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Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.

Audit Details
Sedex Company ZC:1058186 Sedex Site Reference: ZS:1042222
Reference: (only available on Sedex
(only available on Sedex System)
System)

Business name (Company SERVICIOS AGROPECUARIOS SRL


name):
Site name: SERVICIOS AGROPECUARIOS SRL

Site address: RUTA PROVINCIAL Country: Argentina


(Please include full address) Nº10 S/N - HERNANDO
- CORDOBA
Site contact and job title: Baltazar Prono – Responsible for Hygiene, Safety and Environment
Site phone: +54 353 4960348 Site e–mail: servagrop@servagrop.com.ar

SMETA Audit Pillars: Labour Health & Environment Business Ethics


Standards Safety
Date of Audit: 5, 6 y 7 Diciembre 2018 / 5, 6 & 7 December 2018

 Audit Company Name & Logo:


 Report Owner (payee):
(If paid for by the customer of the site
please remove for Sedex upload)

SERVICIOS AGROPECUARIOS SRL

Argentina

 Audit Conducted By

Commercial Purchaser
Retailer

Brand owner NGO Trade Union

Multi– Combined Audit (select all that apply)


stakeholder

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 2
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 3
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

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

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

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

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


Lead auditor: Fernando Tapia C.
Team auditor: Not applicable
Interviewers: Fernando Tapia C.
Report writer: Fernando Tapia C.
Report reviewer: B. Sathiyanarayanan
Audit Company Report Reference: AR/BUE2012650
Date of declaration: 09th Jan 2019

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

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

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 4
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

Non–Compliance Table

Area of Non–Conformity Findings


Issue (Only check box when there is a non– Record the number (note to auditor, summarise in as few words as
(please click on the issue title to go direct conformity, and only in the box/es where the of issues by line*: possible NCs, Obs and GE)
to the appropriate audit results by clause ) non–conformity can be found)
Note to auditor, please ensure that when issuing
the audit report, hyperlinks are retained. ETI Base Additional Customer NC Obs GE
Local Law
Code Elements Code

0A Universal Rights covering UNGP 5 Nil  No appointed responsible for human


rights.
 Not identified interested parties,
impacts and issues.
 Not measured direct, indirect and
potential impact.
 No action to remediate the impacts.
 Complaint system not communicate
that apply to human right too.

0B Management systems and 2 Nil Nil  Management system implemented is


code implementation not effective.
 No appointed formally a responsible for
maintenance of code of conduct.

1. Freely chosen Employment Nil Nil Nil

2 Freedom of Association Nil Nil Nil

3 Safety and Hygienic Conditions 10 1 Nil  No appointed formally a responsible for


Health & Safety matter.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 5
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

 Sub-standard electric connection.


 Cylinders (LPG and compressed gas)
without subjection system.
 Manometer for N2 cylinders in bad
condition.
 First aid kit with expired supplies.
 Risk signalling deficient and/or missing.
 External workers working over 2 meters
high without fastening system.
 There is no skirting board on production
platform.
 Forklift back flash light in bad condition.
 Working cloths not provided in time.

4 Child Labour Nil Nil Nil

5 Living Wages and Benefits 1 Nil 1  Overtime paid is lower than


attendance records show.

Good Example:
 The organization provides its workers
with monetary incentives for the use of
bicycles to go from home to the
company or to do it walking.

6 Working Hours 1 Nil Nil  Attendance record not provided to


workers for their review.

7 Discrimination Nil Nil Nil

8 Regular Employment Nil Nil Nil

8A Sub–Contracting and Nil Nil Nil


Homeworking

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 6
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

9 Harsh or Inhumane Treatment 1 Nil Nil  Sanction process that has the
company is not being carries as is
established.

10A Entitlement to Work Nil Nil Nil

10B2 Environment 2-Pillar Nil Nil Nil

10B4 Environment 4–Pillar 2 1 Nil  Company environmental policy not


communicated to all levels inside the
organization.
 Hazardous residues not handled
adequately.

Observation
 No appointed responsible for
environment matter.

10C Business Ethics 3 Nil Nil  System to communicate bad practices


has not an easy access.
 No appointed formally a responsible for
Business Ethics matter.
 Organization does not have a system to
ensure the key personnel to know how
to act in case of any problem.

General observations and summary of the site:

The company “SERVICIOS AGROPECUATIOS SRL” has implemented a system to handle the matter related with social compliance and the relation with the
employees and stakeholders. The company has document about how proceeds, which are communicated to all employees (Internal Rules, Emergency
plan, Risk Matrix among others). Besides, in a regular way the company provide training to their employees in different items. During the audit, were
evidenced high level of deviations showing although the company has implemented a management system, it was not effective and then some deviations
are evidenced principally in Health & Safety matter, and in lower grade in Wages & Benefits, Working hours, Harsh or Inhumane Treatment, Environment and
Business Ethics. Besides, were evidenced some observations associated with the Human Rights matter and environment. However, can be observed that the
company has the commitment to improve every day and work to solve the deviations, matter that is instilled in its own workers.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 7
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

*Please note the table above records the total number of Non-compliances (NC), Observations (Obs) and Good Examples (GE). This gives the reviewer an
indication of problem areas but does not detail severities of each issue – Reviewers need to check audit results by clause.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 8
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

Site Details

 Site Details

A: Company Name: SERVICIOS AGROPECUARIOS SRL

B: Site name: SERVICIOS AGROPECUARIOS SRL

C: GPS location: GPS Address: Not available Latitude: -32.4381245


(if available) Longitude: -63.7205764

D: Applicable business and other RNE 04003551 – Enabling Registration Senasa Nº 11263
legally required licence numbers and
documents, for example, business
license number, liability insurance, any
other required government inspections

E: Products/Activities at site, for Peanut production (selected, blanched, roasted and Small
example, garment manufacture, peanut seed "grana") and derivatives (flour, paste and shell
electricals, toys, grower, cutting, pellets).
sewing, packing etc.

F: Site description: The company “SERVICIOS AGROPECUARIOS SRL” is located at


(Include size, location, and age of site. Ruta Provincial N°10 S/N Hernando, Córdoba, Argentina.
Also, include structure and number of Starting the activities since 1 Oct 1997.
buildings)
In view of the facilities, the company is in a total area of 110000
square meters with 18100 square meters built. The company
has two principal construction (processing plant and raw
material warehouse). Besides there are other minor
constructions where are located offices, dining room,
bathroom, maintenance room.

Production Description Remark, if any


Building no 1
Floor 1 Processing plant. No
Is this a shared
No No
building?

Production Description Remark, if any


Building no 2
Raw material
Floor 1 No
warehouse.
Is this a shared
No No
building?

For below, please add any extra rows if appropriate.

Visible structural integrity issues (large cracks) observed?

Yes

No

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 9
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

Please give details:

Does the site have a structural engineer evaluation?

Yes

No
Please give details:

G: Site function: Agent


Factory Processing/Manufacturer
Finished Product Supplier
Grower
Homeworker
Labour Provider
Pack House
Primary Producer
Service Provider
Sub–Contractor

H: Month(s) of peak season: May to August


(if applicable)

I: Process overview: The facility provides: Peanut production (selected, blanched,


(Include products being produced, main roasted and Small peanut seed "grana") and derivatives (flour,
operations, number of production lines, paste and shell pellets).
main equipment used)
The main process is: Reception and collection of raw material,
peeling and selection of raw runner peanuts, blanched and
roasted peanuts, fried, grana and pasta.

The facility has the following principal equipment to cover the


activity: 6 PRODUCTION LINES:
1) cleaning, peeling, selection and packaging runner
peanuts, 2) blanching of runner peanuts, where the
peanut goes through an oven drying process to later
remove the cuticle or skin from the grain,
3) toasting the grain at controlled temperature in ovens,
4) grana, 'grain distribution in particles of different sizes,
5) Paste, grinding of peanut grain, until obtaining the
paste and
6) Fried, cooking the grain in fryer.

Main equipment used (equipment and quantity): 2


Precleaning, 3 dehulling, 2 gravity tables, 2 sizes, 6 electronic
selectors, 3 ovens, 9 blanchers, and fryer, 1 pasta line, 1 grana
machine, 10 hoists.

J: What form of worker representation / Union (“STIA” and “UATRE”)


union is there on site? Worker Committee
Other (specify)
None

K: Is there any night production work at Yes


the site? No

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 10
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

L: Are there any on site provided worker Yes


accommodation buildings e.g. No
dormitories If yes approx. % of workers in on site accommodation

M: Are there any off site provided Yes


worker accommodation buildings No
If Yes approx. % of workers

N: Were all site provided Yes


accommodation buildings included in No
this audit If No, please give details

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 11
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

 Audit Parameters

A: Time in and time out Day 1 Time in: 09:00 Day 2 Time in: 09:00 Day 3 Time in: 09:00
Day 1 Time out: Day 2 Time out: Day 3 Time out:
18:00 18:00 13:00

B: Number of auditor days used: 2.5 MD (1 auditor)

C: Audit type: Full Initial


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

D: Was the audit announced? Announced


Semi – announced: Window detail: weeks
Unannounced

E: Was the Sedex SAQ available for Yes


review? No
If No, why not

F: Any conflicting information Yes


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

G: Who signed and agreed CAPR Sebastián Barale – Manager of Administration, Finance, HR and
(Name and job title) Systems.

H: Is further information available Yes


(If yes please contact audit company for No
details)

I: Previous audit date: 1 February 2012

J: Previous audit type: Full Initial

K: Were any previous audits reviewed Yes No


for this audit
N/A

Audit attendance Management Worker Representatives

Senior Worker Committee Union


management representatives representatives

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

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

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 12
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

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

D: If Worker Representatives were not There is no worker representative


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

E: If Union Representatives were not There is no Union representative


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

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 13
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

Worker Analysis


The term "migrant worker" refers to a person who is engaged or has been engaged in a remunerated activity
in a country of which they are not a national and where they do not intend to remain permanently or has
purposely migrated on a temporary basis to another in-country region to seek and engage in a remunerated
activity

 Worker Analysis

Local Migrant* 
Total
Home
Permanent Temporary Agency Permanent Temporary Agency
workers

Worker numbers –
156 43 0 0 0 0 0 199
Male

Worker numbers –
22 4 0 0 0 0 0 26
female

Total 178 47 0 0 0 0 0 225

Number of Workers
17 2 0 0 0 0 0 19
interviewed – male

Number of Workers
interviewed – 7 0 0 0 0 0 0 7
female

Total – interviewed
24 2 0 0 0 0 0 26
sample size

A: Nationality of Management Argentina

B: Nationality of workers Countries:


Please add more rows as applicable Country 1: Argentina
Country 2: ________
Country 3: ________

C: For the majority nationality of workers: Nationality 1 approx % total workforce_100____


Nationality 2 approx % total workforce________
Nationality 3 approx % total workforce________

D: Worker remuneration (management _______% workers on piece rate


information) __40___% hourly paid workers
__60___% salaried workers

Payment cycle:
_______% daily paid
_______% weekly paid
_100___% monthly paid

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 14
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_______% other
If other, please give details

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 15
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

Worker Interview Summary


Worker Interview Summary

A: Were workers aware of the audit? Yes


No

B: Were workers aware of the code? Yes


No

C: Number of group interviews: 4 groups of 5 members


(Please specify number and size of groups. Please see SMETA
Best Practice Guidance and Measurement Criteria. If the
auditor was not able to follow the BPG, please state within the
declaration)

D: Number of individual interviews Male: 3 Female: 3


(Please see SMETA Best Practice Guidance and Measurement
Criteria)

E: All groups of workers are included in the scope of this Yes


audit such as; Direct employees, Casual and agency No
workers, Workers employed by service providers such as
security and catering staff as well as workers supplied by If no, please give details
other contractors.
Note to auditor: please record details of migrant /agency/contractor
workers in section 8 – Regular Employment, under Responsible
Recruitment

F: Interviews were done in private and the confidentiality Yes


of the interview process was communicated to the No
workers?

G: In general, what was the attitude of the workers Favourable


towards their workplace? Non–favourable
Indifferent

H: What was the most common worker complaint? No complaints were issued.

I: What did the workers like the most about working at this Payment on time, provision of working clothes,
site? tolerance, calm work, open doors, fellowship,
humanity towards the worker, monetary
incentive to go to the company by bike or
walking, free vaccination, the worker is
wanted, solidarity with the worker, birthday
celebration, the worker is thought of, the
company has grown.

J: Any additional comment(s) regarding interviews: During the interview was commented the
necessity to:
 Review salary scale
 Control the use of comments made by
the workers by the bosses so as not to
influence the evaluations
 Cleaning the dining room by workers
who use it

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 16
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 Improve the communication of the


middle managers and between the
areas
that the trainings are also made to the
personnel of the first level and not only to
supervisors

K: Attitude of workers to hours worked: In general, the working hours are inside the
maximum required by the local regulation.

L. Is there any worker survey information available?

Yes
No
If yes, please give details:

M: Attitude of workers:
(Include their attitude to management, workplace, and the interview process. Both positive and negative information should be
included) Note: Do not document any information that could put workers at risk

Interviews with 26 workers randomly selected by auditors were conducted in an independent room.
The interviewees showed a cooperative attitude and effective evidence was collected during the workers
interview. In general, the appreciation is good, however some suggestions were issued.

N: Attitude of worker’s committee/union reps:


(Include their attitude to management, workplace, and the interview process. Both positive and negative information
should be included) Note: Do not document any information that could put workers at risk

Although most workers are associated to a Union, there is not a committee of workers, union delegates or
representatives of workers, because the they did not want to choose it.

O: Attitude of managers:
(Include attitude to audit, and audit process. Both positive and negative information should be included)

The facility responsible attitude was good respect the audit and process, giving all their support to develop
an adequate audit and access to all necessary documents and visited areas. Besides, he was receptive
with the findings founded which were accepted without problem, indicating the commitment to attend
them and make the corrective actions necessary in an adequate way and time.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 17
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

Audit Results by Clause


0A: Universal Rights covering UNGP
0A: Universal Rights covering UNGP
(Click here to return to NC–table)

0.A. Guidance for Observations


0.A.1 Businesses should have a policy, endorsed at the highest level, covering human rights impacts and
issues, and ensure it is communicated to all appropriate parties, including its own suppliers.
0.A.2 Businesses should have a designated person responsible for implementing standards concerning
Human rights
0.A.3 Businesses shall identify their stakeholders and salient issues.
0.A.4 Businesses shall measure their direct, indirect, and potential impacts on stakeholders (rights holders)
human rights.
0.A.5 Where businesses have an adverse impact on human rights within any of their stakeholders, they
shall address these issues and enable effective remediation.
0.A.6 Businesses shall have a transparent system in place for confidentially reporting, and dealing with
human rights impacts without fear of reprisals towards the reporter.

Note for auditors and readers. This is not a full Human Rights Assessment, but instead a check on
the business’s implementation of processes to meet their Universal rights covering UNGP
responsibilities.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
During the audit, document review, facility responsible, managers and employees interview was
evidenced that the requirement is not fully implemented yet.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
Were reviewed different documents that have the company:
 Corporate Code of Conduct
 Internal Rules Document
 Code of ethics and coexistence
 Besides were interviewed the Administrative personnel and the selected employees.

Any other comments: None

A: Policy statement that expresses commitment to Yes


respect human rights? No
Please give details (mainly applicable for the parent
company): The corporate code of conduct
expresses the commitment to respect the human

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 18
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rights. Document that is available in the web page


of the company.

B: Does the business have a designated person Yes


responsible for implementing standards No
concerning Human Rights?
Please give details:
Name:
Job title:

C: Does the businesses have a transparent system Yes


in place for confidentially reporting, and dealing No
with human rights impacts without fear of reprisals Please give details: Company has a system, but till
towards the reporter? audit was not communicated to the employees that
it is applicable for human rights too.

D: Does grievance mechanism meet with UNGP Yes


requirement of e.g. (Legitimate, Accessible, No
Predictable, Equitable, Transparent, Rights-
compatible, a source of continuous learning and If no, please give details: Company has a system,
based on stakeholder engagement)? however it is no communicate to the employees that
apply to human rights too, and it is not based in
stakeholder’s engagement.

E: Does the business demonstrate effective data Yes


privacy procedures for workers’ information, No
which is implemented?
Please give details: The files are handled by the
Human resources department, which handle the
worker´s information in a protected way, with limited
access. Besides, it is included in the Ethic and
coexistence code.

Findings # 1

Finding: Observation Company NC Objective evidence


Description of observation: observed:

The company has not appointed a person responsible for implementing the
regulations related to Human Rights. Observed during facility
responsible, managers,
Local law or ETI/Additional elements / customer specific requirement: employees’ interview
Additional elements and document review.
0.A.2 Businesses should have a designated person responsible for implementing
standards concerning Human rights

Comments:
The facility responsible was in agreeing with the finding and will attend it
promptly.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 19
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Findings # 2

Finding: Observation Company NC Objective evidence


Description of observation: observed:

The organization has not identified the interested parties, the impacts towards
them, and the issues evidenced by the evaluation. Observed during facility
responsible, managers,
Local law or ETI/Additional elements / customer specific requirement: employees’ interview
Additional elements and document review.
0.A.3 Businesses shall identify their stakeholders and salient issues.

Comments:
The facility responsible was in agreeing with the finding and will attend it
promptly.

Findings # 3

Finding: Observation Company NC Objective evidence


Description of observation: observed:

The organization has not measured the direct, indirect and potential impact to
the stakeholders in relation to human rights. Observed during facility
responsible, managers,
Local law or ETI/Additional elements / customer specific requirement: employees’ interview
Additional elements and document review.
0.A.4 Businesses shall measure their direct, indirect, and potential impacts on
stakeholders (rights holders) human rights.

Comments:
The facility responsible was in agreeing with the finding and will attend it
promptly.

Findings # 4

Finding: Observation Company NC Objective evidence


Description of observation: observed:

Since the impact in relation to human rights has not been measured, the
organization does not know about them and therefore cannot establish any Observed during facility
action on them to generate an effective remediation. responsible, managers,
employees’ interview
Local law or ETI/Additional elements / customer specific requirement: and document review.
Additional elements
0.A.5 Where businesses have an adverse impact on human rights within any of
their stakeholders, they shall address these issues and enable effective
remediation.

Comments:
The facility responsible was in agreeing with the finding and will attend it
promptly.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 20
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Findings # 5

Finding: Observation Company NC Objective evidence


Description of observation: observed:

The organization has a system for filing complaints, however, it is not explicit
that it also applies to human rights. Observed during facility
responsible, managers,
Local law or ETI/Additional elements / customer specific requirement: employees’ interview
Additional elements and document review.
0.A.6 Businesses shall have a transparent system in place for confidentially
reporting, and dealing with human rights impacts without fear of reprisals
towards the reporter.

Comments:
The facility responsible was in agreeing with the finding and will attend it
promptly.

Good examples observed:

Description of Good Example (GE): None Objective Evidence


Observed:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 21
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Measuring Workplace Impact


Measuring Workplace Impact Table
Workplace Impact

A: Annual worker turnover: Last year: This year


Number of workers leaving in last 12 months as a % _4.29__ % _4.28__ %
of average total number of workers on site over the
year (annual worker turnover)

B: Current % quarterly (90 days) turnover: Between 12.7% and 16.4%


Number of workers leaving from the first of the 90
day period through to the last day of the 90 day
period / [(number of employees on the 1st day of
90 day period + number of employees on the last
day of the 90 day period) / 2]

C: Annual % absenteeism: Last year: This year


Number of days lost through job absence in the _3.0__ % _2.8__ %
year /
[(number of employees on 1st day of the year +
number employees on the last day of the year) / 2]
* number available workdays in the year

D: Quarterly (90 days) % absenteeism: 0.75% 0.70%


Number of days lost through job absence in the
period /
[(Number of employees on 1st of the period +
Number of employees on the last day of the
period) / 2]
* Number of available workdays in the month

E: Are accidents recorded? Yes


No
Please describe: The company has a procedure that gives the
step to investigate and recorded the accidents and incidents.
Besides, there is a legal requirement to report accidents. The
company made an annual record.

F: Annual Number of work related Last year: 2017 This year: 2018
accidents and injuries per 100 workers: Number: 7.468 Number: 1.521
[(Number of work related accidents and injuries *
100) / Number of total workers]

G: Quarterly (90 days) number of work 1.867 0.380


related accidents and injuries per 100
workers:
[(Number of work related accidents and injuries *
100) / Number of total workers]

H: Lost day work cases per 100 workers: Last year: 334.025 This year: 52.091
[(Number of lost days due to work accidents and
work related injuries * 100) / Number of total
workers]

I: % of workers that work on average 6 months 12 months


more than 48 standard hours / week in __19.60___% workers __16.21___% workers
the last 6 / 12 months:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 22
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J: % of workers that work on average 6 months 12 months


more than 60 total hours / week in the _4.12____% workers __5.22____% workers
last 6 / 12 months:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 23
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0: Management systems and Code Implementation


0B: Management system and Code Implementation
(click here to return to NC Table)

0.B.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code.
0.B.2 Suppliers are expected to be operating legally in premises with the correct business licenses and
permissions and to have systems to ensure that all relevant land rights have been complied with
0.B.3 Suppliers shall appoint a senior member of management who shall be responsible for compliance
with the Code.
0.B.4 Suppliers are expected to communicate this Code to all employees.
0.B.5 Suppliers should communicate this code to their own suppliers and, where reasonably practicable,
extend the principles of this Ethical Code through their supply chain.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers,
to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what
relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence
checked should detail any documentary or verbal evidence shown to support the systems.

Current systems:
The organization has no implemented adequately the code of conduct. There is a site responsible who
has the responsibility to personal handle/manage and besides the management system control, bit not
formally appointed. During the audit was evidenced some weakness on the implementation of the
management system, and besides that there is no effective.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
During the audit was reviewed the documents “Internal Rules” and the “Code of ethics and coexistence”
that has the company, besides were interviewed the company responsible, administrative and the
selected employees.

Any other comments:


None

Management Systems:

A: In the last 12 months, has the site been subject to Yes


any fines/prosecutions for non–compliance to any No
regulations? Please give details:

B: Do policies and/or procedures exist that reduce the Yes


risk of forced labour, child labour, discrimination, No
harassment & abuse? Please give details: Code of ethics and
coexistence

C: If Yes, is there evidence (an indication) of effective The code is communicated in the induction
implementation? Please give details. manual to the collaborators before starting the
contractual relation; besides a copy of the
document is provided too. During audit was
evidenced there is not forced labour, child
labour, discrimination, harassment & abuse.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 24
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D: Have managers and workers received training in Yes


the standards for forced labour, child labour, No
discrimination, harassment & abuse? Please give details: During document review
were evidenced records about training in the
pertinent standards.

E: If Yes, is there evidence (an indication) that training Yes


has been effective e.g. training records etc.? Please No
give details Please give details: During facility´s responsible
and worker interview was possible to evidence
that the training was effective. The employees
know well the requirements and the rights and
obligations to avoid problems in this matter.
Besides, the employees have the open door to
the owner to present question and/or complaint.

F; Does the site have any internationally recognised Yes


system certifications e.g. ISO 9000, 14000, OHSAS No
18000, SA8000 (or other social audits). Please give details: BRC version 7, valid till 29 July
Please detail (Number and date). 2019.

G: Is there a Human Resources manager/department? Yes


If Yes, please detail. No
Please give details: The department is formed by
a Manager of Human resources, Administration,
Finance and System, and a person in charge of
the area.

H: Is there a senior person /manager responsible for Yes


implementation of the code No
Please give details: The responsible is the
Manager of Human resources, Administration,
Finance and System. However, the responsibility
is not formally established.

I: Is there a policy to ensure all worker information is Yes


confidential No
Please give details: Included in the Code of
ethics and coexistence document. Document
establishes that all information related with the
workers shall handle in a confidential way.
During the audit was evidenced that this is
handled by the human resources department in
a way that only the authorized personnel has
access to them.

J: Is there an effective procedure to ensure Yes


confidential information is kept confidential No
Please give details: During the audit, was
evidenced that the confidential information is
protected and only approved personnel has
access to them.

K: Are risk assessments conducted to evaluate policy Yes


and procedure effectiveness? No

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 25
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Please give details: Internal audits are made.


However, the audits are associated with the
certification that has the company.

L: Does the facility have a process to address issues Yes


found when conducting risk assessments, including No
implementation of controls to reduce identified risks? Please give details: Company has a Corrective
action procedure. However, the procedure is
associated with the certification that has the
company.

M: Does the facility have a policy/code which require Yes


labour standards of its own suppliers? No
Please give details: Included in the Code of
ethics and coexistence document, which
established that only businesses are maintained
with suppliers that develop their activity in
compliance with the applicable regulations,
and that are respectful of human rights, as well
as those that respect the code of conduct of
the organization and / or have a code of
conduct appropriate with the legislation on
criminal responsibility in force.

Land rights

N: Does the site have all required land rights licenses Yes
and permissions (see SMETA Measurement Criteria)? No
Please give details: Land deeds where the plant
is located. Besides, the company has the
corresponding municipal qualification which
requires that the company demonstrate
previously they have the land right licenses and
permissions.

O: Does the site have systems in place to conduct Yes


legal due diligence to recognize and apply national No
laws and practices relating to land title? Please give details: The Company handle a
legal requirement through their legal
representative.

P: Does the site have a written policy and procedures Yes


specific to land rights. No
If yes, does it include any due diligence the company If yes, how does the company obtain FPIC:
will undertake to obtain free, prior and informed
consent, (FPIC) even if national/local law does not
require it

Q: Is there evidence that facility / site compensated Yes


the owner/lessor for the land prior to the facility being No
built or expanded. Please give details: The company is owner of the
land since 1986.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 26
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Yes
R. Does the Facility demonstrate that alternatives to a No
specific land acquisition were considered to avoid or Please give details:
minimize adverse impacts?

S: Is There any evidence of illegal appropriation of land Yes


for facility building or expansion of footprint. No
Please give details:

Non–compliance:

Description of non–compliance: Objective evidence


NC against ETI/Additional Elements NC against Local Law observed:
NC against customer code: (where relevant please
add photo numbers)
There is no evidence that the management system implemented to comply
with the TSI / CLIENT conduct code is effective. Observed during:
 document review
Local law and/or ETI requirement:  facility responsible
ETI interview
0.B.1 Suppliers are expected to implement and maintain systems for delivering  employees interview
compliance to this Code.  During audit were
evidenced
Recommended corrective action: deviations against
Be sure to maintain a management system that is effective to comply with the the requirements
ETI / CUSTOMER code of conduct.

Non–compliance: 2

Description of non–compliance: Objective evidence


NC against ETI/Additional Elements NC against Local Law observed:
NC against customer code: (where relevant please
add photo numbers)
The organization has not formally defined a representative of senior
management to ensure the maintenance and observance of the principles of Observed during:
the ETI / CUSTOMER Code of Conduct.  document review
 facility responsible
Local law and/or ETI requirement: interview
ETI
0.B.3 Suppliers shall appoint a senior member of management who shall be
responsible for compliance with the Code.

Recommended corrective action:


Establish formally a responsible person to ensure the maintenance and
observance of the principles of the ETI / CUSTOMER Code of Conduct.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 27
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Observation:

Description of observation: None Objective evidence


observed:
Local law or ETI requirement:

Comments:

Good Examples observed:

Description of Good Example (GE): None Objective evidence


observed:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 28
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1: Employment is Freely Chosen


1: Freely Chosen Employment
(Click here to return to NC–table)

ETI
1.1 There is no forced, bonded or involuntary prison labour.
1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free
to leave their employer after reasonable notice.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
All the employees can present their voluntary renounce to their job without posterior effect, matter
evidenced through employee´s interview. Additionally, the company has Human Resources responsible
which review this matter. At the time of audit, no evidence of bonded or involuntary prison labour was
found in the facility. Workers confirmed that no original documents were requested to be deposited with
the facility by the workers at the time of the recruitment. Besides the workers commented they have free
movement and no restrictions to go to the bathroom and/or dining room to drink water if they need it.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
Were observed documents related with the working relation between the facility and the employees that
do not show any items related with forced employment.
 Employees personnel file
 Company internal rules
 Management and employees interview
 Code of ethics and coexistence

Any other comments: None

A: Is there any evidence of Yes


retention of original documents, No
e.g. passports/ID’s If yes, please give details and category of workers affected:

B: Is there any evidence of a loan Yes


scheme in operation No
If yes, please give details and category of workers affected: The
loan scheme is available to all employees according with their
necessity, and the discount is made monthly.

C: Is there any evidence of Yes


retention of wages /deposits No
If yes, please give details and category of workers affected:

D: Are there any restrictions on Yes


workers’ freedom to terminate No
employment? Please describe finding:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 29
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E: If any part of the business is UK Yes


based or registered there & has a No
turnover over £36m, is there is a
published ‘modern day slavery Please describe finding:
statement.

Not applicable

G: Is there evidence of any Yes


restrictions on workers’ freedoms No
to leave the site at the end of the Please describe finding:
work day?

H: Does the site understand the Yes


risks of forced / trafficked / No
bonded labour in its supply chain
If yes, please give details and category of workers affected:

Not applicable

I: Is the site taking any steps taking Yes


to reduce the risk of forced / No
trafficked labour?
Please describe finding: The organization works under the guidelines
of national legislation, the employment contract law No. 20,744 and
code of ethics and coexistence of the company.

Non–compliance:

1. Description of non–compliance: NONE Objective evidence


NC against ETI NC against Local Law: NC against customer observed:
code: (where relevant please
add photo numbers)

Local law and/or ETI requirement

Recommended corrective action:

Observation:

Description of observation: None Objective evidence


observed:
Local law or ETI requirement:

Comments:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 30
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Good Examples observed:

Description of Good Example (GE): None Objective evidence


observed:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 31
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2: Freedom of Association and Right to Collective Bargaining are Respected


2: Freedom of Association and Right to Collective Bargaining are Respected
(Click here to return to NC–table)
(Click here to return to Key Information)

ETI
2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to
bargain collectively.
2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational
activities.
2.3 Workers’ representatives are not discriminated against and have access to carry out their
representative functions in the workplace.
2.4 Where the right to freedom of association and collective bargaining is restricted under law, the
employer facilitates, and does not hinder, the development of parallel means for independent and free
association and bargaining.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
There is an Argentinean Law # 23551 that gives the requirement related with the union. Besides for the
employees in the facility are associated with two unions STIA and UATRE that regulate this matter.
Actually, there is no union delegate.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
 Interview with workers
 Interview with managers
 Company Code of ethics and coexistence

Any other comments:


There is no Union delegate in the facility because the employees are not interested in appointing one.

A: What form of worker Union (name)


representation/union is there on Worker Committee
site? Other (specify)
None

B: Is it a legal requirement to have a Yes


union? No

C: Is it a legal requirement to have Yes


a worker’s committee? No

D: Is there any other form of Yes


effective worker/management No
communication channel? (Other

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 32
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than union/worker committee e.g. H&S, Describe: The worker has access to the Human Resources
sexual harassment) responsible and besides to the company owner (matter confirmed
during the employee’s interview). Additionally, the company has a
suggestion/complaint box and web page.

Is there evidence of free elections?


Yes
No

E: Does the supplier provide Yes


adequate facilities to allow the No
Union or committee to conduct Details: Not applicable – there is no union delegate.
related business?

F: Name of union and union STIA (Trade Union of Is there evidence of free elections?
representative, if applicable: Workers of the Food Yes No N/A
Industry) and UATRE
(Argentine Union of
Rural Workers and
Stevedores).

There is not Union


representative.

G: If there is no union, is there a Not applicable. There Is there evidence of free elections?
parallel means of consultation with are National Unions Yes No N/A
workers e.g. worker committees? which have the
responsibility to held
meeting with the
companies and with
their affiliates.

H: Are all workers aware of who Yes No Not applicable. There is no union
their representatives are? delegate.

I: Were worker representatives freely Yes No Date of last election:


elected? Not applicable. There is no union
delegate.

J: Do workers know what topics can Yes No Not applicable. There is no union
be raised with their representatives? delegate.

K: Were worker Yes No


representatives/union If Yes, please state how many:
representatives interviewed? Not applicable. There is no union delegate.

L: Please describe any evidence Not applicable. There is no union delegate.


that union/worker’s committee is
effective?
Specify date of last meeting; topics
covered; how minutes were
communicated etc.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 33
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M: Are any workers covered by Yes No


Collective Bargaining Agreement
(CBA)?

If Yes, what percentage by trade _100_% workers covered by ____% workers covered by
Union/worker representation Union CBA worker rep CBA

If Yes, does the Collective Yes


Bargaining Agreement (CBA) No
include rates of pay?

Non–compliance:

1. Description of non–compliance: NONE Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please add
photo numbers)

Local law and/or ETI requirement:

Recommended corrective action:

 Observation:

Description of observation: NONE Objective evidence


observed:
Local law or ETI requirement:

Comments:

 Good Examples observed:

Description of Good Example (GE): NONE Objective evidence


observed:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 34
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3: Working Conditions are Safe and Hygienic


3: Working Conditions are Safe and Hygienic
(Click here to return to NC–table)
(Click here to return to Key Information)

ETI
3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing
knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent
accidents and injury to health arising out of, associated with, or occurring in the course of work, by
minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
3.2 Workers shall receive regular and recorded Health & Safety training, and such training shall be
repeated for new or reassigned workers.
3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food
storage shall be provided.
3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for Health & Safety to a senior
management representative.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
During the plant visit was evidenced that the facility is in some grade under the required compliance with
the requirements related with the Safe & Hygienic conditions, matter that is supported through the
interviewed employee answer and comments, documental review and facility visit. However, were
observed high number of deviations in relation with Health and Safety.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
 PPE provision record
 Working clothes provision record
 Policy Hygiene, safety and occupational risk prevention policy
 Evaluation of workers exposed to risk agent
 Risk identification and risk evaluation
 Visit record associated with Safety and hygiene matters
 Business plan with high accident rates
 Program to reduce accident rate
 Training matrix for 2018 year
 Forklift driving training record
 Evacuation drawing and evacuation routes training record
 First aid and CPR training record
 Risk in storage cellar and PPE use training record
 Accident investigation records
 Fire extinguisher matrix
 Report about fire net system status
 Hydraulic test certificate fire hoses
 Statistics of accident rate
 Matrix with accidents record
 Report about chemical contaminants in the working area

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 35
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 Report about light intensity in working area


 Report about noise in the working area
 Report about thermic stress in the working area
 Reporting about grounding resistance
 Evacuation drawing
 Emergency lights
 Risk advertising
 PPE use labelling
 Eye washing systems
 MSDS available
 Fire evacuation drill

Any other comments:


None

Yes
A: Does the facility have general and
occupational Health & Safety policies No
and procedures that are fit for purpose
and are these communicated to Please give details: Organization has a Policy on Hygiene,
workers? Safety and Prevention of Occupational Hazards and manual
management of MASH (Environment Safety and Hygiene)
published and known to all workers.

Yes
B: Are the policies included in workers’
manuals? No

Please give details: However, the policy is published in different


areas of the company.

Yes
C: Are there any structural additions
without required permits/inspections No
(e.g. floors added)?
Please give details:
Yes
D: Are visitors to the site informed on
H&S and provided with personal No
protective equipment
Please give details:

Yes
E: Is a medical room or medical facility
provided for workers? No

If yes, do the room(s) meet legal Please give details: The company has a medical room inside
requirements and is the size/number of the facility, according with the local regulation.
rooms suitable for the number of
workers.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 36
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Yes
F: Is there a doctor or nurse on site or
there is easy access to first aider/ No
trained medical aid?
Please give details: There are weekly doctor visits, as well as
the emergency brigade of the company, as well as first aid kits
distributed in the different sectors of the company.

Yes
G: Where the facility provides worker
transport - is it fit for purpose, safe, No
maintained and operated by
competent persons e.g. buses and Please give details:
other vehicles?

Yes
H: Is secure personal storage space
provided for workers in their living No
space and is it fit for purpose?
Please give details: Not applicable

Yes
I: Are H&S Risk assessments conducted
(including evaluating the arrangements No
for workers doing overtime e.g. driving
after a long shift) and are there controls Please give details: The company has a matrix IH 08 Hazard
to reduce identified risk? Identification, Risk Assessment and Control Measures. However,
the risk associated with overtime is not evaluated.

Yes
J: Is the site meeting its legal obligations
on environmental requirements No
including required permits for use and
disposal of natural resources? Please give details: Although the company has an
environmental policy, which is known by the workers and it is
made internal inspection, was evidenced that the
environmental management is not effective, due was
observed a non-adequate handling of hazardous residues.
Yes
K: Is the site meeting its customer
requirements on environmental No
standards, including the use of banned
chemicals? Please give details: The company analyses the product on
remains of pesticides or heavy metals annually to the different
products processed.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 37
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Non–compliance: 3

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
A representative of senior management has not been formally defined to take
charge of Health & Safety. Observed during
 document review
Local law and/or ETI requirement  facility responsible
ETI interview
3.5 The company observing the code shall assign responsibility for Health &
Safety to a senior management representative.

Recommended corrective action:


Establish formally a responsible person to ensure the maintenance and
observance of the principles of the ETI / CUSTOMER Code of Conduct.

Non–compliance: 4

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
Sub-standard electrical connections are observed.
Observed during facility
Local law and/or ETI requirement visits (Plug in poor
ETI condition, unprotected
3.1 A safe and hygienic working environment shall be provided, bearing in electric cables, open
mind the prevailing knowledge of the industry and of any specific hazards. electrical panels).
Adequate steps shall be taken to prevent accidents and injury to health arising
out of, associated with, or occurring in the course of work, by minimising, so far
as is reasonably practicable, the causes of hazards inherent in the working
environment.

Local law
LAW 19587. Article 9 - Without damage of what determine the regulations
especially, are also the employer's obligations;
d) to maintain in good conservation state, use and operation the electric
facilities and services of drinkable waters;

Recommended corrective action:


Review the different areas and correct the deviations detected.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 38
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Non–compliance: 5

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
Cylinders of liquefied gas and pressurized gas without clamping system are
observed. Observed during facility
visits.
Local law and/or ETI requirement
ETI
3.1 A safe and hygienic working environment shall be provided, bearing in
mind the prevailing knowledge of the industry and of any specific hazards.
Adequate steps shall be taken to prevent accidents and injury to health arising
out of, associated with, or occurring in the course of work, by minimising, so far
as is reasonably practicable, the causes of hazards inherent in the working
environment.

Local law
Decree 351/1979. Article 142 The storage of recipients, tubes, cylinders, drums
and others that contain pressurized liquefied gases, inside the local, it will be
adjusted to the following requirements:
2. Will be placed in convenient form, to assure them against fallen and
crashes.

Recommended corrective action:


Check the different areas and make sure that the cylinders are always
subjected.

Non–compliance: 6

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
A manometer in poor condition is observed for nitrogen cylinders in the Chiller
sector. Observed during facility
visits
Local law and/or ETI requirement
ETI
3.1 A safe and hygienic working environment shall be provided, bearing in
mind the prevailing knowledge of the industry and of any specific hazards.
Adequate steps shall be taken to prevent accidents and injury to health arising
out of, associated with, or occurring in the course of work, by minimising, so far
as is reasonably practicable, the causes of hazards inherent in the working
environment.

Local law
LAW 19.587. Art. 9 - Without prejudice to what the regulations especially
determine, they are also obligations of the employer;
b) keep the machinery, installations and work tools in a good state of
conservation, use and operation;

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 39
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Recommended corrective action:


Change manometer for one in good condition.

Non–compliance: 7

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
There is a first aid kit that has some expired supplies.
Observed during facility
Local law and/or ETI requirement visits (input store room
ETI and maintenance
3.1 A safe and hygienic working environment shall be provided, bearing in room)
mind the prevailing knowledge of the industry and of any specific hazards.
Adequate steps shall be taken to prevent accidents and injury to health arising
out of, associated with, or occurring in the course of work, by minimising, so far
as is reasonably practicable, the causes of hazards inherent in the working
environment.

Local law
LAW 19.587 Art. 9- Without prejudice to what is determined by regulations, the
following are also obligations of the employer:
i) Have adequate means for the immediate provision of first aid;

Recommended corrective action:


Review first aid kit and replace expired supplies.

Non–compliance: 8

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
The signage of risk is deficient and / or missing in some points of the plant. (Ex.
Fuel, inflammable, electrical risk, storage at height). Observed during facility
visits (different areas).
Local law and/or ETI requirement
ETI
3.1 A safe and hygienic working environment shall be provided, bearing in
mind the prevailing knowledge of the industry and of any specific hazards.
Adequate steps shall be taken to prevent accidents and injury to health arising
out of, associated with, or occurring in the course of work, by minimising, so far
as is reasonably practicable, the causes of hazards inherent in the working
environment.

Local law
LAW 19.587 Art. 9- Without prejudice to what is determined by regulations, the
following are also obligations of the employer:
j) Place and maintain in visible places notices or posters that indicate
measures of hygiene and safety or warn of dangerousness in the machinery
and facilities;

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 40
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Recommended corrective action:


Review the different areas and improve and / or place the missing signage.

Non–compliance: 9

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
It is observed workers (external personnel) doing activity on 2 meters height
without fastening system. Observed during facility
visits.
Local law and/or ETI requirement
ETI  One standing on
3.1 A safe and hygienic working environment shall be provided, bearing in the back of a truck
mind the prevailing knowledge of the industry and of any specific hazards. (loading area)
Adequate steps shall be taken to prevent accidents and injury to health arising compacting the
out of, associated with, or occurring in the course of work, by minimising, so far loaded material
as is reasonably practicable, the causes of hazards inherent in the working with its own body,
environment. without safety
harnesses. Another
Local law making application
Decree 351/79 Art. 200.- In all work at height, with danger of falls, the use of of foam protector in
seat belts will be mandatory. camera standing
on scaffolding with
Recommended corrective action: safety harness, but
Make sure that all work at height (about 1.8 m) is used relevant fastening not anchored.
system. Place rope of life.
Train the workers.

Non–compliance: 10

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
In the elaborated product and blancher sector there is no skirting board.
Observed during facility
visits
Local law and/or ETI requirement
ETI
3.1 A safe and hygienic working environment shall be provided, bearing in
mind the prevailing knowledge of the industry and of any specific hazards.
Adequate steps shall be taken to prevent accidents and injury to health arising
out of, associated with, or occurring in the course of work, by minimising, so far
as is reasonably practicable, the causes of hazards inherent in the working
environment.

Local law
LAW 19.587 Art. 8 - Every employer must adopt and put into practice the
appropriate measures of hygiene and safety to protect the life and integrity of
workers, especially as regards:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 41
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a) To the construction, adaptation, installation and equipment of buildings and


workplaces in adequate environmental and sanitary conditions;
b) To the placement and maintenance of guards and protectors of machinery
and all kinds of facilities, with the hygiene and safety devices that the best
technique advises;

Recommended corrective action:


Check the areas and place the missing skirting board.

Non–compliance: 11

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
There are two fork cranes that do not have a safety back light.
Observed during
Local law and/or ETI requirement  facility visits
ETI
3.1 A safe and hygienic working environment shall be provided, bearing in
mind the prevailing knowledge of the industry and of any specific hazards.
Adequate steps shall be taken to prevent accidents and injury to health arising
out of, associated with, or occurring in the course of work, by minimising, so far
as is reasonably practicable, the causes of hazards inherent in the working
environment.

Local law
Decree 351/79. Art. 134.- They will be provided with lights, brakes and acoustic
warning devices.

Recommended corrective action:


Repair the safety back light in poor condition.

Non–compliance: 12

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
Work clothes are not delivered as often as required (every 6 months).
Observed during
Local law and/or ETI requirement  document review
ETI  employee interview
3.1 A safe and hygienic working environment shall be provided, bearing in  facility responsible
mind the prevailing knowledge of the industry and of any specific hazards. interview
Adequate steps shall be taken to prevent accidents and injury to health arising
out of, associated with, or occurring in the course of work, by minimising, so far According facility rules,
as is reasonably practicable, the causes of hazards inherent in the working the work clothes shall
environment. be provided each six
month
Local law
LAW 20744 Art. 103 BIS. - Social benefits.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 42
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Social benefits are the benefits of a legal nature of social security, non-
remunerative, non-monetary, non-cumulative or substitutable in money, which
the employer provides to the worker by himself or through third parties, which
aims to improve the quality of life of the dependent or of his family in charge.
e) The provision of work clothes and any other element related to the clothing
and equipment of the worker for exclusive use in the performance of their
duties:

Recommended corrective action:


Review the process of delivery of clothing so that it is delivered within the
established deadlines.

Observation:

Description of observation: NONE Objective evidence


observed:
Local law or ETI requirement:

Recommended corrective action:

Good Examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 43
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

4: Child Labour Shall Not Be Used


4: Child Labour Shall Not Be Used
(Click here to return to NC–table)
(Click here to return to Key Information)

ETI
4.1 There shall be no new recruitment of child labour.
4.2 Companies shall develop or participate in and contribute to policies and programmes which provide
for the transition of any child found to be performing child labour to enable her or him to attend and
remain in quality education until no longer a child.
4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO Standards.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
The plant has a human resource responsible who verify the employees age through the Identification
card. In case of young worker, the plant required before the corresponding parents’ authorization, but
until today the plant does not have younger worker. No child labour was present during the factory visit
on the day of audit. Workers interviews confirmed that factory does not hire any child labour.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
 Employee file records for sample draw.
 Internal Rules document
 Code of Ethics and Coexistence
 Interview with employees
 Interview with facility responsible

Any other comments:


None

A: Legal age of employment: Argentinean Law 26390/2008:


Article 2º - The present law will reach the work of people smaller
than eighteen (18) years in all its forms.
The minimum age of admission to the employment rises at
sixteen (16) years in the terms of the present.
It is forbidden the work of people smaller than sixteen (16) years
in all their forms, exist or not relationship of contractual
employment, and be this remunerated or not.

Article 3º - Substitutes the article 32 of the Law 20.744, the one


that will be edited in the following way:
Article 32: Capacity. People from the eighteen (18) years, can
celebrate work contract.

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 44
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People from sixteen (16) years and smaller than eighteen (18)
years, can celebrate work contract, with their parents'
authorization, responsible or tutors. It is presumed off such an
authorization when the adolescent live independently of them.

B: Age of youngest worker found: 20 years old

C: Are there children present on the work Yes


floor but not working at the time of No
audit?

D: % of under 18’s at this site (of total 0 %


workers)

E: Are workers under 18 subject to Yes


hazardous work assignments? No
(Go to clause 3 – Health and Safety) If yes, please give details

Non–compliance:

1. Description of non–compliance: NONE Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)

Local law and/or ETI requirement:

Recommended corrective action:

Observation:

Description of observation: NONE Objective evidence


observed:
Local law or ETI requirement:

Comments:

Good Examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 45
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5: Living Wages are paid


5: Living Wages are Paid
(Click here to return to NC–table)
(Click here to return to Key information)

ETI
5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards
or industry benchmark standards, whichever is higher. In any event wages should always be enough to
meet basic needs and to provide some discretionary income.
5.2 All workers shall be provided with written and understandable information about their employment
conditions in respect to wages before they enter employment and about the particulars of their wages
for the pay period concerned each time that they are paid.
5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from
wages not provided for by national law be permitted without the expressed permission of the worker
concerned. All disciplinary measures should be recorded.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
The human resources responsible make a verification of each salary payment to determine the correct
amount to pay supported by the attendance records and bonus that apply. Factory paid different
income level depending on the position and numbers of working years –in agreeing with the Union (STIA
& UETRA) Salary table established. The employees confirm that the payment is on time, the payment stub
is clear and the discount applied is in agreed with the local law. Although the company has an
adequate management system associated with the payment, a punctual deviation was observed.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
 Employee pay stub from the sample draw.
 Collective Bargaining for the three union that actually has the Company.
 Employee interview.
 Facility responsible interview.

Any other comments:


None

Non–compliance: 13

1. Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
From the documentary review it is observed that some workers have worked
overtime according to attendance record that is higher than what they have Observed during
been paid (observed in revised records). document review (pay
stub for the sample
Local law and/or ETI requirement: draw)

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 46
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ETI  Attendance records


5.2 All workers shall be provided with written and understandable information show more
about their employment conditions in respect to wages before they enter overtime hours than
employment and about the particulars of their wages for the pay period those appear in the
concerned each time that they are paid. pay stub
document.
Local law
LAW 20744 Art. 119. - Prohibition to pay lower salaries.
For any reason, salaries lower than those fixed in accordance with this chapter
may be paid, except for those that result from reductions for apprentices or
minors, or for workers with a clearly diminished capacity or who work shorter
hours, not imposed by the qualification, in accordance with the provisions of
article 200.

Recommended corrective action:


Review the calculation process of overtime for payment, ensuring that all are
paid at all times.

Observation:

Description of observation: NONE Objective evidence


observed:
Local law or ETI requirement:

Comments:

Good Examples observed: !

Description of Good Example (GE): Objective Evidence


The organization provides its workers with monetary incentives for the use of Observed:
bicycles to go from home to the company or to do it walking.
Observed during the
interview with the
workers and the person
in charge of the
company.

Summary Information
 Criteria Local Law Actual at the Site Is this part of
(Please state legal (Record site results a Collective
requirement) against the law) Bargaining
Agreement?

A: Standard/Contracted work hours: Legal maximum: According with the Yes


(Maximum legal and actual required working Argentinean Law 11.544 document review, No
hours excluding overtime, please state if .- Article 1° - The the maximum
possible per day, week, and month) duration of the work

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 47
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won't be able to worked hours


exceed of eight daily were:
hours or forty eight
weekly hours for all Daily: 8 hours
person occupied by Weekly: 48 hours
other people's bill in
public or private
exploitations, although
they don't pursue ends
of lucre.

B: Overtime hours: Legal maximum: The site is in Yes


(Maximum legal and actual overtime hours, Argentinean Decree N° agreeing with the No
please state if possible per day, week, and 484/2000.- Article 1º - maximum legal.
month) Starting from the validity
of the present According with the
Ordinance, the document review,
maximum number of the maximum
supplementary hours worked hours
foreseen in the article 13 were:
of the Ordinance Nº
16.115/33, modified by Monthly: 8 hours
the Ordinance Nº
2882/79, it is established
in THIRTY (30) monthly
hours and TWO
HUNDRED (200) annual
hours, without necessity
of previous
administrative
authorization and
without damage of the
application of the
relative legal forecasts
work and rest.

C: wage for standard/contracted hours: Legal minimum: The site is in Yes


(Minimum legal and actual minimum wage at In any case, the total agreeing with the No
site, please state if possible per hr, day, week, remuneration that legal minimum
and month) perceives a monthly wage paid.
worker that fulfils a legal
working day will be able According with the
to be inferior to the vital document review,
minimum wage and the minimum paid
mobile settled down by is:
the corresponding Union
document.  STIA –
Minimum to be paid AR$112.51/Hour
from 1 Oct to 31 Dec  UATRE –
2018. AR$107.17/Hour
 STIA –
AR$112.51/Hour;
AR$202523.22/month

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 48
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 UATRE – AR$
87.52/Hour;
15915.29/month

D: overtime wage: Legal minimum: The site is in Yes


(Minimum legal and actual minimum overtime Argentinean Law agreeing with the No
wage at site, please state if possible per hr, #20744.- Article 201. - legal minimum
day, week, and month) Supplementary hours. overtime wage
The employer will pay paid.
the worker that lend
services in According with the
supplementary hours, document review,
mediate or non- the overtime
authorization of the percentage paid is
competent 50% and 100%
administrative organism,
an overcharge of fifty
percent (50%)
calculated on the
habitual wage, if will be
about the common
days, and of hundred
percent (100%) in days
Saturday after thirteen
o'clock (13) hours,
Sunday and holidays.
Wages analysis:
 Wages analysis:
(Click here to return to Key Information)

A: Were accurate records shown at Yes


the first request? No

If No, why not? Not applicable

B: Sample Size Checked 26 employees from October 2018 and 5 employees from
(State number of worker records November 2017 till September 2018.
checked and from which weeks/months
– should be current, peak, and
random/low. Please see SMETA Best
Practice Guidance and Measurement
Criteria)

C: Are there different legal minimum Yes If Yes, please give details:
wage grades? If Yes, please specify No If Yes, please give details:
all. According with corresponding Collective
bargain for each union (STIA & UETRA).

D: If there are different legal Yes If No, please give details:


minimum grades, are all workers No
graded and paid correctly? N/A

E: For the lowest paid production Below legal Lowest actual wages found: Note: full time
workers, are wages paid for min employees and please state hour / week / month etc.
standard/contracted hours Meet

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 49
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(excluding overtime) below or above Above The lowest earning found is in line with the
the legal minimum? minimum established for each union collective
bargain and with the lowest possible position.

F: Please indicate the breakdown of _0__% of workforce earning under min wage
workforce per earnings: _1.3% of workforce earning min wage
98.7% of workforce earning above min wage

F: Bonus scheme found: Bonus Scheme found:


Please specify details: Note: full time employees and please state hour / week / month
etc.

Company paid union bonus, production incentive and heath


bonus to employees when use bicycle and walk to go facility to
work.

H: What deductions are required by Social security


law e.g. social insurance? Seniority
Please state all types: Union Contribution

I: Have these deductions been Yes Please list all 1. Social security 3 %
made? Please list all deductions that No deductions that 2. Seniority 11 %
have/have not been made. have been made. 3.- Union Contribution 2.5 %
(STIA) & 3.0% (UETRA) for
unionized workers
4.- Funeral insurance 1.5%
(UATRE)
5.- Guild Share 2.0%
6.- LAW 119032 3.0%

Please describe: The deduction


made are in agreeing with the
local regulation and approved
by the workers.

Please list all 1.


deductions that 2.
have not been
made. Please describe:

J: Were appropriate records Yes


available to verify hours of work and No
wages?

K: Were any inconsistencies found? Yes Poor record keeping


(if yes describe nature) No Isolated incident
Repeated occurrence:

L: Do records reflect all time worked? Yes


(For instance, are workers asked to No
attend meetings before or after work Please give details:
but not paid for their time)

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M: Is there a defined living wage: Yes


This is not normally minimum legal No
wage. If answered yes, please state Please specify amount/time: There is no living wage.
amount and source of info: The minimum wage is determined by the authority and by each
Please see SMETA Best Practice Union every year.
Guidance and Measurement Criteria.

If yes, what was the calculation ISEAL/Anker Benchmarks


method used. Asia Floor Wage
Figures provided by Unions
Living Wage Foundation UK
Fair Wear Wage Ladder
Fairtrade Foundation
Other – please give details:

N: Are there periodic reviews of Yes


wages? If Yes give details (include No
whether there is consideration to Please give details:
basic needs of workers plus
discretionary income).

O: Are workers paid in a timely Yes


manner in line with local law? No

P: Is there evidence that equal rates Yes


are being paid for equal work: No
Please give details:

Q: How are workers paid: Cash


Cheque
Bank Transfer
Other
If other, please explain:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 51
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6: Working Hours are not Excessive


6: Working Hours are not Excessive
(Click here to return to NC–table)
(Click here to return to Key Information)

 ETI
6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6
below, whichever affords the greater protection for workers. Sub–clauses 6.2 to 6.6 are based on
international labour standards.

6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per
week.

6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the
following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It
shall not be used to replace regular employment. Overtime shall always be compensated at a premium
rate, which is recommended to be not less than 125% of the regular rate of pay.

6.4 The total hours worked in any 7-day period shall not exceed 60 hours, except where covered by
clause 6.5 below.

6.5 Working hours may exceed 60 hours in any 7-day period only in exceptional circumstances where all
of the following are met:
– this is allowed by national law;
– this is allowed by a collective agreement freely negotiated with a workers’ organisation
representing a significant portion of the workforce;
– appropriate safeguards are taken to protect the workers’ health and safety; and
– The employer can demonstrate that exceptional circumstances apply such as unexpected
production peaks, accidents or emergencies.

6.6 Workers shall be provided with at least one day off in every 7-day period or, where allowed by
national law, 2 days off in every 14-day period.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
The company human resources responsible perform the review and verification of monthly attendance
records for each employee to determine the working hours to determine the normal and overtime hours
worked. During the document and worker interview was evidenced that the overtime is voluntary and
the employees can refuse made it without posterior consequences. However, a punctual deviation was
observed.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
 Employee attendance records for sample draw.
 Employees interview
 Human resources responsible interview

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 52
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Any other comments:


None

Non–compliance: 14

1. Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
The organization does not provide its workers with attendance records so they
can review it and confirm consistency in the marks presented. Observed during:
 Document review
Local law and/or ETI requirement:  Employees
ETI interview
6.1 Working hours must comply with national laws, collective agreements, and  Facility
the provisions of 6.2 to 6.6 below, whichever affords the greater protection for responsible
interview
workers. Sub–clauses 6.2 to 6.6 are based on international labour standards.
 Human
Resources
Local law
interview
National Decree 16115/33. Art 21. Art. 21.- The companies will keep permanent
records of all the extensions of the working day, which are exceptional,
indicating their duration in hours and days, causes that they obey and
personnel included in the exceptions and, in their case, in the recovery.

Recommended corrective action:


Be sure to provide a record of assistance to workers so that they can review
their marks and verify that they are correct.

Observation:

Description of observation: NONE Objective evidence


observed:
Local law or ETI requirement:

Comments:

Good Examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 53
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Working hours’ analysis


Working hours’ analysis
Please include time e.g. hour/week/month
(Go back to Key information)

Systems & Processes

A. What timekeeping Describe: Company (approaching card),


systems are used:
time card etc.

Yes
B: Is sample size same No
as in wages section? If no, please give details

C: Are Yes If NO, please give details including % and which


standard/contracted No type of workers do NOT have standard hours
working hours defined in contracts/employment agreements.
defined in all Please give details:
contracts/employme
nt agreements?

D: Are there any Yes If YES, please complete as appropriate:


other types of No
contracts/employme
nt agreements used? 0 hrs Part Other
time Variable
hrs

If “Other”, Please define:

E. Do any Yes If yes, please detail hours, %, types of workers


standard/contracted No affected and frequency
working hours
defined in Please give details:
contracts/employme
nt agreements
exceed 48 hours per
week?

F: Are workers Please select all applicable: Is this allowed by local law?
provided with at 1 in 7 days Yes
least 1 day off in 2 in 14 days No
every 7-day-period, No
or 2 in 14-day- If ‘No’, please explain:
period?
Maximum number of days worked without a day off (in sample):

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 54
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During document review was evidenced that the employees worked as


maximum 6 continuous days.

Standard/Contracted Hours worked

G: Were standard Yes If yes, % of workers & frequency:


working hours over 48 No
hours per week
found?

H: Any local Yes If yes, please give details:


waivers/local law or No
permissions which
allow
averaging/annualise
d hours for this site?

Overtime Hours worked

I: Actual overtime Highest OT hours: 30 hours per month.


hours worked in
sample (State per
day/week/month)

J: Combined hours Yes


(standard or No
contracted +
overtime hours =
total) over 60 found?
Please give details:

K: Approximate __0____%
percentage of total
workers on highest
overtime hours:

L: Is overtime Yes Please detail evidence e.g. Wording of contract /


voluntary? No employment agreement / handbook / worker
Conflicting Information interviews / refusal arrangements:

According with employees interview in general they


commented that can refuse to made overtime or
work on holidays days

Overtime Premiums

M: Are the correct Yes Please give details of normal day overtime premium
legal overtime No as a % of standard wages:
premiums paid? N/A – there is no legal
requirement to OT  50% on working days
premium  100% on holydays.

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N: Is overtime paid at Yes If yes, please describe % of workers & frequency:


a premium? No
The % of workers is relative, depending of the
necessity of the final client. In general the numbers
of workers that made overtime is very low and there
is no a clear frequency.

O: If the site pays less No


than 125% OT Consolidated pay (May be standard wages above minimum legal wage, with
premium and this is no/low overtime premium)
allowed under local Collective Bargaining agreements
law, are there other Other
considerations?
Please complete the Please explain any checked boxes above e.g. detail of consolidated pay / CBA
boxes where or Other
relevant.

Not applicable. The company pay more than 125%.

P: If more than 60 Overtime is voluntary


total hours per week Onsite Collective bargaining allows 60+ hours/week
and this is legally Safeguards are in place to protect worker’s health and safety
allowed, are there Site can demonstrate exceptional circumstances
other considerations? Other reasons (please specify)
Please complete the
boxes where Please explain any checked boxes above e.g. detail of consolidated pay / CBA
relevant. or other:

Q: Is there evidence Yes


that overtime hours No
are being used for If yes, please give details:
extended periods to
make up for labour
shortages or
increased order
volumes?

R: If sufficient workers Yes


cannot be hired, are No
new working time
arrangements
explored to ensure
that overtime is the
exception rather
than the rule.

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7: No Discrimination is practiced
7: No Discrimination is Practiced
(Click here to return to NC–table)

ETI
7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or
retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual
orientation, union membership or political affiliation.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
During the audit, the employees confirmed there is not discrimination. Besides, the plant is following the
Argentinean law in this matter that forbidden the discrimination as a fundamental worker right. The
employees commented that they receive the payment in agree with the position and production.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
 Employees interview
 Facility responsible interview
 Internal rules document
 Code of Ethics and Coexistence
 Pay stub for sample draw

Any other comments:


None

A: Gender breakdown of Management Male: _75____ %


+ Supervisors (Include as one combined Female_25____ %
group)

B: Number of women who are in skilled #: 23 women working in the sector of quality, guard,
or technical roles e.g. where specific administration of plant and field.
qualifications are needed i.e. machine
engineer / laboratory analyst:

C: Is there any evidence of Hiring


discrimination based on race, caste, Compensation
national origin, religion, age, disability, access to training
gender, marital status, sexual orientation, promotion
union membership or political affiliation?: termination or retirement

Professional Development

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A: What type of training and development Annual training plan incorporating the following topics: safety,
are available for workers? hygiene and safety and specific to the workplace.

B: Are HR decisions e.g. promotion, Yes


training, compensation based on
objective, transparent criteria? No

If no, please give details:

Non–compliance:

1. Description of non–compliance: NONE Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)

Local law and/or ETI requirement:

Recommended corrective action:

Observation:

Description of observation: NONE Objective evidence


observed:
Local law or ETI requirement:

Comments:

Good Examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

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8: Regular Employment Is Provided


8: Regular Employment Is Provided
(Click here to return to NC–table)
(Click here to return to Key Information)

ETI
8.1 To every extent possible work performed must be on the basis of recognised employment relationship
established through national law and practice.
8.2 Obligations to employees under labour or social security laws and regulations arising from the regular
employment relationship shall not be avoided through the use of labour–only contracting, sub–
contracting, or home–working arrangements, or through apprenticeship schemes where there is no real
intent to impart skills or provide regular employment, nor shall any such obligations be avoided through
the excessive use of fixed–term contracts of employment.

Additional Elements: Responsible Recruitment


8.3 Suppliers have full understanding of the entire recruitment process and assess all labour recruiters and
intermediaries against legal and/or ethical requirements.
8.4 There are effective management systems in place to identify and monitor the hiring and
management of all migrant workers, contract workers, agency workers, temporary or casual labour. The
supplier shall implement processes to enable adequate control over agencies with regards the above
points and related legislation.
8.5 Employment agencies must only supply workers registered with them.
8.6 Workers pay no recruitment fee at any stage of the recruitment process.
8.7 Worker contracts accurately reflect the agreed payment and terms in the recruitment process and
are understood and signed by workers.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
The human resources responsible verify the preparation of contractual relation and make a regular
control of them. All the employees need to sign and put the date when the communication about their
job relation with the company start, matter that is made through the document CAT (“Clave Alta
Temprana”). Company has adequate understanding about the migrant contract process -the company
has not migrant workers. There is no use of employment agency and the workers does not paid any fee
during the recruitment process, matter confirmed during interviews.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:

 Contracts for the sample draw


 Employees interview
 Facility responsible interview
 Human Resources responsible interview
 Other documents that support the relationship between the facility and the employees for
selected sample draw

Any other comments:

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None

Non–compliance:

1. Description of non–compliance: NONE Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)

Local law and/or ETI requirement:

Recommended corrective action:

Observation:

Description of observation: NONE Objective evidence


observed:
Local law or ETI requirement:

Comments:

Good Examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

Responsible Recruitment

All Workers

A: Were all workers presented Terms & Conditions presented


with terms of employment at the Understood by workers
time of recruitment, did they Same as actual conditions
understand them and are they
same as current conditions? If any are unchecked, please describe finding and specific
category(ies) of workers affected:

B: Did workers pay any fees, Yes


taxes, deposits or bonds for the No
purpose of If yes, please describe details and specific category(ies) of workers
recruitment/placement? affected:

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C: If yes, check all that apply: Recruitment / hiring fees


Service fees
Application costs
Recommendation fees
Placement fees
Administrative, overhead or processing fees
Skills tests
Certifications
Medical screenings
Passports/ID’s
Work / resident permits
Birth certificates
Police clearance fees
Any transportation and lodging costs after employment offer
Any transport costs between work place and home
Any relocation costs after commencement of employment
New hire training / orientation fees
Medical exam fees
Deposit bonds or other deposits
Any other non-monetary assets
Other – please give details

D: If any checked, give details: Not applicable

Migrant Workers:
The term "migrant worker" refers to a person who is engaged or has been engaged in a remunerated activity in a
country of which they are not a national and where they do not intend to remain permanently or has purposely
migrated on a temporary basis to another in-country region to seek and engage in a remunerated activity

A: Type of work undertaken by Not applicable, all workers are Argentinean.


migrant workers:

B: Migrant worker recruitment Total number of (in country recruitment agencies) used: 0
Total number of (outside of local country) recruitment agencies
used: 0

C: Are migrant workers’ voluntary Yes Observations


deductions (such as for remittances) No
confirmed in writing by the worker and Please describe Not applicable. There are no migrant
is evidence of the transaction supplied finding: workers.
by the facility to the worker?

Yes
D: Are any migrant workers in skilled, No
technical, or management roles
If yes number and example of roles:
Migrant Workers (this should include all
migrant workers including permanent
workers, temporary and/or seasonal Not applicable. There are no migrant workers.
workers)

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NON-EMPLOYEE WORKERS

Recruitment Fees:
A: Are there any fees? Yes
No Not applicable. There are no Non-employees workers.

B: If yes, check all that Recruitment / hiring fees


apply: Service fees
Application costs
Recommendation fees
Placement fees
Administrative, overhead or processing fees
Skills tests
Certifications
Medical screenings
Passports/ID’s
Work / resident permits
Birth certificates
Police clearance fees
Any transportation and lodging costs after employment offer
Any transport costs between work place and home
Any relocation costs after commencement of employment
New hire training / orientation fees
Medical exam fees
Deposit bonds or other deposits
Any other non-monetary assets
Other – please give details

C: If any checked, give


details: Not applicable. There are no Non-employees workers.

Agency Workers (if applicable)


(workers sourced from a local agent who are not directly paid by the site, but paid by the agency, Usually the
agencies are paid by the site and the wages of the individual workers are paid by the agency.)

A: Number of agencies used 0


(average): Names if available:
Not applicable. There are no Agency workers.

B: Were agency workers’ age / Yes


pay / hours included within the No
scope of this audit? Not applicable. There are no Agency workers.

C: Were sufficient documents for Yes


agency workers available for No
review? Not applicable. There are no Agency workers.

D: Is there a legal contract / Yes


agreement with all agencies? No

Please give details:


Not applicable. There are no Agency workers.

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E: Does the site have a system for Yes


checking labour standards of No
agencies?
If yes, please give details. Please give details:

Not applicable. There are no Agency workers.

Contractors:
Note: contractors in this context are generally individuals who supply several workers to a site. Usually the contractors
are paid by the site and the wages of the workers are paid by the contractor. Common terms include, gang bosses,
labor provider,

Yes
A: Any contractors on site? No
If yes, how many contractors are present, please give details:

During the audit, there is no contractor. They are requested to


B: If Yes, how many workers supplied
go to the company when it is necessary some specific activity
by contractors?
to develop inside like Pest Control and Assembly.

Yes
C: Do all contractor workers No
understand their terms of Please describe finding:
employment? Not applicable - during the audit, there was not observed
contractor.

D: If Yes, please give evidence for Not applicable - during the audit, there was not observed
contractor workers being paid per law: contractor.

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8A: Sub–Contracting and Homeworking:


8A: Sub–Contracting and Homeworking
(Click here to return to NC–table)
(Click here to return to Key Information)

8A.1 There should be no sub–contracting unless previously agreed with the main client.
8A.2 Systems and processes should be in place to manage sub–contracting, homeworking and external
processing.
Note to auditor on homeworking:
Report on whether it is direct or via agents. How many workers, relationship with site and what control
systems are in place.
Note to auditor on subcontracting: auditor should use this section for subcontractors of part made or
wholly made finished goods, this section should not be used for raw material manufacturers unless
instructed otherwise by customers

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
The facility has not subcontracting and home working. During site tour was evidenced that there is not
dormitories within the premises of the facility, all employees live outside. There is not external process
developed.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
No applicable. There is not external process developed.

If any processes are sub–contracted – please populate below boxes


Process Subcontracted Process 1 Process 2
Name of factory
Address

Details:
No applicable. There is not external process developed.

Non–compliance:

1. Description of non–compliance: NONE Objective evidence


NC against ETI/Additional Elements NC against Local Law observed:
NC against customer code: (where relevant please
add photo numbers)

Local law and/or ETI /Additional Elements requirement:

Recommended corrective action:

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Observation:

Description of observation: NONE Objective evidence


observed:
Local law or ETI/Additional elements requirement:

Comments:

Good Examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

 Summary of sub–contracting – if applicable


Not Applicable please x

A: Has the auditor made a simple Yes


calculation to compare capacity No
with workers’ work load in order to Please describe:
identify possible unrecorded work
or undeclared sub-contracting

B: If sub–contractors are used, is Yes


there evidence this has been No
agreed with the main client? If Yes, summarise details:

C: Number of sub–
contractors/agents used:

D: Is there a site policy on sub– Yes


contracting? No
If Yes, summarise details:

E: What checks are in place to


ensure no child labour is being
used and work is safe?

 Summary of homeworking – if applicable


Not Applicable please x

A: If homeworking is being used, is Yes


there evidence this has been No
agreed with the main client? If Yes, summarise details:

B: Number of homeworkers Male: Female: Total:

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C: Are homeworkers employed Directly If through agents, number of


direct or through agents? Through Agents agents:

D: Is there a site policy on Yes


homeworking? No

E: How does the site ensure


worker hours and pay meet local
laws for homeworkers?

F: What processes are carried out


by homeworkers?

G: Do any contracts exist for Yes


homeworkers? No

Please give details:

H: Are full records of homeworkers Yes


available at the site? No

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9: No Harsh or Inhumane Treatment is allowed


9: No Harsh or Inhumane Treatment is Allowed
(Click here to return to NC–table)

ETI
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal
abuse or other forms of intimidation shall be prohibited.
Additional elements:
9.2 companies should provide access to a confidential grievance mechanism for all workers

A: Are there published, anonymous Yes


and/or open channels available for No
reporting any violations of Labour Please give details: Company has a complaint box located in
standards and H&S or any other the site in an adequate play ensuring confidentiality. Besides,
grievances to a 3rd party? there is a web page where can be reach an email address to
issue complaint and suggestions or through a phone number.

 http://www.servagrop.com.ar/conducta.php#about-
accordion3
 rse@servagrop.com.ar
 (54-353) 4960348

B: If Yes, are workers aware of these Yes. Confirmed during the employee’s interview and besides
channels and have access? Please give during facility responsible and managers.
details.

C: If yes, what type of mechanism is used Web page


e.g. hotline, whistle blowing mechanism, Email
comment box etc. Please give details. Phone number
Workers
D: Which of the following groups is there a Communities
grievance mechanism in place for? Suppliers
Other

Please give Details: Actually the grievance mechanism is


focused in workers and supplier. And at the end of the audits
was understood the necessity to include the community,
matter that will be developed in a short time.
Yes
E: Are there any open disputes? No

If yes, please give details

Yes
F: Does the site encourage its business No
partners (e.g., suppliers) to provide If no, please give details
individuals and communities with access
to effective grievance mechanisms (e.g.
help lines or whistle blowing mechanism)

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Yes
G: Is there a published and transparent No
disciplinary procedure? If no, please explain

Yes
H: If yes, are workers aware of these the No
disciplinary procedure? If no, please give details

Yes
I: Does the disciplinary procedure allow for No
deductions from wages (fines) for If yes, please give details
disciplinary purposes (see wages section)?

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
The Company is following the Argentinean law in this matter that forbidden an inhumane treatment nor
harsh. No evidence found for harsh or inhumane treatment in the Company. Records review did not
evidence any disciplinary action taken against any worker. Workers interviews confirmed the same.
However, during the audit was observed a deviation associated with the sanction procedure
application.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
 Employees interview
 Facility responsible interview
 Internal rules document
 Code of Ethics and coexistence

Any other comments:


NONE

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Non–compliance: 15

Description of non–compliance: Objective evidence


NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please
add photo numbers)
The sanction process that the organization has is not being carried out as it is
established in the document "Internal Regulation".
Observed during
Local law and/or ETI requirement:  Document review
ETI  Employee interview
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other  Facility responsible
harassment and verbal abuse or other forms of intimidation shall be prohibited. interview

Recommended corrective action: Evidenced that


Make sure that the established sanction process is followed as established. sanctions were issued
Leave evidence of it. to workers, without
receiving the worker's
appeal, as established
in the procedure to be
followed.

Observation:

Description of observation: NONE Objective evidence


observed:
Local law or ETI requirement:

Comments:

Good Examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

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10 A: Entitlement to Work and Immigration


10. Other Issue areas: 10A: Entitlement to Work and Immigration
(Click here to return to NC–table)

Additional Elements
10A.1 Only workers with a legal right to work shall be employed or used by the supplier.
10A.2 All workers, including employment agency staff, must be validated by the supplier for their legal
right to work by reviewing original documentation.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
Compliance of the law as it specifies that can be hired migrant worker, having open the doors to any
non-Argentinean person that want work – same opportunity. The human resource responsible has the
responsibility to control this matter. The step is first to verify the legal right to the worker to be employee
through the requirement of working authorization issued by the local authorities or well through the
identification card. The organization has not non-Argentinean employee.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:

 Employees interview
 Facility responsible interview
 Facility Human Resources responsible
 Internal rules document

Any other comments: None

Non–compliance:

1. Description of non–compliance: NONE Objective evidence


NC against ETI/Additional Elements NC against Local Law observed:
NC against customer code: (where relevant please
add photo numbers)
Local law and/or ETI /Additional Elements requirement:

Recommended corrective action:

Observation:

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Description of observation: NONE Objective evidence


observed:
Local law or ETI/Additional Elements requirement:

Comments:

Good examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

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10 B 2: Environment 10B4: Environment 4–Pillar


10. Other issue areas 10B4: Environment 4–Pillar
(Click here to return to NC–table)
To be completed for a 4–Pillar SMETA Audit and remove the previous page which is 10B2 environment 2
pillar

B.4. Compliance Requirements


10B4.1 Businesses as a minimum must meet the requirements of local and national laws related to
environmental standards.
10B4.2 Where it is a legal requirement, businesses must be able to demonstrate that they have the
relevant valid permits including for use and disposal of resources e.g. water, waste etc.
10B4.3 Businesses shall be aware of their end client’s environmental standards/code requirements
10B4.4 Suppliers should have an environmental policy, covering their environmental impact, which is
communicated to all appropriate parties, including its own suppliers.
10B4.5 Suppliers shall be aware of the significant environmental impact of their site and its processes.
10B4.6 The site should measure its impacts, including continuous recording and regular reviews of use and
discharge of natural resources e.g. energy use, water use (see 4–pillar audit report and audit checks for
details).
10B4.7 Businesses shall make continuous improvements in their environmental performance.
10B4.8 Businesses shall have available for review any environmental certifications or any environmental
management systems documentation
10B4.9 Businesses should have a nominated individual responsible for co–ordinating the site’s efforts to
improve environmental performance.
B4. Guidance for Observations
10B4.10 Suppliers should have completed the appropriate section of the SAQ and made it available to
the auditor.
10B4.11 Has the site recently been subject to (or pending) any fines/prosecutions for noncompliance to
environmental regulations.

Note for auditors and readers. This environment section is intended to take not more than 0.25 auditor
days. It is an assessment only and the main requirement is to establish whether a site is meeting
applicable environmental laws and/or has any certifications or environmental management systems in
place. Following this assessment the client/supplier may decide a full environmental audit is required (see
also best practice guidance/environment and guidance for auditor)

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
The Company has a behaviour that includes a good performance against the environment maintaining
a continued improvement in this matter. This is known by the employees who are clear and understand
that they are part of good service provision practices and shall contribute to maintain it. However, were
founded two punctual deviations in this matter.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:

- Environmental Management System manual


- Environmental aspect and impact matrix

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- Record of natural resources control


- Environmental objectives and goals
- Residues management procedure
- Certificate of disposition and co-processing of contaminates solids
- Waste removal receipt (27 Feb 2018, 22 Jun 2018, 29 Nov 2018)
- Interview of site responsible
- Interview of site employees

Any other comments: None

Non–compliance: 16

Description of non–compliance: Objective evidence


NC against ETI/Additional Elements NC against Local observed:
NC against customer code: (where relevant please
add photo numbers)
The organization has an environmental policy, but there is no evidence that
has been disseminated to all levels of the organization.
Observed during
Local law and/or ETI/Additional Elements requirement:  Document review
ETI  Facility responsible
10B4.4 Suppliers should have an environmental policy, covering their interview
environmental impact, which is communicated to all appropriate parties,
including its own suppliers.

Recommended corrective action:

Make sure that the environmental policy has been disseminated to all levels of
the organization. Leave a record of it.

Non–compliance: 17

Description of non–compliance: Objective evidence


NC against ETI/Additional Elements NC against Local observed:
NC against customer code: (where relevant please
add photo numbers)
An empty lubricating oil container (hazardous waste) is observed in a domestic
garbage container. Additionally, non-hazardous waste is deposited in
containers that indicate "hazardous waste", container to leave used Observe during facility
lubricating oil that has a label that does not correspond and container visits.
containing oil without secondary containment system.

Local law and/or ETI/Additional Elements requirement:


ETI
10B4.1 Businesses as a minimum must meet the requirements of local and
national laws related to environmental standards.

Local law
Law 28611 General Environmental Law. Article 119 ° .- the management of
solid waste.

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119.1 The management of solid waste from domestic, commercial origin or


being of different origin have similar characteristics to those, are the
responsibility of local governments. By law management regime and
management of municipal solid wastes.
119.2 The management of solid wastes other than those listed in the preceding
paragraph are the responsibility of the generator to their proper disposal under
control conditions and supervision provided for in the legislation.

Recommended corrective action:


Ensure that hazardous waste is handled properly. Train workers in this regard.

Observation: 6

Description of observation: Objective evidence


observed:
There is no evidence that the organization nominated formally a person
responsible for coordinating the site's efforts to improve its environmental
performance. Observed during facility
responsible interview.
Local law or ETI/Additional elements requirements:
ETI
10B4.9 Businesses should have a nominated individual responsible for co–
ordinating the site’s efforts to improve environmental performance.

Comments:
The company has a responsible, however the nomination was not made
formally. According with the comments made by the facility responsible, the
nomination will be made in a short time to be in compliance with the
requirement.

Good examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

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Environmental Analysis
 Environmental Analysis
(Site declaration only – this has not been verified by auditor. Please state units in all cases below.)

A: Is there a manager responsible for Environmental Baltazar Prono – Responsible for Environmental,
issues (Name and Position): Safety and Hygiene

Yes No
B: Has the site conducted a risk assessment on the Please give details: Environmental Impact matrix
environmental impact of the site, including
implementation of controls to reduce identified
risks?

C: Does the site have a recognised environmental Yes No


system certification such as ISO 14000 or Please give details:
equivalent?
Please detail.

D: Does the site have an Environmental policy? Yes No


(For guidance, please see Measurement criteria) If yes, is it publicly available?

E: If yes, does it address the key impacts from their Yes No


operations and their commitment to improvement? Please give details:

F: Does the site have a Biodiversity policy? Yes No


(For guidance, please see Measurement criteria)

G: Is there any other sustainability systems present Yes No


such as Chain of Custody, Forest Stewardship Please give details:
Council (FSC), Marine Stewardship Council (MSC)
etc.?
Please detail.
(For guidance, please see Measurement criteria)

H: Have all legally required permits been shown? Yes No


Please detail. Please give details:

I: Is there a documentation process to record Yes No N/A


hazardous chemicals used in the manufacturing Please give details: Manual of Good Manufacture
process? Practices and list of all chemical allowed.

J: Is there a system for managing client’s Yes No


requirements and legislation in the destination Please give details: Not applicable
countries regarding environmental and chemical
issues?

K: Facility has reduction targets in place for Yes No


environmental aspects e.g. water consumption Please give details:
and discharge, waste, energy and green-house
gas emissions

L: Facility has evidence of waste recycling and is Yes No


monitoring volume of waste that is recycled. Please give details:

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M: Does the facility have a system in place for Yes No


accurately measuring and monitoring consumption Please give details:
of key utilities of water, energy and natural
resources that follows recognised protocols or
standards

N: Has the facility checked that any Sub- Yes No


Contracting agencies or business partners Please give details: established in the providers
operating on the premises have the appropriate evaluation.
permits and licences and are conducting business
in line with environmental expectations of the
facility?

 Usage/Discharge analysis

Criteria Previous year: Please Current Year: Please


state period: state period: _March to
_2017__________ May 2018__________

Electricity Usage: 396.084 995.510


Kw/hrs

Renewable Energy Usage: N/A N/A


Kw/hrs

Gas Usage: 98.470 m3 141.603 m3


Kw/hrs

Has site completed any carbon Footprint Analysis? Yes No Yes No

If Yes, please state result N/A N/A

Water Sources:  Well water  Well water


Please list all sources e.g. lake, river, and local water
authority.

Water Volume Used: Not informed Not informed


(m³)

Water Discharged:  Infiltration  Infiltration


Please list all receiving waters/recipients.  

Water Volume Discharged: Not informed Not informed


(m³)

Water Volume Recycled: N/A N/A


(m³)

Total waste Produced 25.620 kilos October to 23.940 kilos April to June
(please state units) Dec 2017 2018

Total hazardous waste Produced: 320 kilos 400 kilos


(please state units)

Waste to Recycling: N/A N/A

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(please state units)

Waste to Landfill: N/A N/A


(please state units)

Waste to other: N/A N/A


(please give details and state units)

Total Product Produced 50.221 TON Not informed


(please state units)

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10C: Business Ethics – 4–Pillar Audit


10C: Business Ethics – 4-Pillar Audit
(Click here to return to NC–table)
To be completed for a 4–Pillar SMETA Audit

10C. Compliance Requirements


10C.1 Businesses shall conduct their business ethically without bribery, corruption, or any type of
fraudulent Business Practice.
10C.2 Businesses as a minimum must meet the requirements of local and national laws related to bribery,
corruption, or any type of fraudulent Business Practices.
10C.3 Where it is a legal requirement, businesses must be able to demonstrate that they comply
with all fiscal legislative requirements.
10C.4 Businesses shall have access to a transparent system in place for confidentially reporting, and
dealing with unethical Business Ethics without fear of reprisals towards the reporter.
10C.5 Businesses should have a Business Ethics policy, covering bribery, corruption, or any type of
fraudulent Business Practice,
10C.6 Businesses should have a designated person responsible for implementing standards concerning
Business Ethics
10C.7 Suppliers should ensure that the staff whose job roles carry a higher level of risk in the area of
ethical Business Practice e.g. sales, purchasing, logistics are trained on what action to take in the event of
an issue arising in their area.

10C. Guidance for Observations

10C.8 Businesses should communicate their Business Ethics policy, covering bribery, corruption, or any
type of fraudulent Business Practice to all appropriate parties, including its own suppliers.
10C.9 Has the site recently been subject to (or pending) any fines/prosecutions for non-compliance to
Business Ethics regulations. If so is there evidence that sustainable corrective actions have been
implemented

Note for auditors and readers. This Business Ethics section is intended to take not more than 0.25 auditor
days. It is an assessment not an audit.

 Current Systems and Evidence Examined


To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
The company has a Business Integrity Policy which is published in the web page and in different areas of
the company. This Policy is communicated to the employees during the induction made to new
employees, matter that was evidenced during the employees’ interview. Besides the company has a
Code of Ethics and Coexistence which include Business Integrity elements. However, deviations were
observed.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:

 Internal policy
 Employee interview
 Facility responsible interview
 Web page view

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 Code of Ethics and Coexistence

Any other comments: None

Non–compliance: 18

Description of non–compliance: Objective evidence


NC against ETI/Additional Elements NC against Local observed:
NC against customer code: (where relevant please
add photo numbers)
The organization has a transparent system to confidentially report unethical
Business Practices without fear of reprisals against the informant. However, the
implemented system - web page - does not allow the user easy access and Observed during facility
understand the applicability of this link. responsible interview.

Local law and/or ETI/Additional Elements requirement:


ETI
10C.4 Businesses shall have access to a transparent system in place for
confidentially reporting, and dealing with unethical Business Ethics without fear
of reprisals towards the reporter.

Recommended corrective action:


Check the web page so that access is easily accessible.

Non–compliance: 19

Description of non–compliance: Objective evidence


NC against ETI/Additional Elements NC against Local observed:
NC against customer code: (where relevant please
add photo numbers)
The organization has not formally defined a responsible person to carry out the
rules about the Business Practices.
Observed during facility
Local law and/or ETI/Additional Elements requirement: responsible interview.
ETI
10C.6 Businesses should have a designated person responsible for
implementing standards concerning Business Ethics

Recommended corrective action:


Establish formally a responsible to carry out the rules about the Business
Practices.

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Non–compliance: 20

Description of non–compliance: Objective evidence


NC against ETI/Additional Elements NC against Local observed:
NC against customer code: (where relevant please
add photo numbers)
There is no evidence that the organization has a system that ensures that its
key personnel related to ethical business practices know how to act in case of
any problem in this matter. Observed during facility
responsible interview.
Local law and/or ETI/Additional Elements requirement:
ETI
10C.7 Suppliers should ensure that the staff whose job roles carry a higher level
of risk in the area of ethical Business Practice e.g. sales, purchasing, logistics
are trained on what action to take in the event of an issue arising in their area.

Recommended corrective action:


Be sure to implement a system that ensures that your key personnel related to
ethical business practices know how to act in case of any problem in this
matter.

Observation

Description of observation: NONE Objective evidence


observed:

Local law or ETI/Additional elements requirement:

Comments:

Good examples observed:

Description of Good Example (GE): NONE Objective Evidence


Observed:

Internal Policy
A: Does the facility have a Business Ethics Policy for third parties including suppliers
Policy and is the policy communicated and

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applied internally, externally or both, as


appropriate? Please give details: The policy is published in different
areas of the facility, known by the workers. Evidenced
during document review.
Yes
B: Does the site give training to relevant No
personnel (e.g. sales and logistics) on
business ethics issues? Please give details: However, there is no formal evidence.
Yes
C: Is the policy updated on a regular (as No
needed) basis?
Please give details: The Management established the
policy will be reviewed every year, and in case of
necessity will be updated.
Yes
D: Does the site require third parties No
including suppliers to complete their own
business ethics training Please give details: The company communicate the Code
of Conduct to third parties and urges them to follow the
guidelines established in the code and / or to establish
their own code.
Other findings

Other Findings Outside the Scope of the Code

None

Community Benefits
(Please list below any specific community benefits that the site management stated that they were involved in, for
example, HIV programme, education, sports facilities)

Economic help to the Bibilia Abierta church


T-shirt shopping to the club “LIBERTAD”
One of the company owners is an active member on LALCEC (“Liga Argentina de Lucha Contra el
Cáncer”)
Buy to the municipality of Mobile Unit /consulting room
An agreement was signed with the Popular University of Hernando, where one of the directors is an
active member.

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Appendix 1
 Comparison between ETI code and Customer's Supplier's Code. Any areas where a site complies with the
Customer's Supplier Code, but not with the ETI code are discussed at the audit close out meeting and
recorded on the CAPR. Note to supplier "for this customer it may not be necessary to complete corrective
actions where NC's DO NOT meet the ETI code, but DO meet your customer's code. If the audit is shared
with other customers who work to the ETI code or an equivalent international standard, corrective actions
will be necessary."
Not Applicable please x

NOTE: The provisions of the ETI base Code Instruction to Audit Company: fill in the relevant
constitute minimum and not maximum standards, clauses from the Customer Supplier Code - where
and this code should not be used to prevent applicable.
companies from exceeding these standards.
Companies applying the ETI Base Code are
expected to comply with national and other
applicable law and, where the provisions of law
and the ETI Base Code address the same subject,
to apply that provision which affords the greater
protection.

ETI Code / Additional Elements Customer's Supplier Code equivalent

0.A. Universal Rights covering UNGP 0.A. Universal Rights covering UNGP

0.A. Guidance for Observations


0.A.1 Businesses should have a policy, endorsed at
the highest level, covering human rights impacts
and issues, and ensure it is communicated to all
appropriate parties, including its own suppliers.
0.A.2 Businesses should have a designated person
responsible for implementing standards concerning
Human rights
0.A.3 Businesses shall identify their stakeholders and
salient issues.
0.A.4 Businesses shall measure their direct, indirect,
and potential impacts on stakeholders (rights
holders) human rights.
0.A.5 Where businesses have an adverse impact on
human rights within any of their stakeholders, they
shall address these issues and enable effective
remediation.
0.A.6 Businesses shall have a transparent system in
place for confidentially reporting, and dealing with
human rights impacts without fear of reprisals
towards the reporter.

0.B. Management Systems & Code Implementation 0.B. Management Systems & Code Implementation

0.1 Suppliers are expected to implement and


maintain systems for delivering compliance to this
Code.

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0.2 Suppliers shall appoint a senior member of


management who shall be responsible for
compliance with the Code.
0.3 Suppliers are expected to communicate this
Code to all employees.
0.4 Suppliers should communicate this code to their
own suppliers and, where reasonably practicable,
extend the principles of this Ethical Code through
their supply chain.

ETI 1. Forced Labour ETI 1. Forced Labour

1.1 There is no forced, bonded or involuntary prison


labour.
1.2 Workers are not required to lodge “deposits” or
their identity papers with their employer and are
free to leave their employer after reasonable
notice.

ETI 2. Freedom of association and the right to ETI 2. Freedom of association and the right to
collective bargaining are respected collective bargaining are respected

2.1 Workers, without distinction, have the right to


join or form trade unions of their own choosing and
to bargain collectively.
2.2 The employer adopts an open attitude towards
the activities of trade unions and their
organisational activities.
2.3 Workers’ representatives are not discriminated
against and have access to carry out their
representative functions in the workplace.
2.4 Where the right to freedom of association and
collective bargaining is restricted under law, the
employer facilitates, and does not hinder, the
development of parallel means for independent
and free association and bargaining.

ETI 3. Working conditions are safe and hygienic ETI 3. Working conditions are safe and hygienic

3.1 A safe and hygienic working environment shall


be provided, bearing in mind the prevailing
knowledge of the industry and of any specific
hazards. Adequate steps shall be taken to prevent
accidents and injury to health arising out of,
associated with, or occurring in the course of work,
by minimising, so far as is reasonably practicable,
the causes of hazards inherent in the working
environment.
3.2 Workers shall receive regular and recorded
Health & Safety training, and such training shall be
repeated for new or reassigned workers.
3.3 Access to clean toilet facilities and to potable
water, and, if appropriate, sanitary facilities for
food storage shall be provided.

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3.4 Accommodation, where provided, shall be


clean, safe, and meet the basic needs of the
workers.
3.5 The company observing the code shall assign
responsibility for Health & Safety to a senior
management representative.

ETI 4. Child labour shall not be used ETI 4. Child labour shall not be used

4.1 There shall be no new recruitment of child


labour.
4.2 Companies shall develop or participate in and
contribute to policies and programmes which
provide for the transition of any child found to be
performing child labour to enable her or him to
attend and remain in quality education until no
longer a child.
4.3 Children and young persons under 18 shall not
be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to
the provisions of the relevant ILO Standards.

ETI 5. Living wages are paid ETI 5. Living wages are paid

5.1 Wages and benefits paid for a standard


working week meet, at a minimum, national legal
standards or industry benchmark standards,
whichever is higher. In any event wages should
always be enough to meet basic needs and to
provide some discretionary income.
5.2 All workers shall be provided with written and
understandable information about their
employment conditions in respect to wages before
they enter employment and about the particulars
of their wages for the pay period concerned each
time that they are paid.
5.3 Deductions from wages as a disciplinary
measure shall not be permitted nor shall any
deductions from wages not provided for by
national law be permitted without the expressed
permission of the worker concerned. All disciplinary
measures should be recorded.

ETI 6. Working Hours are not excessive ETI 6. Working Hours are not excessive

6.1 Working hours must comply with national laws,


collective agreements, and the provisions of 6.2 to
6.6 below, whichever affords the greater
protection for workers. Sub–clauses 6.2 to 6.6 are
based on international labour standards.

6.2 Working hours, excluding overtime, shall be


defined by contract, and shall not exceed 48 hours
per week.

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6.3 All overtime shall be voluntary. Overtime shall


be used responsibly, taking into account all the
following: the extent, frequency and hours worked
by individual workers and the workforce as a
whole. It shall not be used to replace regular
employment. Overtime shall always be
compensated at a premium rate, which is
recommended to be not less than 125% of the
regular rate of pay.

6.4 The total hours worked in any 7 day period shall


not exceed 60 hours, except where covered by
clause 6.5 below.

6.5 Working hours may exceed 60 hours in any 7


day period only in exceptional circumstances
where all of the following are met:
– this is allowed by national law;
– this is allowed by a collective agreement
freely negotiated with a workers’
organisation representing a significant
portion of the workforce;
– appropriate safeguards are taken to
protect the workers’ health and safety; and
– The employer can demonstrate that
exceptional circumstances apply such as
unexpected production peaks, accidents
or emergencies.

6.6 Workers shall be provided with at least one day


off in every 7 day period or, where allowed by
national law, 2 days off in every 14 day period.

ETI 7. No discrimination is practised ETI 7. No discrimination is practised

7.1 There is no discrimination in hiring,


compensation, access to training, promotion,
termination or retirement based on race, caste,
national origin, religion, age, disability, gender,
marital status, sexual orientation, union
membership or political affiliation.

ETI 8. Regular employment is provided ETI 8. Regular employment is provided

8.1 To every extent possible work performed must


be on the basis of recognised employment
relationship established through national law and
practice.
8.2 Obligations to employees under labour or social
security laws and regulations arising from the
regular employment relationship shall not be
avoided through the use of labour–only
contracting, sub–contracting, or home–working
arrangements, or through apprenticeship schemes
where there is no real intent to impart skills or

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provide regular employment, nor shall any such


obligations be avoided through the excessive use
of fixed–term contracts of employment.

Additional Elements: Responsible Recruitment


8.3 Suppliers have full understanding of the entire
recruitment process and assess all labour recruiters
and intermediaries against legal and/or ethical
requirements.
8.4 There are effective management systems in
place to identify and monitor the hiring and
management of all migrant workers, contract
workers, agency workers, temporary or casual
labour The supplier shall implement processes to
enable adequate control over agencies with
regards the above points and related legislation.
8.5 Employment agencies must only supply workers
registered with them.
8.6 Workers pay no recruitment fee at any stage of
the recruitment process.
8.7 Worker contracts accurately reflect the agreed
payment and terms in the recruitment process and
are understood and signed by workers.

8A: Sub–Contracting and Homeworking 8A: Sub–Contracting and Homeworking

8A.1 There should be no sub–contracting unless


previously agreed with the main client.
8A.2 Systems and processes should be in place to
manage sub–contracting, homeworking and
external processing.

ETI 9. No harsh or inhumane treatment is allowed ETI 9. No harsh or inhumane treatment is allowed

9.1 Physical abuse or discipline, the threat of


physical abuse, sexual or other harassment and
verbal abuse or other forms of intimidation shall be
prohibited.
Additional elements:
9.2 companies should provide access to a
confidential grievance mechanism for all workers

10. Other Issue areas: 10A: Entitlement to Work and


Immigration

Additional Elements
10A.1 Only workers with a legal right to work shall
be employed or used by the supplier.
10A.2 All workers, including employment agency
staff, must be validated by the supplier for their
legal right to work by reviewing original
documentation.

10. Other issue areas 10B2: Environment 2–Pillar

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10B2.1 Suppliers must comply with the requirements


of local and international laws and regulations
including having necessary permits.
10B2.2 The supplier should be aware of and comply
with their end clients’ environmental requirements.
Note for auditors and readers, This is not a full
environmental assessment but a check on basic
systems and management approach.

SMETA Extra Sections for 4 Pillar Audit: SMETA Extra Sections for 4 Pillar Audit:

Environment Section Environment Section

B.4. Compliance Requirements


10B4.1 Businesses as a minimum must meet the
requirements of local and national laws related to
environmental standards.
10B4.2 Where it is a legal requirement, businesses
must be able to demonstrate that they have the
relevant valid permits including for use and disposal
of resources e.g. water, waste etc.
10B4.3 Businesses shall be aware of their end
client’s environmental standards/code
requirements
10B4.4 Suppliers should have an environmental
policy, covering their environmental impact, which
is communicated to all appropriate parties,
including its own suppliers.
10B4.5 Suppliers shall be aware of the significant
environmental impact of their site and its
processes.
10B4.6 The site should measure its impacts,
including continuous recording and regular reviews
of use and discharge of natural resources e.g.
energy use, water use (see 4–pillar audit report and
audit checks for details).
10B4.7 Businesses shall make continuous
improvements in their environmental performance.
10B4.8 Businesses shall have available for review
any environmental certifications or any
environmental management systems
documentation
10B4.9 Businesses should have a nominated
individual responsible for co–ordinating the site’s
efforts to improve environmental performance.
B4. Guidance for Observations
10B4.10 Suppliers should have completed the
appropriate section of the SAQ and made it
available to the auditor.
10B4.11 Has the site recently been subject to (or
pending) any fines/prosecutions for
noncompliance to environmental regulations.

Business Practices Section

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10C. Compliance Requirements


10C.1 Businesses shall conduct their business
ethically without bribery, corruption, or any type of
fraudulent Business Practice.
10C.2 Businesses as a minimum must meet the
requirements of local and national laws related to
bribery, corruption, or any type of fraudulent
Business Practices.
10C.3 Where it is a legal requirement,
businesses must be able to demonstrate
that they comply with all fiscal legislative
requirements.
10C.4 Businesses shall have access to a transparent
system in place for confidentially reporting, and
dealing with unethical Business Ethics without fear
of reprisals towards the reporter.
10C.5 Businesses should have a Business Ethics
policy, covering bribery, corruption, or any type of
fraudulent Business Practice,
10C.6 Businesses should have a designated person
responsible for implementing standards concerning
Business Ethics
10C.7 Suppliers should ensure that the staff whose
job roles carry a higher level of risk in the area of
ethical Business Practice e.g. sales, purchasing,
logistics are trained on what action to take in the
event of an issue arising in their area.

10C. Guidance for Observations

10C.8 Businesses should communicate their Business


Ethics policy, covering bribery, corruption, or any
type of fraudulent Business Practice to all
appropriate parties, including its own suppliers.
10C.9 Has the site recently been subject to (or
pending) any fines/prosecutions for non-
compliance to Business Ethics regulations. If so is
there evidence that sustainable corrective actions
have been implemented.

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Photo Form
Adding Images To help keep the size of the Report as small as possible for ease of sending
and saving the document we recommend that you use Microsoft Paint to resize your photos. To
do so please follow these instructions:
1) To start Microsoft Paint, click 'Start', 'Programs', 'Accessories', then 'Paint'.
2) Open the image file you wish to edit.
3) Click the 'Image' Menu at the top and select "Stretch/Skew Image”.
4) Choose a percentage figure to resize the image: to avoid distortion, choose the same
percentage for horizontal and vertical stretch. Click OK.
5) Once you have the desired size, click File > Save As… (To prevent overwriting the original
image).
Save As jpeg (this provides compression to make the file smaller).
6) Please delete this text once complete.

Administrative offices Guard room Attendance control system

Emergency phone numbers Exterior view Exterior view

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Bathrooms Lookers Dining room

Dining room Complaint & suggestion box Corporative Code of Conduct

PPE use advertising Evacuation map Emergency roles

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Truck loading area LPG tank dully closed and Emergency exit door and
signalled emergency light

PPE use advertising Emergency stop button Fire emergency switch and alarm

K type fire extinguisher Risk advertising signal Risk advertising signal

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Environmental Management Environmental aspect & impact Natural resources control


Manual Matrix

PPE provision record Policy of Hygiene, Safety and Identification of hazard and risk
Laboral Risk Prevention evaluation matrix

Training schedule (2018) Training record (evacuation plan) Accident investigation record

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FE identification record Los statistics Accidents record

Commercial authorization Reports of environmental Safety meeting point


condition measurements

Sub-standard electric connection Sub-standard electric connection LPG cylinders not subjected

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Compressed gas cylinder not Manometer in bad condition First aid kit with expired supplies
subjected

Expired supplies No risk signalling (electric shock) No risk signalling (combustible)

External worker over 2 meters and External worker over 2 meters and No skirting board on platform.
not anchored not anchored (on the truck
cargo area)

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 94
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

Not safety back light. Not safety back light. Open electric panel

Hazardous residues disposed in Non-hazardous residues stored in Container with used lubricating
container for non-hazardous container for hazardous oil without secondary container

Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 95
Sedex Audit Reference: 2018ARZAA405653761 Sedex Members Ethical Trade Audit Report Version 6.0

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Audit company: SGS Argentina S.A. Report reference: AR/BUE2012650 Date: 5-7/DEC/2018 96

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