted.

• Legal Requirement:
“According to JCPenney Guideline – English May 2018”
• Recommendation:
It is recommended to place rubber mats under the electric panels. Management reported initiating the process of purchasing the rubber mats.

7.1.51 7.1.51 Machines are not equipped with emergency stop switches where applicable (O)
7.1.52 7.1.52 Machine guards are missing (O)
7.1.53 7.1.53 Regular machinery maintenance program is not available/conducted (D)
7.1.56 7.1.56 Personal protective equipment is not provided to all employees free of charge (I O)
7.1.57 7.1.57 Personal protective equipment is not properly provided or utilized in isolated occurrences . Non-Compliant MEDIUM
Comments

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 • Workers using pallet jacks and carts with fabrics without safety shoes.
• Detailed Finding:
It was observed workers in departments of Crudo, Acabado, Cutting using pallet jacks and carts with fabrics without safety shoes. The factory
management has identified in the job safety analyses the use of safety shoes for those workers. During the audit, the management showed the
quotation for the purchase of safety shoes as well as the total of workers that will be provided with safety shoes.

• Legal Requirement:
In accordance to General Regulation of Preventive Measures of Work Accidents and Occupational Diseases (Reformed). Art. 269 and 305. The
use of means of personal protection will be mandatory when the use of collective protection means is not possible, or if these means do not
guarantee full protection of professional risks. In jobs where there is a risk of falling heavy objects or pinching fingers under heavy loads, safety
footwear will be used that will have steel toe caps or to protect the feet of the worker against the penetration of sharp objects.

• Recommendation:
It is recommended to finalize the purchase of the safety shoes and provide them to workers in accordance with the risks of the job operation.

7.1.58 7.1.58 Personal protective equipment is not properly provided or utilized systematically
7.1.59 7.1.59 First aid supplies are not available on each floor as per local law
7.1.60 7.1.60 First aid kits are not fully stocked as per local law
7.1.61 7.1.61 Factory does not provide health and safety training as required by local law
7.1.62 7.1.62 Number of individuals trained in first aid is insufficient per local law (I D)
7.1.64 7.1.64 Facility ventilation is poor (I O)
7.1.65 7.1.65 Temperature control is missing or inadequate (I O)
7.1.66 7.1.66 Workspace lighting is inadequate (O)
7.1.67 7.1.67 Drinkable water is unavailable (I O)
7.1.68 7.1.68 Drinking water is unsafe (O D)
7.1.69 7.1.69 No training/certification for kitchen or canteen workers as per law
7.1.71 7.1.71 No management representative responsible for health AND safety as required by law.
7.1.72 7.1.72 Food preparation and eating areas are not clean and/or food service company does not have legal permit (O)
7.1.73 7.1.73 Eating facility is unavailable and/or is not protected from the elements and/or has inadequate seating/tables/lighting (O)
7.1.74 7.1.74 Unsanitary facility conditions such as excessive dust, waste, trash, garbage, etc (O)
7.1.75 7.1.75 Toilets are not sanitary, and/or well-lit, well-ventilated, or stocked with toilet paper, soap, towels, and running water (O)
7.1.76 7.1.76 Number of toilet facilities are insufficient as per local law
7.1.79 7.1.79 Toilets are not provided with appropriate privacy (stalls with doors) (O)
7.1.80 7.1.80 Generators are not on the ground level or basement.
7.1.81 7.1.81 Industrial facility is a converted residential building (O)
7.1.82 7.1.82 Facility is in a multi-use building housing multiple unrelated business types (I O)
7.1.83 7.1.83 Building is shared with multiple owners or leaseholders (I O D)
7.1.85 7.1.85 Daycare facility is not located on factory premises as required by local law, or on the ground floor in the absence of local law (O)
7.1.86 7.1.86 Boilers and other heat producing equipment (e.g. furnace) are not separated from production floor as local law requires, or if there is no law, by
a five inch brick and mortar wall (O)
7.1.87 7.1.87 Generators and oil-filled transformers are not separated from the production floor as local law requires, and if there is no law, by a ten inch
brick and mortar wall (O)
7.1.89 7.1.89 Records for medicine consumption are missing or incomplete as per local law.
7.1.90 7.1.90 Records for work related injuries and accidents are missing or incomplete (D)
7.1.91 7.1.91 Process for external medical treatment of workers in the event of occupational injury or illness is missing (I D)
7.1.92 7.1.92 Factory is not undertaking, maintaining and paying for regular occupational health tests for employees as required by law
7.1.93 7.1.93 Operators are not trained on safe operating procedures with documented records (I D)
7.1.94 7.1.94 The facility does not have a Health and Safety Committee / Worker Participation Committee as per local law (I D)
7.1.99 7.1.99 Eye wash stations are not tested for general good conditions at least once per month
7.1.100 7.1.100 Evacuation safety/assembly points are not assigned.
7.1.102 7.1.102 Roof, mezzanine floors, and/or floor openings are not covered or protected to prevent falls and accidents.

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 7.1.103 7.1.103 Workers are not communicated and trained on proper use of personal protective equipment and the effects of non-use(I D)
7.1.104 7.1.104 No gap was present between the rack and the wall as required by local law in the storage areas
7.1.105 7.1.105 Exit Signs, Evacuation plans, MSDS sheets should be in a language understood by majority of the workers
7.1.106 7.1.106 Designated emergency exit doors do not open in an outward direction but it is equipped with a mechanism to ensure doors are locked open
during work hours
7.1.109 7.1.109 Missing electrician (hired or outsource) to maintain the electrical system.
7.1.110 7.1.110 Exits of internal departments / sections are partially or fully blocked /locked
7.1.111 7.1.111 No connection with an earth continuity conductor (ECC). Notation: includes all type of Motors/ drill machines/ grinding machines/ electric
irons/ electric kettles.
7.1.112 7.1.112 No connection with an earth continuity conductor (ECC) in isolated case. Notation: includes all type of Motors/ drill machines/ grinding
machines/ electric irons/ electric kettles.
7.1.113 7.1.113 Auto Fire Extinguishing system such as Sprinkler is missing as per local law
7.1.114 7.1.114 No Fire Alarm is installed and audible throughout all section of the facility.
7.1.115 7.1.115 The fire alarm system is installed and audible only in isolated areas.
7.1.116 7.1.116 The fire alarm system is not equipped with battery back-up in the factory.
7.1.117 7.1.117 The alarm system is not equipped with battery back-up in isolated case.
7.1.118 7.1.118 The fire alarm system is not in function at the factory.
7.1.119 7.1.119 The fire alarm system does not function in isolated case.
7.1.120 7.1.120 There is no fire detection (Smoke, heat, and/or flame) whatsoever installed in the facility.
7.1.121 7.1.121 The fire detection (smoke, heat, and/or flame) is insufficient.
7.1.122 7.1.122 Other (I O D)
7.1.123 7.1.123 Emergency exits, stairwells, or stairwell landings are locked or fully blocked but alternative emergency exits available Non-Compliant CRITICAL
Comments
• One of two emergency exits in the Crudo area was blocked with a loading cart. The emergency route has a stowed cloth with a height of
approximately
2 meters.

• Detailed Finding:
During the factory tour, it was observed that one of two emergency exits in the Crudo area was blocked with a loading cart. Also, the other
emergency
route has a stowed cloth with a height of approximately 2 meters, which represents a risk of obstruction of the emergency route and emergency
door.
• Legal Requirement:
In accordance to General Regulation of Preventive Measures of Work Accidents and Occupational Diseases (Reformed). Art 61, 3. The doors
and
emergency exits no obstacles will be allowed to interfere with the normal exit of the workers, avoiding in any case the agglomerations.
• Recommendation:
It is recommended to maintain at all times emergency exits and evacuation routes free from obstructions
7.1.124 7.1.124 Emergency exits, stairwells or stairwell landings are partially blocked
7.1.125 7.1.125 Anti-explosive lights and/or covers are not installed in areas in which flammable and combustible materials are stored (e.g. warehouses,
chemical storage, etc.).
7.1.126 7.1.126 Factory is not monitoring and assessing the factors of occupational disease hazards regularly at the workplace as required by law (Auditor
guidance: It's acceptable if the type of test report is Entrust/Commision)
7.1.127 7.1.127 Gas cylinders are properly marked, used, inspected, stored, and secured.
7.1.128 7.1.128 Noise level tests are not conducted as required by law

HEALTH AND SAFETY : Dormitories

ID QUESTION TEXT RESPONSE PRIORITY
7.2.1 7.2.1 Rooms are not segregated by gender (I O)
7.2.2 7.2.2 Dormitory is not separate from the production area (O)
7.2.3 7.2.3 Residents are not provided with their own mats or beds (I O)

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 7.2.4 7.2.4 Residents are not provided with adequate living space (I O)
7.2.5 7.2.5 Residents are not provided with locked storage space (I O)
7.2.6 7.2.6 Number of toilet and shower facilities is insufficient per local law (O)
7.2.7 7.2.7 No showers with hot water (O)
7.2.11 7.2.11 Other (I O D)

NON-DISCRIMINATION
ID QUESTION TEXT RESPONSE PRIORITY
8.1 8.1 Disciplinary procedures are taken against workers based on personal characteristics (I O D)
8.2 8.2 Personnel policies, work rules, and practices include discriminatory practices based on personal characteristics (I O D)
8.3 8.3 Opportunities for overtime are provided to workers based on personal characteristics (I O D)
8.4 8.4 Wages or benefits are systematically provided based on personal characteristics (I O D)
8.5 8.5 Wages or benefits are provided based on personal characteristics in isolated occurrences (I O D)
8.6 8.6 Policies prohibiting discrimination are absent (D)
8.7 8.7 Employees are not provided with prayer areas where applicable (I O)
8.8 8.8 Other (I O D)

WOMEN'S RIGHTS
ID QUESTION TEXT RESPONSE PRIORITY
9.1 9.1 Facility is engaging in pregnancy testing, virginity testing, or questioning pregnancy or virginity status as a condition of employment (I O D)
9.2 9.2 Pregnant workers are terminated for pregnancy (I D)
9.3 9.3 Facility reduces wages, pay, or working conditions for employees who return after pregnancy leave (I D)
9.4 9.4 Workers are forced to use contraception (I D)
9.5 9.5 Pregnant workers are performing dangerous tasks (I O)
9.6 9.6 Body searches are performed by individuals of different gender than workers (I O)
9.7 9.7 Other (I O D)

FREEDOM OF ASSOCIATION AND COLLECTIVE BARGAINING

ID QUESTION TEXT RESPONSE PRIORITY
10.1 10.1 Employers are actively interfering with worker attempts to organize (I D)
10.2 10.2 Workers who have attempted to organize or collectively bargain are terminated (I D)
10.3 10.3 Workers are not allowed to freely elect their representative where applicable (I)
10.4 10.4 Employers threaten to terminate workers who support attempts to organize (I D)
10.5 10.5 Facility has a stated policy of refusing employment to union members (I D)
10.6 10.6 Questions related to union affiliation are included in hiring process (I D)
10.7 10.7 Documented and communicated grievance mechanisms for employees to raise concerns or resolve disputes without fear of reprisal is missing
(I O D)
10.9 10.9 Employer does not recognize the union of the employees' choice (I O D)
10.10 10.10 A labor union / employee organization is missing, where required by law (I D)
10.11 10.11 All past and present collective bargaining agreements (CBA) are not maintained on file (D
10.12 10.12 Employee strike, demonstration, or other type of labor conflict has occurred in the past 2 years (I D)
10.13 10.13 Other (I O D)

ENVIRONMENT
ID QUESTION TEXT RESPONSE PRIORITY
11.1 11.1 Improper air emissions are discharged (O D)
11.2 11.2 Liquid waste is discharged into the environment (I O D)
11.3 11.3 Chemical and/or solid waste is improperly disposed of (I O D)
11.4 11.4 Employees handling waste are not effectively trained on safe handling of waste (I D)
11.5 11.5 Records of any hazardous waste disposal are not retained (D)
11.6 11.6 An authorized waste contractor to remove hazardous waste is not being used (D)
11.7 11.7 Procedures for notifying local community authorities of any accidental discharge or other environmental emergency are not in place as
applicable (D)
11.8 11.8 Facility is missing required environmental permits, permissions and/or registration formalities (including water use, waste water, and chemicals)
11.9 11.9 Facility has been penalized by authorities due to environmental violations in the past two years (I D)
11.10 11.10 Facility does not have a waste water treatment plan as required by law.
11.12 11.12 There is no trained member of management responsible to coordinate environmental management activities as required by law.
11.13 11.13 Other (I O D)

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 11.14 11.14 Air emissions control devices for all point sources, to ensure compliance with air quality standards, are not installed.
11.16 11.16 Facility did not provide records of total energy usage (e.g. KWh/MJ electricity, BTU natural gas, L diesel) reported by month.
11.17 11.17 Documentation for industrial wastewater quality testing was not provided (wastewater quality reports).
11.18 11.18 Facility does not have an Emergency Response Plan (ERP) that includes a contingency plan/protocol and remediation plan in case any
environmental accident, chemical spillage, or improper waste discharge causes an environmental incident on-site.
11.19 11.19 Facility did not provide an up-to-date chemical inventory document.
11.20 11.20 Are there energy meters available for those major consumer units?
11.21 11.21 Do you have water meters for all sources of incoming fresh water (including underground water usage)?
11.22 11.22 Is the usage of water recorded and tracked?
11.23 11.23 Are there water meters available for those major consumption processes?
11.24 11.24 Are you aware of the amount of industrial wastewater discharge based on the flow meter record at each final discharge point?
11.25 11.25 Does the amount of wastewater meet the pollution discharge permit?
11.26 11.26 Is all hazardous / non-hazardous wastes handled by a qualified vendor?
11.27 11.27 Does your factory have or are planning to implement MRSL (Manufacturing Restricted Substances List)?

SUBCONTRACTING
ID QUESTION TEXT RESPONSE PRIORITY
12.1 12.1 Homework is being utilized but was not declared on the booking form (I O D)
12.2 12.2 Unauthorized subcontracting is being utilized (I O D)
12.3 12.3 Employer does not maintain appropriate records of suppliers/subcontractors (and where appropriate sub-suppliers) for at least 12 months (D)
12.4 12.4 A valid, written, and signed agreement between facility and Contractor/sub-contractor is missing (I D)
12.5 12.5 Facility is not monitoring sub-contractors for compliance with their agreement (I D)
12.6 12.6 Contract labor agencies without proper licenses are being used by facility (I D)
12.8 12.8 Production occurring in residential building and/or dormitory but restricted by local law.
12.9 12.9 Other (I O D)

MONITORING
ID QUESTION TEXT RESPONSE PRIORITY
13.1 13.1 Auditors are denied access to the facility to avoid evaluation (I O D)
13.2 13.2 Auditors are denied access to requested documentation and records (D)
13.3 13.3 Auditors are denied access to facility workers for interview purposes (I)
13.4 13.4 Records and/or documentation are not maintained on site at the facility (O D)
13.5 13.5 Documents provided are intentionally falsified (I O D)
13.8 13.8 Employees are intentionally ''coached'' with misleading, inaccurate information for the purpose of providing standard answers to questions asked
by auditor(s) (I)
13.9 13.9 Factory offers bribes to or threatens auditors (O)
13.10 13.10 Postings of required wage, benefit, and health posters are missing as applicable (O D)
13.11 13.11 Other (I O D)
13.12 13.12 The facility does not conduct periodic internal audits (at least annually) of its social compliance system in order to identify improvement
opportunities.

MIGRANT LABOR
ID QUESTION TEXT RESPONSE PRIORITY
14.1 14.1 The facility is missing valid documents from local authority for permission to employ foreign migrant employees as required by law.
14.2 14.2 The facility is missing written agreements with recruitment agents or labor brokers if migrant workers present
14.3 14.3 The facility does not ensure all foreign migrant employees sign a written employment contract in their own language and receive a copy of the
employment contract prior to departing from the sending country.
14.4 14.4 The facility does not pay all host country fees and costs involved in the recruitment process up front, including any levies, visa, work permit,
renewal fees or other costs associated with the use of foreign migrant employee.
14.5 14.5 The facility charges back or accepts reimbursement from any foreign migrant employee to recover any recruitment fees or travel costs it has
paid to hire foreign migrant employees.
14.6 14.6 Upon foreign migrant workers resignation, departure, or termination, the facility does not pay to the employee any wages, benefits, or other
items owed to the employee; at the same time, ensures his or her return to the home country without penalty.
14.7 14.7 The facility does not provide training for foreign migrant employee on rights, job responsibilities, etc., as required by law.
14.8 14.8 The facility does not maintain a current list of foreign migrant workers employed at the facility, including the date of arrival, contract duration
and the anticipated date of return to their home country.
14.9 14.9 The facility does not comply with all applicable laws and regulations governing ‘Foreign Migrant Labour’.
14.10 14.10 Other

Confidential

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