QIMA Sample SMETA 4 Pillar Report

Audit Details
Sedex Company ZC: Anonymous Sedex Site Reference: ZS: Anonymous

Reference: (only available on Sedex
(only available on Sedex System)
System)
Business name (Company Anonymous

name):
Site name: Anonymous
Site address: Anonymous Country: Anonymous
(Please include full address)
Site contact and job title: Mr. X/Administration Manager

Site phone: Anonymous Site e–mail: Anonymous
SMETA Audit Type: Labour Health & Environment Business Ethics
Standards Safety
Date of Audit: XX-May-20XX
Audit Company Name &

Logo: QIMA Limited
Report Owner (payee): Shanghai Everise Tools
Industrial Co., Ltd.
Audit Conducted By
Commercial Purchaser
Retailer
Brand owner NGO Trade Union
Multi– Combined Audit (select all that apply)

stakeholder
Audit company: QIMA Report reference: R-Cloud-XXXXXXX Date: XX-May-20XX 2

SMETA Declaration
I declare that the audit underpinning the following report was conducted in accordance
with SMETA Best Practice Guidance and SMETA Measurement Criteria.
(1) Where appropriate non-compliances were raised against the ETI code / SMETA Additions & local law
and recorded as non-compliances on both the audit report, CAPR and on Sedex.
(2) Any Non-Compliance against customer code alone shall not be uploaded to Sedex. However, in
the CAPR these ‘Variances in compliance between ETI code / SMETA Additions/ local law and
customer code’ shall be noted in the observations section of the CAPR.
Any exceptions to this must be recorded here (e.g. different sample size):
Auditor Team (s) (please list all including all interviewers):

Lead auditor: Steven Wong
Team auditor: Steven Wong
Interviewers: Steven Wong
Report writer: Steven Wong

Report reviewer: Karmela Malinao
Date of declaration: XX-May-20XX

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: QIMA Report reference:R-Cloud-XXXXXXX Date:XX-May-20XX 4

Non–Compliance Table
Area of Non–Conformity NC Findings Only
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 NC’s only)
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 0 0 None observed
0B Management systems and 0 1 0 Obs:

code implementation -No effective procedure to ensure confidential
information was kept confidential.
1. Freely chosen Employment 0 0 0 None observed
2 Freedom of Association 0 0 0 None observed
3 Safety and Hygienic Conditions 3 0 0 NC:

-No MSDS posted at chemical used or stored
areas
-No inspection records of pressure vessel
-Plastic smashing workers did not wear earplugs
4 Child Labour 0 0 0 None observed
5 Living Wages and Benefits 0 0 0 None observed
6 Working Hours 0 0 0 None observed
7 Discrimination 0 0 0 None observed

8 Regular Employment 0 0 0 None observed
8A Sub–Contracting and 0 0 0 None observed

Homeworking
9 Harsh or Inhumane Treatment 0 0 0 None observed
10A Entitlement to Work 0 0 0 None observed
10B4 Environment 4–Pillar 2 1 0 NC:

- Untrained environment specialist in the facility
- No environmental legal register in place and
no cycle/ways to update the environmental
legal
Obs:
-No SAQ was provided for review during audit.
10C Business Ethics 1 0 0 NC:

-No signed non-disclosure agreement for
employees and no training about intellectual
property and business information loss or
unauthorized disclosure.
General observations and summary of the site:
1. The products manufactured in the facility were hardware & power tools, plastic packaging products.
2. Overall responsibility for meeting the standards was taken by Mr. X / Vice General Manager.
3. There were a total of 98 employees on site (96 were migrant employees and 2 local employees, all are permanent). Migrant employees are mainly from
XXX and etc.
4. The youngest worker on site was 18 years old.
5. There is no union at this facility. Employee committee presented during the audit, attend the opening meeting, close meeting and interview.
6. There was evidence of both male and female in management and among supervisor. The distribution was Male 70%, Female 30%.
7. The peak month in the facility was from XXX to XXX.
8. No sub-contractor was used by the facility.

9. 26 employees were randomly selected for interview including 12 males and 14 females, they were interviewed as 4 group of 5 employees and 6
employees were interviewed individually.
10. Twelve months’ payroll records from April 20XX to March 20XX and attendance records from XX-April-20XX up to audit day were provided for review
during this audit. 26 employees’ attendance and payroll records were randomly selected from July and November 20XX, and March 20XX
11. Based on the provided attendance records, standard working hours in this facility were 8 hours per day, 40 hours per week with at least 1 day off in one
week.
12. Based on the provided attendance records and payrolls, all employees were paid by hourly rate, and overtime working was paid correctly, 150%, 200%
of normal rate was paid for employees overtime work in normal day and rest day respectively, no overtime work in national holiday for all employees.
13. Based on the social insurance receipt provided by the facility, there were 98 employees in the facility in May 20XX, except 8 employees who hired in May
2018, the rest 90 employees had participated in basic endowment insurance, basic medical insurance, maternity insurance, unemployment insurance
and employment injury insurance.
14. Based on the provided attendance records, the status of overtime hours in sample was as below:
64-66 hours /month in March 20XX (current month)
48-60 hours /month in November 20XX(Peak month)
36 hours /month in July 20XX (random month)
The factory obtained the comprehensive calculating working hours permit form local government and the annual total working hours met the
requirement of the permit.
Issues Found:
NC’s:
3 Safety and Hygienic Conditions
1. No MSDS was posted at where chemical used or stored.
2. No inspection records of pressure vessel were provided for review during audit.
3. Plastic smashing workers wore masks, but did not wear earplugs.
10B.4 Environment 4–Pillar

1. It was noted that the environment specialist in the facility had not been trained or qualified.
2. It was noted that no environmental legal register in place and regularly updated, also no cycle, ways to update the environmental legal.
10C Business Ethics

1. The facility had established Intellectual Property Management Procedure, but the facility did not sign any non-disclosure agreement (separate or part of
employment contract) for employees and employee, furthermore, the training about intellectual property and business information loss or unauthorized
disclosure had not been arranged before.

Observation:
0B Management systems and code implementation
1. No evidence showed that there was an effective procedure to ensure confidential information was kept confidential.
10B.4 Environment 4–Pillar
1. No evidence showed the facility had completed the appropriate section of the SAQ, no SAQ was provided for review during audit.
Good Example:
None observed
*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.

Site Details
Site Details
A: Company Name: Anonymous
B: Site name: Anonymous
C: Applicable business and other Business License Number: XXXXXXXXXXXXXX

legally required licence numbers and Valid date from XX-June-XXXX to XX-June-20XX
documents
for example, business license no, liability
insurance, any other required
government inspections
D: Products/Activities at site, for Hardware & power tools, plastic packaging products
example, garment manufacture,
electricals, toys, grower
E: Site description: Company X is located at ABC Country.

(Include size, location, and age of site.
Also, include structure and number of The total land area occupied by the facility is 14,539 square
buildings) meters. They had been in operation at the existing location
since June XXXX.
In view of the facilities, the facility consisted of three 1-storey

buildings used as production floor and warehouse, one 3-storey
building used as office, one 3-storey building used as canteen
and dormitory.
For building details, please refer to below tables:
Warehouse Description Remark, if any

Building no
Raw material and
Year of
Floor 1 accessories
establishment:2005
warehouse
Is this a shared
No Nil
building?
Production Description Remark, if any

Building no
Assembly and
Year of
Floor 1 packaging
establishment:2002
workshop
Is this a shared
No Nil
building?

Office Description Remark, if any
Building no
Year of
Floor 1 Office
establishment:20XX
Year of
Floor 2 Office
establishment:20XX
Year of
Floor 3 Office
establishment:20XX
Is this a shared
No Nil
building?
Production Description Remark, if any

Building no
Injection
moulding
Year of
Floor 1 workshop and
establishment:20XX
finished products
warehouse
Is this a shared
No Nil
building?
Dormitory Description Remark, if any

Building no
Year of
Floor 1 Canteen
establishment:20XX
Year of
Floor 2 Dormitory
establishment:20XX
Year of
Floor 3 Dormitory
establishment:20XX
Is this a shared
No Nil
building?
A total of 98 employees are currently working in the facility,

including 70 production employees and 28 non-production
employees. There were 2 local employees in the facility.
Migrant employees mostly came from other provinces in ABC.
The employees worked for 5 days a week in one shift. The
normal working hour was from 08:00 to 17:00 with 1 hour’ lunch
break from 12:00 to 13:00. Electronic attendance system was
used for time keeping. Employees’ wages were calculated on
hourly-rated basis and paid monthly.
Visible structural integrity issues (large cracks) observed and

without structural engineer evaluation
Yes
No
Details: N/A

F: Site function: Agent
Factory Processing/Manufacturer
Finished Product Supplier
Grower
Home employee
Labour Provider
Pack House
Primary Producer
Service Provider
Sub–Contractor
G: Month(s) of peak season: From Month X to Month Y

(if applicable)
H: Process overview: The main products manufactured by the facility are Hardware
(Include products being produced, main & power tools, plastic packaging products. The main
operations, number of production lines, production processes are listed as follows: Injection moulding,
main equipment used) assembly, inspection and packing.
The main machineries of the facility include: 24 injection

moulding machines, 27 drying machines, 8 plastic smashing
machines, 6 plastic mixing machines, 7 air compressors, 8 blister
packing machines, 2 punching machines, 4 production lines
and etc.
I: What form of worker representation / Union (name)

union is there on site? Worker Committee
Other (specify)
None
J: Is there any night production work at Yes

the site? No
K: Are there any on site provided Yes

worker accommodation buildings e.g. No
dormitories If yes approx. 30% of workers in on site accommodation
L: Are there any off site provided worker Yes

accommodation buildings No
If Yes approx. % of workers
M: Were the site provided Yes

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

Audit Parameters
A: Time in and time out Day 1 Time in: Day 2 Time in: Day 3 Time in:
9:30 8:45 N/A
Day 1 Time out: Day 2 Time out: Day 3 Time out:
17:00 15:30 N/A
B: Number of Auditor Days Used: 2 days *1 auditor = 2 man-days
C: Audit type: Full Initial

Periodic
Full Follow–up
Partial Follow–Up
Partial Other – 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
Remarks: No SAQ was provided for review during audit.
F: Any conflicting information Yes

SAQ/Pre-Audit Info to Audit findings? No
If Yes, please capture detail in appropriate audit by clause
Remarks: N/A, no SAQ was provided for review during audit.
G: Who signed and agreed CAPR Mr. X/Administration Manager

(Name and job title)
H: Is further information available Yes

(if Y please contact audit company for No
details)
I: Previous audit date: XX-May-20XX
J: Previous audit type: Full initial
K: Was any previous audit reviewed Yes No

during this audit
N/A
Audit attendance Management Worker Representatives
Senior Worker Committee Union representatives

management representatives
A: Present at the opening meeting? Yes No Yes No Yes No
B: Present at the audit? Yes No Yes No Yes No

C: Present at the closing meeting? Yes No Yes No Yes No
D: If Worker Representatives were not N/A

present please explain reasons why
(only complete if no worker reps present)
E: If Union Representatives were not There was no union in the facility.

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

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 –
2 0 0 42 0 0 0 44
Male
Worker numbers –
0 0 0 54 0 0 0 54
female
Total 2 0 0 96 0 0 0 98
Number of Workers
0 0 0 12 0 0 0 12
interviewed – male
Number of Workers
interviewed – 0 0 0 14 0 0 0 14
female
Total – interviewed
0 0 0 26 0 0 0 26
sample size
A: Nationality of Management Anonymous
B: Majority nationality of workers Main countries:

Country 1: _ABC_ approx % total workforce___100%_____
Country 2: __N/A_ approx % total workforce__ N/A_____
Country 3: __N/A__ approx % total workforce__ N/A_____
C: Worker remuneration (management ___0____% employees on piece rate

information) __100____% hourly paid employees
___0____% salaried employees
Payment cycle:
___0____% daily paid
___0___% weekly paid
__100__% monthly paid
___0____% other – please give details

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, comprised of 12 female

(Please specify number and size of groups. Please see SMETA Best employee and 8 male employees in total.
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: 4 Female: 2

(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 N, 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? None
I: What did the workers like the most about working at this Wages were always paid on time and good
site? working environment
J: Any additional comment(s) regarding interviews: None
K: Attitude of workers to hours worked: Positive
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
6 employees were selected for individual interview and total of 20 employees divided into 4 groups were
selected for group interview. All the interviewed employees were favourable with the management and

facility environment. There was no negative information raised.
The employees were assured of confidentiality and they spoke freely of their views of the facility. All
employees said they were satisfied with their employment at the facility.
All employees said they were satisfied with their employment at the facility and the current wages which in
their view were in line with wages in the locality. They felt free to leave this employer and understood the
notice period required. They had good relationships with their supervisors and managers who treated them
with respect.
They were able to make suggestions to their supervisors and team leaders and sometimes they had seen
these suggestions used. They felt able to complain directly to their supervisors but also felt free to give their
general concerns to their employee committee representative who would take it to the employee
management committee.
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
One employee committee representative attended the opening, close meeting and interview. During the
whole audit, the representative was positive to cooperation with audit. All non-compliance and observation
findings were accepted by her without negative comment.
O: Attitude of managers:
(Include attitude to audit, and audit process. Both positive and negative information should be included)
The facility management showed a positive attitude to this audit during the whole process. Locked areas
encountered during the audit were unlocked timely. All documents were provided for review timely. At the
end of the audit, all findings and suggested corrective actions were accepted by the facility management
and no negative information was raised from managers.

Audit Results by Clause
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:
1. This facility had established relevant policy and endorsed at the highest level to cover the human rights
impacts and issues, and such policy had been communicated to all appropriate parties, including its
own suppliers.
2. The facility had a designated responsible person- Mr. X / Vice General Manager to responsible for
implementing standards concerning Human rights.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Details:
1. Policy regarding human rights issues provided for review;
2. Appointment letters to enhance the implement of human right issues;
3. Training records provided for employees regarding communications and acknowledgement;
4. Internal audit documents;
5. Written social compliance commitments from Suppliers and social compliance assessment reports for its
suppliers;
6. Management interview and employee interview.
Any other comments:

Nil

A: Policy statement that expresses commitment to Yes
respect human rights? No
Please give details: The policy expressed that human
rights would be respected by the facility.
B: Does the business have a designated person Yes

responsible for implementing standards No
concerning Human Rights?
Please give details: Any issue concerning human rights
could be raised to the designated responsible person.
Name: Mr. X
Job title: Vice General Manager
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: The reporter’s personal information
towards the reporter? would not be revealed, and the reporting practice
would never effect the working arrangement or
promotion/position.
D: Does the business demonstrate effective data Yes

privacy procedures for workers’ information, No
which is implemented?
Please give details: Relevant training regarding privacy
procedures would be provided to employees when
they joined the facility.
Findings
Finding: Observation Company NC Objective evidence

Description of observation: observed:
None observed. Not applicable
Local law or ETI/Additional elements / customer specific requirement:
Not applicable
Comments:
Not applicable
Good examples observed:
Description of Good Example (GE): Objective Evidence

None observed Observed:
Not applicable

Measuring Workplace Impact
Workplace Impact
A: Annual worker turnover: Last year: This year

Number of workers leaving in last 12 months as a % __5___ % __2___ %
of average total number of workers on site over the
year (annual worker turnover)
B: Current % quarterly (90 days) turnover: 2%

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 ___2__ % __2___ %
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: 2%

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: Based on the reviewed accident records, no
accident happened in the last 12 months.
F: Annual Number of work related Last year: 0 This year: 0

accidents and injuries per 100 workers: Number: 0 Number: 0
[Number of work related accidents and injuries *
100) / Number of total workers]
G: Quarterly (90 days) number of work 0 0

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: 0 This year: 0
[(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 ____0___% workers ____0____% workers
the last 6 / 12 months:
J: % of workers that work on average 6 months 12 months

more than 60 total hours / week in the ___0____% workers ____0____% workers
last 6 / 12 months:

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.

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:
1. The facility implemented and maintained systems for delivering compliance to this Code.
2. Overall responsibility for meeting the standards was taken by Mr. X/Vice General Manager.
3. There was an internal audit team for internal audit of the social standards of the facility and they
reported to the General Manager their findings.
4. Implementation of any necessary changes was given to the individual department heads after
agreement with the Vice General Manager.
5. The facility communicated this Code to all employees by regular trainings.
6. The facility communicated the code to their suppliers by providing copy of CSR manual and asking
suppliers to sign the written social compliance commitments; and the facility also conducted social
compliance assessments for its suppliers annually.
Details:
1. A CSR manual created by the facility which contained all required documents and all appropriate
procedures for meeting the client’s code of conduct and the legal requirements.
2. Appointment papers for compliance responsible persons
3. Internal audit documents (e.g. annual audit reports) from the internal audit team
4. Client’s code of conduct at the facility (posted in Chinese in the workshops)
5. Training records for employees
6. Written social compliance commitments from Suppliers and social compliance assessment reports for
its suppliers
7. Management interview and employee interview
Any other comments:

Nil

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 describe: N/A, no any fine/prosecution in
past year.
B: Do policies and/or procedures exist that reduce the Yes

risk of forced labour, child labour, discrimination, No
harassment & abuse? Please describe: The facility had established the
policies and procedures for forced labour, child
labour and discrimination, harassment and
abuse.
C: If Yes, is there evidence (an indication) of effective The facility had provided relevant trainings for
implementation? Please give details. employees.
D: Have managers and workers received training in Yes

the standards for forced labour, child labour, No
discrimination, harassment & abuse? Please describe: The facility provided regular
trainings in the standards for forced labour, child
labour, discrimination, harassment and abuse for
both management and employees.
E: If Yes, is there evidence (an indication) that training Yes

has been effective e.g. training records etc.? Please No
give details Please describe: Regular training records were
provided for review, the latest training was held
in January 20XX. The employees were aware
clearly of the facility’s relevant policies and
procedures according to the interviews.
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 describe: The factory obtained ISO 9001:
Please detail (Number and date). 2015 certificate.
G: Is there a Human Resources manager/department? Yes

If Yes, please detail. No
Please describe: The facility had Human
Resources department in charge of the
recruitment of employees, assignment of
employees’ post, etc. HR Manager Mr. Zhuang
Huifeng was present in the audit.
H: Is there a senior person /manager responsible for Yes

implementation of the Code No
Please describe: Mr. X /Vice General Manager
was assigned as responsible for implementation
of the Code.
I: Is there a policy to ensure all worker information is Yes

confidential No
Please describe: The facility had established a
policy to ensure all workers information was

confidential.
J: Is there an effective procedure to ensure Yes

confidential information is kept confidential No
Please describe: No evidence showed that there
was an effective procedure to ensure
confidential information was kept confidential.
K: Are risk assessments conducted to evaluate policy Yes

and procedure effectiveness? No
Details: Risk assessment would be conducted
regularly to evaluate policy and procedure
effectiveness.
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? Details: Any risk identified during assessment
would be corrected immediately.
M: Does the facility have a policy/code which require Yes

labour standards of its own suppliers? No
Details: The facility had its supplier filter program
to ensure all suppliers in compliance with legal
requirements regarding labour standards.
Land rights
N: Does the site have all required land rights licenses Yes
and permissions (see SMETA Measurement Criteria)? No
Details: the facility had provided property
ownership certificate for all occupied buildings
for review.
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 Details: NA, no such national law requirements.
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: NA
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 the Yes

owner/lessor for the land prior to the facility being built No
or expanded. Details: NA, not applicable for this facility.
Please give details.
Yes
R. Does the Facility demonstrate that alternatives to a No
specific land acquisition were considered to avoid or Details: NA, not applicable for this facility.
minimize adverse impacts
Please give details.

S: Is There any evidence of illegal appropriation of land Yes
for facility building or expansion of footprint. No
Details: NA, not applicable for this facility.
Non–compliance:
1. Description of non–compliance: Objective evidence

NC against ETI/Additional Elements NC against Local Law observed:
NC against customer code: (where relevant please add
None observed. photo numbers)
Not applicable
Local law and/or ETI requirement:

Not applicable
Recommended corrective action:

Not applicable
Observation:
1. Description of observation: Objective evidence

No evidence showed that there was an effective procedure to ensure observed:
confidential information was kept confidential. Not applicable
Local law or ETI requirement:

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:
Factory should establish a transparent system for confidential reporting and
ensure that confidential information are kept confidential.
Good Examples observed:
Description of Good Example (GE): Objective evidence

None observed observed:
Not applicable

1: Employment is Freely Chosen
1: Freely Chosen Employment
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.

procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any
Current systems:
1. The facility had a written policy of prohibiting forced, bonded and prison labor. The policy stated that
the facility did not require deposit or withhold employees’ ID cards. The facility did not limit the
employees’ freedom and prohibited forced, bonded or involuntary prison labour. Employees were free
to leave their employer after reasonable notice, etc.
2. There was a written recruitment procedure which states that employees must present their ID cards for
proof of age but only copies must be kept in the personnel files and the original ID cards would be
given back to the employees.
3. The employee handbook – given to all employees on joining, states that employees were free to leave
with 3 days’ prior written notice within their probation period and could resign with one month’s prior
written notice after the probation period; the employees would be given their full wages on their last
day of work; the employees were free to leave the workplace outside of their working hours; the
overtime was voluntary, etc.
4. Security guards stated that their main responsibility is to only protect the safety of the facility’s
employees and properties, and security guards were not allowed to abuse employees and conduct
body search.
Details:
1. Policy of prohibiting forced, bonded and prison labor
2. Recruitment procedure
3. Employee handbook
4. Personnel files and labor contracts
5. Resignation records
6. Onsite observation, management and employee interview
Any other comments:

Nil

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 employees affected
N/A
B: Is there any evidence of a loan Yes

scheme in operation No
If yes please give details and category of employee affected
N/A
C: Is there any evidence of Yes

retention of wages /deposits No
If yes please give details and category of employee affected
N/A
D: Are there any restrictions on Yes

workers’ freedom to terminate No
employment? Please describe finding:
N/A
E: If any part of the business is UK Yes

based / registered & turnover is No
36m+ there is a requirement to
publish a ‘modern day slavery Please describe finding:
statement. N/A
F: Is there a modern day slavery
statement published Not applicable
G: Is there evidence of any Yes

restrictions on workers’ freedoms to No
leave the site at the end of the Please describe finding: N/A
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 employees affected:
N/A
Not applicable
I: Is the site taking any steps taking Yes

to reduce the risk of forced / No
trafficked labour?
Please describe finding: N/A

Non–compliance:

NC against ETI NC against Local Law: NC against customer observed:
code: (where relevant please
None observed add photo numbers)
Not applicable
Local law and/or ETI requirement

Not applicable

Not applicable
Observation:
Description of observation: Objective evidence

Not applicable

Not applicable
Comments:
Not applicable

Not applicable

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 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:
1. There was no union representative in the facility.
2. The facility appointed a qualified person to be responsible for communicating, deploying and
monitoring the freedom of association practices as prescribed by labour law.
3. Employees could freely communicate issues related to working condition, wage & benefits, and
Freedom of Association etc. to managements directly, through regularly meeting with top management
or posting their documented issues into suggestion box etc.
4. Through employees’ interview, all the employees confirmed that the facility did not interfere with them
to join the union or other organisational activities.
Details:
1. Minutes of the works committee meeting
2. Site policy on freedom of association
3. Interview with employees
4. Interview with employees committee members
5. Interview with managers
Any other comments:

Nil
A: What form of worker Union (name)

representation/union is there on site? Employee Committee
Other (specify)
None
B: Is it a legal requirement to have a Yes

union? No

C: Is it a legal requirement to have a Yes
worker’s committee? No
D: Is there any other form of Yes

effective worker/management No
communication channel? (Other Describe: Suggestion box and hotline
than union/worker committee) e.g.
H&S, sexual harassment 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: The Employee Committee could conduct free deployment
related business? without interference or restriction.
F: Name of union and union N/A. There was no Is there evidence of free elections?
representative, if applicable: union in the facility. Yes No N/A
G: If no union what is parallel means Employee committee Is there evidence of free elections?
of consultation with workers e.g. Yes No N/A
worker committees?
H: Are all workers aware of who their Yes No Through interview, the employees knew
representatives are? the representative of each workshop.
I: Were worker representatives freely Yes No Date of last election: XX-March-20XX

elected?
J: Do workers know what topics can Yes No The production employees could raise
be raised with their representatives? any topic related their working conditions
with their representatives.
K: Were worker Yes No

representatives/union If Yes, please state how many: 1
representatives interviewed
L: State any evidence that Yes No

union/worker’s committee is During document review, such as meeting records, there was some
effective? requirement from employees and there were resolving methods and
Specify date of last meeting; topics schedule. In addition, during relevant employee interview, they
covered; how minutes were claimed that the facility would consider employees’ requirement
communicated etc. and do proper action.
Last meeting was held on XX-March-20XX topic was regular meeting
between management and worker representatives. Based on
management and workers representative interview, minutes would
be posted at notice board.
M: Are any workers covered by Yes No

Collective Bargaining Agreement N/A. There was no CBA.
(CBA)

N: If Yes what percentage by trade __N/A__% employees covered by __N/A__% employees covered
Union/worker representation Union CBA by employee rep CBA
O: If Yes, does the Collective Yes

Bargaining Agreement (CBA) No
include rates of pay N/A No
Non–compliance:

NC against ETI NC against Local Law NC against customer observed:
code: (where relevant please add
None observed photo numbers)
Not applicable
Not applicable

Not applicable
Observation:

Not applicable
Not applicable
Comments:
Not applicable

Not applicable

3: Working Conditions are Safe and Hygienic
3: Working Conditions are Safe and Hygienic
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:
1. General Health and Safety management
-Mr. X /Vice General Manager is appointed as Health & Safety Manager for the site.
-Potable water was freely available in all areas.
-Sufficient clean toilets segregated by gender were available at all times to employees
-Ventilation, temperature and lighting were adequate for the production processes.
-Minutes of meetings show that there were monthly meetings between the H&S committee (employees)
and the H&S manager, and each point was acted on.
2. Fire Safety
-There were at least 2 exits from each work area and these were clearly marked.
-Sufficient fire extinguishers and fire hydrants were installed.
-Fire alarms were installed in each workshop and warehouse.
-Smoke detectors and explosion-proof light were installed in warehouse.
-Evacuation diagrams were posted in all areas and understood by all employees interviewed
-Fire drills were organized and recorded every 6 months.
-Safety exit sign and emergency light was installed above safety exits in the facility.
3. Electrical safety
-All electrical equipment was maintained in good condition such as sockets, plugs, switches and main fuse
boards.
-There were competent electricians at the site and their training certificates were available for review.
4. Chemical safety
-Release agent and lubricant oil were used in the factory, chemicals were stored in chemical warehouse
with secondary containers.
-No MSDS was posted at where chemical used or stored.
-Emergency eyewash equipment was installed in the factory.
5. Machine safety
-All machines were installed with safety guards. Machine safety operation instructions were posted at

production areas, and workers were trained on machine operation.
-Inspection records of special equipment such as forklift and travelling crane, and certificates of special
equipment operators were provided for review during audit.
-No inspection records of pressure vessel were provided for review during audit.
-Plastic smashing workers wore masks, but did not wear earplugs.
6. Medical services
-There were adequate first aid kits in each production area and they were well stocked.
-The factory had 3 trained and qualified first aiders, certificate were available and provided for review.
Details:
1. Health and safety policy
2. Health and safety manual
3. Health and safety committee minutes
4. Training records and certificates
5. Fire equipment maintenance records
6. Fire drill records
7. Building structure safety certificate and fire acceptance report
8. Accident reports
9. Interviews with H&S manager
10. Interviews with employees and H&S committee members
Any other comments:

Nil
Yes
A: Does the facility have general Health No
& Safety and occupational Health & Details: The facility had established general Health & Safety
Safety policies and procedures that are and occupational Health & Safety policies and procedures
fit for purpose and are these and employees would be given relevant training on their entry
communicated to workers? date.
Yes
B: Are the policies included in worker’s No
manual? Details: Employees’ manual including facility’s general Health
& Safety and occupational Health & Safety policies and
procedures and detailed requirements.
Yes
C: Are there any structural additions No
without required permits/inspections Details:
(e.g. floors added)?
Yes
D: Are visitors to the site informed on No
H&S and provided with personal Details: All visitors would be introduced with H&S and provided
protective equipment with personal protective equipment if necessary.
Yes
E: Is a medical room or medical facility No
provided for workers? Details: N/A, there was no medical room or medical facility

provided and no such legal requirements.
If yes, do the room(s) meet legal
requirements and is the size/number of
rooms suitable for the number of
workers.
Yes
F: Is there a doctor or nurse on site or No
there is easy access to first aider/ Details: NA, there was no medical room or medical facility
trained medical aid provided and no such legal requirements.
Yes
G: Where facility provides worker No
transport - it is fit for purpose, safe and Details: No
maintained and operated by
competent persons e.g. buses and
other vehicles
Yes
H: Secure personal storage space is No
provided for workers in their living Details: Secure personal storage space was provided for
space and is fit for purpose employees.
Yes
I: H&S Risk assessments are conducted No
(including evaluating the arrangements Details: Based on facility manual, the overtime working hours
for workers doing overtime e.g. driving were strictly controlled by HR.
after a long shift) and there are controls
to reduce identified risk
Yes
J: Is the site meeting its legal obligations No
on environmental requirements Please describe: The factory had a valid Environmental
including required permits for use and Impact Assessment report, and a valid Approval Report of
disposal of natural resources Environmental Impact Assessment, environmental facilities
inspection and acceptance approval, and valid Water
Discharge Permit.
Yes
K: Is the site meeting its customer No
requirements on environmental Please describe: No such chemical used by this facility.
standards, including the use of banned
chemicals
Non–compliance:

code: 1. On-site observation,
No MSDS was posted at where chemical used or stored. document review
and employees
Local law and/or ETI requirement interview.
In accordance with Regulations on Safety in Workplaces Where Chemicals Are
Used, Article 12, The chemicals used by the employing units shall have the labels,
and the dangerous chemicals should be attached with safety labels. Also, the
safety and technical instructions of the chemicals shall be available for operators
engaged in the use of the chemical.
In accordance with Regulations on Safety in Workplaces Where Chemicals Are
Used, Article 20, The employing unit shall let safety and sanitary documents of

dangerous chemicals known to all employees and educate them to identify the
safety labels, understand the safety and technical instructions, master the
emergency handling and self-first-aid measures. The employing unit shall also
regularly educate and train its employees regarding the safety use of chemicals
at the workplaces.
In accordance with 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.

It is recommended that the facility should post MSDS of all chemicals at where
chemical used or stored
Action By: Mr X/Vice General Manager
Recommended completion timescale: 60 days
Verification method: Desktop
2. Description of non–compliance:
NC against ETI NC against Local Law NC against customer
2. On-site observation,
code:
document review
No inspection records of pressure vessel were provided for review during audit.
and employees
interview.
In accordance with Production Safety Law of the People’s Republic of China,
Article 30, Special equipment that threatens the safety of people's lives and is
potentially more dangerous, as well as containers and transport vehicles for
dangerous articles, to be used by production and business units shall be made
by professional manufacturers in accordance with relevant State regulations,
and they shall only be put to use after they pass the test and check by
professionally qualified testing and checking authorities and safe use certificates
or safety tags are issued. The said authorities shall be responsible for the results of
the test and check.
In accordance with Regulations on Safety Supervision over Special Equipment,

Article 28, An entity using special equipment shall, in accordance with the
requirements of the safety technical code on regular inspection, file the request
for regular inspection with the inspection and testing institution in 1 month prior to
the expiry of the period of validity of the safety inspection.
The inspection and testing institution shall, after receiving the request for regular
inspection, make the inspection in a timely way pursuant to the requirements of
the safety technical code.
The special equipment that hasn’t gone through the regular inspection or that
has failed the inspection may not be used any longer.

It is recommended that the facility should obtain inspection records for all
special equipment.
NC against ETI NC against Local Law NC against customer
code:
Plastic smashing workers wore masks, but did not wear earplugs.
3. On-site observation
Please refer to NC
In accordance with Law of the People’s Republic of China on Prevention and
photo#1
Control of Occupational Diseases，Article 20, The employer shall have effective
facilities for prevention of occupational disease and shall provide individual
workers with article for prevention of occupational diseases. The articles for
prevention of occupational diseases provided by the employer to individual
workers shall meet the requirements for prevention and control of occupational
diseases; otherwise, such articles may not be used.
In accordance with Production Safety Law of the People’s Republic of China,

The production and business operation entities shall provide labor protection
articles that meet the national standards or industrial standards to the employees
thereof, supervise and educate them to wear or use these articles according to
the prescribed rules.

It is recommended that the facility should provide PPE to all employees in need,
supervise and educate them to wear or use PPE during working hours.
Observation:

Not applicable
Not applicable

Not applicable


Not applicable

4: Child Labour Shall Not Be Used
4: Child Labour Shall Not Be Used
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:
1. There was a formal procedure for checking ages of employees at application stage, and this includes
checking IDs and there were formal checks of validity of IDs.
2. Once employees had joined, their original ID’s were copied and given back to them whilst copies only
were kept in their personnel file.
3. Checks of all employees’ files showed that the youngest employee is currently 18 years old.
4. There are a total of 98 employees at the site whose age ranged from 18-53 years.
Details:
1. Employee Handbook showed that no labour under 16 years would be employed by the facility.
2. The employee’s personnel files were provided for review. Each employee file includes a bio-data sheet,
a recent photo and the age documentation, which is in the form of photocopied national identification
card. The card lists the employee’s name, household address and the date of birth.
3. The facility’s policy on child labour was reviewed. It stated that the facility would never employ and use
any child labor under the age of 16 years old.
4. On site observation.
5. Management and employee interview.
Any other comments:

Nil
A: Legal age of employment 16 years old
B: Age of youngest worker found: 18 years old
C: Children present on work floor but not Yes

working at time of audit No
Remarks: N/A. No child labor was found during this audit.
D: % of under 18’s at this site (of total 0%

workers)

E: Workers under 18 subject to hazardous Yes
work assignments? No
(Go to clause 3 – Health and Safety) If Y give details N/A
Non–compliance:

NC against ETI NC against Local Law NC against customer code: observed:
None observed (where relevant please
add photo numbers)
Not applicable

Not applicable
Observation:

Not applicable
Not applicable
Comments:
Not applicable

Not applicable

5: Living Wages are paid
5: Living Wages are Paid
(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:
1. The local minimum wage standard was RMB 2300 per month equivalent to RMB 13.22 (2300/21.75/8) per
hour since XX-April-20XX, and RMB 2420 per month equivalent to RMB 13.90 (2420/21.75/8) per hour
since XX-April-20XX.
2. The wages were well organized with a good controlled set of processes which are understood by all
employees.
3. The wages of employees in all departments were calculated by hourly rate and paid monthly.
4. The minimum wage paid by the facility was RMB16.00 per hour, which was higher than legal standards.
5. All employees were provided with written and understandable information about their employment
conditions in respect to wages before they entered employment and about the particulars of their
wages for the pay period concerned each time that they were paid.
6. Through document review, auditor found that there were 98 employees in the facility in May 20XX,
except 8 employees who were hired on May 20XX. 90 out of 98 employees participated in basic
endowment insurance, basic medical insurance, maternity insurance, unemployment insurance and
employment injury insurance.
7. Benefits of paid annual leave were given to all employees and child-bearing leave to appropriate
employees.
8. All employees were paid on or before 30th of each month and each employee was given a pay slip
and signed for their wages.
9. Based the records provided by the facility, all employees were paid corrected for their overtime wages,
150% and 200% of normal wage rate was paid for overtime work in normal days and rest days,
respectively; no overtime work was arranged on holidays.
10. Through document review and employee interview, the numbers of workers on attendance and payroll
records were consistent with the number of workers in the employee register. All employees in the
facility were paid by hourly rate. All employees were paid on or before 30th of every month after the
working period and paid by bank transfer, the pay slips also given to employees when the wages
issued. The calculated period was from 1st to 30th of every month. Through document review and
employees interview, all employees were paid meet the local minimum wage. In employees’ wage, no
illegal deduction from employees’ wage.

Details:
1. Document review
2. Employee interview
3. Local and national laws
4. Wages and benefits policy
5. Local legal minimum wage documents
6. Payroll records from April 20XX to Mach 20XX and attendance records from XX April 20XX to XX May
20XX(audit day) were reviewed.
7. Leave records
8. Social insurance and payment receipts from the local labour department
9. Labour contracts for all employees (to examine agreed wage rates)
11. Payslips of all employees interviewed
12. Production records
Any other comments:

Nil
Non–compliance:

add photo numbers)
Not applicable

Not applicable
Observation:

Not applicable
Not applicable
Comments:
Not applicable

Not applicable

Summary Information
Criteria Local Law Actual at the Is this part of a
(Please state legal Site Collective
requirement) (Record site Bargaining
results against the Agreement?
law)
A: Standard/Contracted work hours: Legal maximum: Legal maximum: Yes

(Maximum legal and actual required working hours 8 hours per day 8 hours per day No
excluding overtime, please state if possible per day, and 40 hours and 40 hours N/A. There was
week, and month) per week per week no Collective
Bargaining
Agreement in
the facility
B: Overtime hours: Legal maximum: 1) 0-2 hours per Yes

(Maximum legal and actual overtime hours, please state 3 hours per day day for all No
if possible per day, week, and month) and 36 hours selected N/A. There was
per month samples in no Collective
March 20XX Bargaining
(current month), Agreement in
November 20XX the facility
(Peak month)
and July 20XX
(random
month)
respectively;
2) 64-66 hours
/month in
March 20XX
(current month)
48-60 hours
/month in
November 20XX
(Peak month)
36 hours /month
in July 20XX
(random
month)
D: Wage for standard/contracted hours: Legal minimum: RMB 16.00 per Yes
(Minimum legal and actual minimum wage at site, RMB 2300 per hour No
please state if possible per hr, day, week, and month) month N/A. There was
equivalent to no Collective
RMB 13.22 per Bargaining
hour since 1 Agreement in
April 20XX the facility
E: Overtime wage: Legal minimum: 150% and 200% Yes

(Minimum legal and actual minimum overtime wage at 150% , 200% of normal rate No
site, please state if possible per hr, day, week, and and 300%of were paid by N/A. There was
month) normal rate facility for no Collective
were paid by employees’ Bargaining
facility for overtime Agreement in

employees’ working in the facility
overtime normal working
working in days and rest
normal working days. No
days, rest days overtime work
and official was arranged
holidays on official
respectively public holidays.
Wages analysis:
Wages analysis:
A: Were accurate records shown at Yes

the first request? No
B: If No, why not? N/A
C: Sample Size Checked Based on management interview, peak season was from October
(State number of worker records checked to the next March.
and from which weeks/months – should 26 samples from July 20XX
be current, peak, and random/low. 26 samples from November 20XX
Please see SMETA Best Practice Guidance
26 samples from March 20XX
and Measurement Criteria)
D: Are there different legal minimum Yes If Yes, please give details:
wage grades? If Yes, please specify No
all.
E: If there are different legal minimum Yes If No, please give details:
grades, are all workers graded and No
paid correctly? N/A
F: For the lowest paid production Lowest Wages Please indicate the breakdown of workforce
workers, are wages paid for found: Note: full per earnings:
standard/contracted hours time employees
(excluding overtime) below or above and please state
the legal minimum? hour / week /
month etc.
RMB16.00/ hour.
Below legal __0__% of workforce earning under min wage

min __0__% of workforce earning min wage
Meet __100__% of workforce earning above min
Above wage
G: Bonus (amount specify) Bonus Scheme found:

Note: full time employees and please state hour / week / month
etc.
No bonus for employees
H: What deductions are required by Social insurance, personal income tax

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

I: Have these deductions been Yes
made? Please list all deductions that No
have/have not been made. If No, please describe
Deductions were made for social insurance and personal income
tax.
J: Were appropriate records available Yes

to verify hours of work and wages? No
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 Details:
but not paid for their time) All working hours were paid sufficiently including meeting or training
hours.
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:
amount and source of info: The facility not defined living wages.
Please see SMETA Best Practice
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/A
N: Are there periodic reviews of Yes

wages? If Yes give details (include No
whether there is consideration to 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
Details:
During document review and employee interview, equal work was
paid with equal rates in the facility.
Q: How are workers paid: Cash

Cheque
Bank Transfer
Other
If other explain:

6: Working Hours are not Excessive
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:
1. Based on employees’ interview, overtime is voluntary.
2. The facility used electronic time keeping system (finger print) to keep all employees working hours.
3. According to the provided attendance records and employee interview basic working hours were 8
hours per day and 40 hours per week with no more than 2 hours overtime per day and no more than 66
hours overtime per month. The maximum consecutive working days for all employees were 6 days.
4. Based on the attendance records provided by the facility:
1) For March 20XX (current month), the monthly overtime hours were 66 hours per month, the average
number of hours worked in a week for the 26 selected samples were 54 hours per week. Maximum
working hours per week were 54 hours (all 26 randomly selected samples).
2) For November 20XX (peak month), the monthly overtime hours were 60 hours per month, the
average number of hours worked in a week for the 26 selected samples were 54 hours per week.
Maximum working hours per week were 54 hours (all 26 randomly selected samples).
3) For July 20XX (random month), the monthly overtime hours were 36 hours per month, the average
number of hours worked in a week for the 26 selected samples were 48.5 hours per week.
Maximum working hours per week were 50 hours (all 26 randomly selected samples).

5. The factory obtained Comprehensive Calculating Working hours Permit (valid from XX-February-20XX to
XX-January-20XX, and from XX-February-20XX to XX-January-20XX). Based on document review,
employees’ total working hours from XX-February-20XX to XX-January-20XX were 2412 hours, which met
the requirement of the permit. Employees’ total working hours from XX-February-20XX to XX-April-20XX
were 516 hours.
Details:
2. Management interview
3. Local and national laws
4. Facility policy on working hours
5. Payroll records from April 20XX to March 20XX
6. Employees contracts
7. Attendance records from XX-April-20XX to XX-May-20XX (audit day) were reviewed.
8. Leave Records
10. Production records, Inspection records
11. Comprehensive calculating working hours permit.
Any other comments:

Nil
Non–compliance:

code: Not applicable
None observed

Not applicable

Not applicable
Observation:

Local law or ETI requirement: Not applicable

Not applicable
Comments:
Not applicable


Not applicable
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: electronic time keeping system (finger print)

systems are used:
time card etc.
B: Is sample size same Yes

as in wages section No
If N, please give details
C: Are Yes If NO, please give details including % and which type
standard/contracted No of workers do NOT have standard hours defined in
working hours defined contracts/employment agreements.
in all Details
contracts/employme
nt agreements?
D: Are there any other Yes If YES, please complete as appropriate:

types of No
contracts/employme 0 hrs Part time Variable Other
nt agreements used? hrs
If “Other”, Please define:
NA
E. Do any Yes If Y please %detail hours, % and types of workers

standard/contracted No &affected and frequency
working hours defined
in Details: NA
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 least 1 in 7 days Yes
1 day off in every 7- 2 in 14 days No
day-period, or 2 in 14- No
day-period (where If ‘No’, please explain:
the law allows)?
Maximum number of days worked without a day off (in sample):
6 days

Standard/Contracted Hours worked
G: Standard working Yes If yes, % of workers & frequency

hours over 48 per No
week found
H: Any local Yes If YES, please give details

waivers/local law or No The factory obtained Comprehensive Calculating
permissions which Working hours Permit (valid from XX-February-20XX to
allow XX-January-20XX, and from XX-February-20XX to XX-
averaging/annualise January-20XX).
d hours for this site?
Overtime Hours worked
I: Actual overtime Highest OT hours: 2 hours /day in March 20XX (current month)
hours worked in 2 hours /day in November 20XX (peak month)
sample (State per 2 hours /day in July 20XX (random month)
day/week/month)
14 hours /week in March 20XX (current month)
14 hours /week in November 20XX (peak month)
10 hours /week in July 20XX (random month)
66 hours /month in March 20XX (current month)

60 hours /month in November 20XX (peak month)
36 hours /month in July 20XX (random month)
J: Combined hours Yes

(standard/contracted No
plus= total) 60 found?
K: Approximate __90__%
percentage of total
workers on highest
overtime hours
L: Is overtime Yes Please detail evidence e.g. Wording of

voluntary? No contract/employment agreement/handbook/worker
Conflicting Information interviews/refusal arrangements:
Voluntary overtime policy was public in workshop
and the facility said they would reject the overtime
working with any punishment from the facility.
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 150%, 200% of normal rate were paid by facility for
requirement to OT premium employees’ overtime working in normal working days
and weekends respectively.
N: Is overtime paid at Yes If yes, please describe % of workers & frequency:

a premium? No 100% employee/monthly

O: ETI Code requires a No
prevailing standard to Consolidated pay (May be standard wages above minimum legal wage, with no/low
give greatest worker overtime premium)
protection. Collective Bargaining agreements
If a site pays less than Other
125% OT premium N/A
and this is allowed
under local law, are Please explain any checked boxes above e.g. detail of consolidated pay CBA or
there other Other
considerations?
Please complete the
boxes where relevant. N/A
Multi select is possible.
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 N/A, the weekly hours was less than 60 hours.
boxes where relevant.
Multi select is possible. Please explain any checked boxes above
N/A
Q: Is there evidence Yes

that overtime hours No
are being used for If yes, please describe
extended periods to The facility said increased order volumes lead to more overtime working.
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.

7: No Discrimination is practiced
7: No Discrimination is Practiced
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:
1. As informed by interviewed employees, most employees spoke highly of the facility owner.
2. No employee was required to do the examination of the hepatitis B virus and HIV.
3. Anti-discrimination procedure on hiring, compensation, promotion and access to training was available
for review during the audit.
4. Gender divisions did not exist in the facility; both female and male employees were distributed in all
types of work.
5. There was an internal grievance process, all sampled employees were aware of the grievance channels
in case they encountered any discrimination cases.
6. There was no evidence of sexual harassment.
Details:
1. The hiring and termination procedure, leave application records and employee handbook.
2. Payrolls
3. Attendance records
4. Termination records
5. Training records
Any other comments:

Nil
A: Gender breakdown of Management Male: _70__ %

+ Supervisors (Include as one combined Female_30__ %
group)
B: Number of women who are in skilled #:

or technical roles e.g. where specific
qualifications are needed i.e. machine N/A
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
Remarks: N/A

Professional Development
A: What type of training and development Please give details

are available for workers?
On-going training was available to en able employees to
progress. An equal and clear fair selection standard was in
place for all promotions and benefits.
B: Are HR decisions on e.g. promotion, Yes

training, compensation based on
objective, transparent criteria? No
If no, please give details:
Non–compliance:

add photo numbers)
Local law and/or ETI requirement: Not applicable
Not applicable

Not applicable
Observation:

Local law or ETI requirement: Not applicable
Not applicable
Comments:
Not applicable

Not applicable

8: Regular Employment Is Provided
8: Regular Employment Is Provided
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:
All employees were recruited by the facility directly. No labour agency was used to hire employees. No
temporary employee, apprenticeship schemes or home employee was identified by the auditor. No
subcontractor was used.
Details:
1. The hiring and termination practices
2. Personal files
3. Payroll records were provided for review.
Any other comments:

Nil

Non–compliance:

add photo numbers)
Not applicable

Not applicable
Observation:

Not applicable
Not applicable
Comments:
Not applicable

Not applicable
Responsible Recruitment
All Workers
A: Were all workers presented with Terms & Conditions presented

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

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
N/A
C: If any checked, give details: N/A
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 migrant All types of work in the facility include migrant employees.
workers:
B: Migrant worker recruitment Total number of (in country recruitment agencies) used: N/A
Total number of (outside of local country) recruitment agencies
used: N/A
C: Migrant workers’ voluntary Yes Observations

deductions (such as for remittances) No
confirmed in writing by the worker and Please describe N/A
evidence of transaction is supplied by finding:
the facility to the worker. N/A
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 There were 8 migrant employees who were working in skilled and
migrant workers including permanent management roles such as production department supervisor.
workers, temporary and/or seasonal
workers)

NON-EMPLOYEE WORKERS
Recruitment Fees:
A: Are there any fees Yes
No
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
N/A
C: If any checked, give N/A
details:
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 N/A. There was no agency employee in the facility.
(average): And names if available: N/A
B: Were agency workers’ Yes

age/pay/hours included within No
scope of this audit Remarks: N/A
C: Were sufficient documents for Yes

agency workers available for No
review? Remarks: N/A
D: Is there a legal contract / Yes

agreement with all agencies? No
N/A
Details: N/A
E: Does the site have a system for Yes

checking labour standards of No

agencies? N/A
If yes, please give details.
Please describe:
N/A
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
Please describe finding: If Y, how many contractors are present
B: If Yes, how many workers supplied by

N/A
contractors
Yes
C: Do all contractor workers understand No
their terms of employment? N/A
Please describe finding: N/A
D: If Yes, please give evidence for

N/A
contractor workers being paid per law:

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.
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:
1. A site tour showed that all production processes were present in the facility
2. No sub-contractor or homeworking was used by the facility.
3. The facility had set up policy in place to manage sub–contracting, homeworking and external
processing.
If any processes are sub–contracted – please populate below boxes

Process Subcontracted Process 1 Process 2
Name of factory N/A N/A
Address N/A N/A
Details:
1. Site tour (Calculation on total production and estimated capacity)
2. Materials in/out records

Non–compliance:

NC against customer code: (where relevant please
Not applicable
Local law and/or ETI /Additional Elements requirement:
Not applicable

Not applicable
Observation:

Not applicable
Local law or ETI/Additional elements requirement:
Not applicable
Comments:
Not applicable

Not applicable
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
hours or undeclared sub- N/A
contracting
B: If sub–contractors are used, is Yes

there evidence this has been No
agreed with the main client? If Yes, summarise details: N/A
C: Number of sub– 0
contractors/agents used
D: Is there a site policy on sub– Yes

contracting? No
If Yes, summarise details: N/A
E: What checks are in place to N/A. No sub-contractor was used in the facility.
ensure no child labour is being
used and work is safe?
Summary of homeworking – if applicable

A: If homeworking is being used, is Yes

there evidence this has been No
agreed with the main client? If Yes, summarise details: N/A
B: Number of homeworkers Male: 0 Female: 0 Total: 0
C: Are homeworkers employed Directly

direct or through agents? Through Agents
N/A
D: If through agents, number of N/A

agents
E: Is there a site policy on Yes

homeworking? No
N/A
F: How does site ensure worker N/A

hours and pay meet local laws for
homeworkers?
G: What processes are carried out N/A

by homeworkers?
H: Do any contracts exist for Yes

homeworkers No
N/A
Please give details: N/A
I: Are full records of homeworkers Yes

available at the site? No
N/A

9: No Harsh or Inhumane Treatment is allowed
9: No Harsh or Inhumane Treatment is Allowed
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 describe: The facility provided access to confidential
standards and H&S or any other grievance mechanism for all employees.
grievances to a 3rd party?
B: If Yes, are workers aware of these All employees were trained on the facility confidential
channels and have access? Please give grievance mechanism.
details.
C: If yes, what type of mechanism is used Suggestion box and employees also could speak to their
e.g. hotline, whistle blowing mechanism, supervisors directly.
comment box etc. Please give details.
Workers
D: Is there a grievance mechanism is Communities
place for: Suppliers
Other
Details: The grievance mechanism includes a provision for

non-retaliation and it allows employees to report issues
anonymously.
Yes
E: Are there any open disputes? No
If yes, please give details

N/A
Yes
F: Does grievance mechanism meet with No
UNGP requirement of e.g. (Legitimate,
Accessible, Predictable, Equitable,
Transparent, Rights-compatible, a source If no, please give details
of continuous learning and based on
stakeholder engagement)? N/A
Yes
G: Does the site \ encourage its business No
partners (e.g., suppliers) provide If No Please give details
individuals and communities with access
to effective grievance mechanisms (e.g., N/A
help lines or whistle blowing mechanism

Yes
H: Is there a published and transparent No
disciplinary procedure If No please explain
N/A
Yes
I: If yes, are workers aware of these the No
disciplinary procedure If no please give details
N/A
Yes
J: Does the disciplinary procedure allow No
for deductions from wages (fines) for If Yes please give details N/A
disciplinary purposes (see wages section)

Current systems:
1. The facility established anti-harsh or inhumane treatment policy. The policy stated that physical abuse
or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms
of intimidation shall be prohibited.
2. The facility established a disciplinary procedure for employees’ misbehaviour which included oral
warning, written warning and finally termination.
3. The anti-harsh or inhumane treatment policy and disciplinary procedure were communicated to the
employees through regular trainings.
4. Employee interview confirmed that employees were aware of anti-harsh or inhumane treatment policy
and disciplinary procedure.
5. There is an internal process for grievance, where employees can report any grievances (harassment,
bullying, discrimination etc.) and any received complaint will be handled by management.
Details:
1. The anti-harsh or inhumane treatment policy and disciplinary procedure
2. Training records regarding anti-harsh or inhumane treatment policy and disciplinary procedure
3. Internal grievance procedure
4. Facility tour
5. Management interview and employee interview
Any other comments:

Nil
Non–compliance:

add photo numbers)
Not applicable

Not applicable

Observation:

Not applicable
Not applicable
Comments:
Not applicable

Not applicable

10 A: Entitlement to Work and Immigration
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.

Current systems:
1. Per document review, facility management representation and employee interview, all employees in
the facility were XXX, around 98% employees were migrant employees who came from other provinces
and 2% were local employees.
2. All employees had the proper legal rights to work in this region. The youngest age is 18 years old. All of
them were recruited directly by the facility and no agency was involved in facility’s recruitment
processes.
3. No agency staff or foreign employee was used by the facility.
Details:
1. Hiring procedure
2. Personnel files
3. Employee handbook
Any other comments:

Nil
Non–compliance:

NC against customer code: (where relevant please
Not applicable
Local law and/or ETI /Additional Elements requirement:

Not applicable

Not applicable

Observation:

Not applicable
Local law or ETI/Additional Elements requirement:
Not applicable
Comments:
Not applicable

Not applicable

10 B 2: Environment 2–pillar10 B 2: Environment 10B4: Environment 4–Pillar
10. Other issue areas 10B4: Environment 4–Pillar
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 coordinating 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:
1. Environmental Impact Assessment (EIA)report, EIA approval, environmental projection acceptance
check report for the completed construction project and water discharge permit were provided for
review during the audit
2. No evidence showed that the facility had completed the appropriate section of the SAQ, no SAQ was
provided for review during audit.
3. The facility established the power use statistical system and provided its monitoring records of energy
consumption.
4. The facility provided its ODS (Ozone Depleting Substances) inventory for review.
5. The facility established the environment policy or declare, and approval for above policy or declare
from the management was available.
6. The facility provided its GHG emissions inventory (direct and indirect/related to energy consumption) for
review and did not calculate the emission quantity of GHG.
7. Mr. X/Vice General Manager was in charge of environmental issues.

8. No evidence showed that the environment specialist in the facility had been trained or qualified.
9. The facility had not been subject to (or pending) any fines/prosecutions for noncompliance to
environmental regulations.
Details:
1. On site observation
4. Environmental management manual
5. Energy use monitor records
Any other comments:

N/A
Non–compliance:

NC against ETI/Additional Elements NC against Local observed:
NC against customer code: 1. Management
interview, document
No evidence showed that the environment specialist in the facility had been review, employee
trained or qualified. interview and on site
observation.
Local law and/or ETI/Additional Elements requirement:
No local law applies
In accordance with 10B4.3 Businesses shall be aware of their end client’s

environmental standards/code requirements
In accordance with 10B4.9 Businesses should have a nominated individual

responsible for coordinating the site’s efforts to improve environmental
performance.

It is recommended that the facility should arrange qualified or trained
environment specialist.
Action By: Mr. /Vice General Manager

NC against ETI/Additional Elements NC against Local 2. Management
NC against customer code: interview, document
review, employee
It was noted that no environmental legal register in place and regularly interview and on site
updated, also no cycle, ways to update the environmental legal. observation.
Local law and/or ETI/Additional Elements requirement:

No local law applies.

In accordance with 10B4.3 Businesses shall be aware of their end client’s
environmental standards/code requirements
10B4.8 Businesses shall have available for review any environmental certifications
or any environmental management systems documentation

It is recommended that the facility should establish environmental legal register
in place and regularly updated and designate relevant principal and define the
update cycle and ways.
Action By: Mr. X/ Vice General Manager

Observation:
1. Description of observation: Objective evidence

No evidence showed the facility had completed the appropriate section of the observed:
SAQ, no SAQ was provided for review during audit. Management interview
and document review.
Local law or ETI/Additional elements requirements:
In accordance with 10B4.10 Suppliers should have completed the appropriate

section of the SAQ and made it available to the auditor.
Comments:
Based on management interview, they did not complete SAQ.

Not applicable

Environmental Analysis
(Site declaration only – this has not been verified by auditor. Please state units in all cases below.)
A: Responsible for Environmental issues (Name and Mr. X/Vice General Manager
Position):
Yes No
B: Has the site conducted a risk assessment on the Details: The facility had conducted an internal risk
environmental impact of the site, including assessment on environmental impact of the site, and
implementation of controls to reduce identified risks had taken same action for reduce the identified
risks.
C: Does the site have a recognised environmental Yes No

system certification such as ISO 14000 or equivalent? Details: No ISO14000 certificate in the facility
Please detail.
D: Does the site have an Environmental policy? Yes No

(For guidance, please see Measurement criteria) If yes, is it publicly available? Yes
E: If yes, does it address the key impacts from their Yes No

operations and their commitment to improvement? Details: Based on document review, the policy
addressed the key impacts from their operations
and their commitment to improvement.
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 Details: N/A
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. Details: The factory obtained Environmental Impact
Assessment (EIA) report, EIA approval, environmental
projection acceptance check report for the
completed construction project, and water
discharge permit.
I: Is there a documentation process to record Yes No N/A

hazardous chemicals used in the manufacturing Details: Release agent and lubricant oil were used in
process? the factory, the factory established chemical handle
procedure.
J: Is there a system for managing client’s Yes No

requirements and legislation in the destination Details: No such program was established in the
countries regarding environmental and chemical facility.
issues?
K: Facility has reduction targets in place for Yes No

environmental aspects e.g. water consumption and Details: No such program was established in the
discharge, waste, energy and green-house gas facility.
emissions

L: Facility has evidence of waste recycling and is Yes No
monitoring volume of waste that is recycled. Details: The general wastes were removed by the
contracted companies.
M: Facility has a system in place for accurately Yes No

measuring and monitoring consumption of key Details: Consumption of water and electricity were
utilities of water, energy and natural resources that monitored monthly.
follows recognised protocols or standards
N: Facility has checked that any Sub-Contracting Yes No

agencies or business partners operating on the Details: The facility checked hazardous waste
premises have appropriate permits and licences disposal company’s business permit.
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: _April 20XX_
______________
Electricity Usage: Not provided by the 3,800.00 per month

Kw/hrs facility
Renewable Energy Usage: Not provided by the Not provided by the

Kw/hrs facility facility
Gas Usage: Not provided by the 200.00 stere per month

Kw/hrs facility
Has site completed any carbon Footprint Analysis? Yes No Yes No
If Yes, please state result N/A N/A
Water Sources: Local water authority Local water authority

Please list all sources e.g. lake, river, and local water
authority.
Water Volume Used: Not provided by the 48.00 tons/month

(m³) facility
Water Discharged: No waste water was No waste water was

Please list all receiving waters/recipients. discharged or produced. discharged or produced.
Domestic waste water Domestic waste water
was discharged to was discharged to
municipal sewage pipe municipal sewage pipe
network. network.
Water Volume Discharged: Not provided by the Not provided by the

(m³) facility facility
Water Volume Recycled: Not provided by the Not provided by the

(m³) facility facility
Total waste Produced Not provided by the Not provided by the

(please state units) facility facility
Total hazardous waste Produced: Not provided by the Not provided by the
(please state units) facility facility
Waste to Recycling: N/A N/A

(please state units)
Waste to Landfill: N/A N/A

Waste to other: N/A N/A

(please give details and state units)
Total Product Produced N/A N/A


10C: Business Ethics – 4–Pillar Audit
10C: Business Ethics – 4-Pillar Audit
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:
1. The facility established the formal Business Ethics policy and procedure.
2. The facility had arranged training about conflict of interest process (including declaration of conflict of
interest) for management staff and employees.
3. The facility established policy which prohibits offering or accepting bribes, kickbacks or inappropriate
gifts or entertainment, and the facility established the formal procedure that ensures gifts to or from
suppliers and customers was not excessive in cost and frequency included a regularly monitoring of its
business. Relevant training had been provided to for management, supervisors and employees before.
4. The facility established procedure to ensure records were not falsified and accurate and has not
established procedures to prevent and investigate misrepresentation by employees, managers and
their agents.
5. The facility had established Intellectual Property Management Procedure, but the facility did not sign
any non-disclosure agreement (separate or part of employment contract) for employees and
employee, furthermore, the training about intellectual property and business information loss or
unauthorized disclosure had not been arranged before.

6. The facility had established formal policy and program was in place to protect privacy and confidential
data
7. The facility established the anti-retaliation policy, and the facility did not arrange any training about
their anti-retaliation policy to all employees.
Details:
2. Document review
Any other comments:

Nil
Non–compliance:

NC against ETI/Additional Elements NC against Local observed:
NC against customer code: Management interview,
document review,
The facility had established Intellectual Property Management Procedure, but employee interview and
the facility did not sign any non-disclosure agreement (separate or part of on site observation.
employment contract) for employees and employee, furthermore, the training
about intellectual property and business information loss or unauthorized
disclosure had not been arranged before.
Local law and/or ETI/Additional elements requirement:

In accordance with 10C.1 Businesses shall conduct their business ethically

without bribery, corruption, or any type of fraudulent Business Practice.
In accordance with 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.
In accordance with 10C.5 Businesses should have a Business Ethics policy,

covering bribery, corruption, or any type of fraudulent Business Practice,
In accordance with 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.

It is recommended that the facility should sign non-disclosure agreement and
should provide relevant training for employees
Action By: Mr. X/Vice General Manager

Observation

Not applicable
Local law or ETI/Additional Elements requirement:
Not applicable
Comments:
Not applicable

Not applicable
Internal Policy
A: Does the facility have a Business Ethics Policy for third parties including suppliers
Policy and is the policy communicated and
applied internally, externally or both, as Please give details: The factory established a Business
appropriate? Ethics Policy and the policy is communicated and applied
internally and externally.
B: Does the site give training to relevant Yes, the factory had given training to relevant personnel
personnel (e.g. sales and logistics) on (e.g. sales and logistics) on business ethics issues on XX-
business ethics issues September-20XX.
Yes
C: Is the policy updated on a regular (as No
needed) basis?
Please give details: Based on document review and
management interview, no evidence showed that the
policy was updated regularly.
Yes
D: Does the site require third parties No
including suppliers to complete their own
business ethics training Please give details: Based on document review and
management interview, no evidence showed the site
required third parties including suppliers to complete their
own business ethics training.
Other findings

Other Findings Outside the Scope of the Code
Nil
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)
Nil

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."
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.
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.
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.
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
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.

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 coordinating 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
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.

Photo Form
Factory gate Factory address Office building
Production building Production building Dormitory building
Raw materials warehouse Finished goods warehouse Sample room

Injection moulding area Plastic smashing area Plastic mixing area
Assembly area Packaging area Belt guards on punching

machines
Machine operation instructions Ladders on injection moulding Emergency lighting and exit sign,
were posted machines were installed with fire alarm
handrails

Evacuation map Electronic box Inspection records of fire alarm
Fire extinguishers and fire hydrant Inspection records of fire hydrant Inspection records of fire
extinguishers
Drinking water Toilet Emergency eyewash equipment
Hazardous storage First aid kits Inspection records of first aid kits

Canteen Kitchen Bedroom
Bathroom and toilet in bedroom Exit sign and emergency light in Fire alarm and first aid kits in
dormitory dormitory
Evacuation map in dormitory Fire extinguishers in dormitory Potable water in dormitory
Time clock Suggestion box Safety warning sign

Auditor GPS Location Map
Business license ISO 9001:2015 certificate Social responsibility system

procedure list
Management representative Building construction certificate Building construction certificate

appointment letter

Fire inspection records Occupational Health hazards Drinking water test report
monitor records
Waste water monitor report Noise monitor report Air emission monitor report
Waste water discharge permit Travelling crane inspection Forklift inspection records
records

Catering service permit Health certificates of canteen Machine list
staffs
Workers roster Social insurance receipt Certificate of forklift driver
Certificates of travelling crane Certificate of pressure vessel First aiders’ certificates

operators operator

Training certificates of safety Environmental Impact Assessment Approval Report of Environmental
management report Impact Assessment
Environmental facilities inspection Prohibition of child labor Prohibition of forced labor

and acceptance approval procedure procedure
Free association procedure Anti- discrimination procedure Disciplinary procedure

Electrician certificates Complain procedure Anti-corruption and bribery
procedure
Comprehensive calculating Employee representative election Employee representative meeting

working hours permit records records
Management employee training Health and safety training records Employees were trained on social
records compliance procedures

PPE training records Machine operation training Chemical training records
records
Internal audit records Corrective action records for Management review records
internal audit
Health and safety committee Fire drill records Fire drill records
meeting records

Supplier list Supplier audit records Employee manual
Anti-corruption and bribery Risk assessment records Resignation records

training records
Leave records Environment impact factors ODC list

identification records

Energy saving procedure Environment policy Accident log
Electricity safety inspection Employee personal file and ID Labor contract

records copy
Production records Production records Attendance records

Payroll records Hazardous waste disposal Business permit of hazardous
contract waste disposal company
Hazardous waste transfer GHG list and monitor records Energy monitor records
records
Factory acknowledgement Signed COC Signed CAP-1

Signed CAP-2 Signed CAP-3 Signed CAP-4
Photos of non-conformities:
Nil Nil
NC: Plastic smashing workers wore

masks, but did not wear earplugs

For more information visit: Sedexglobal.com
Your feedback on your experience of the SMETA audit you have observed is extremely
valuable. It will help to make improvements to future versions.
You can leave feedback by following the appropriate link to our questionnaire:
Click here for Buyer (A) & Buyer/Supplier (A/B) members:

http://www.surveymonkey.com/s.aspx?sm=riPsbE0PQ52ehCo3lnq5Iw_3d_3d
Click here for Supplier (B) members:

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Audit Details

Sedex Company ZC: Anonymous Sedex Site Reference: ZS: Anonymous

Business name (Company Anonymous

Site contact and job title: Mr. X/Administration Manager

Audit Company Name &

Brand owner NGO Trade Union

Multi– Combined Audit (select all that apply)

Audit company: QIMA Report reference: R-Cloud-XXXXXXX Date: XX-May-20XX 2

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

Report writer: Steven Wong

Date of declaration: XX-May-20XX

Audit company: QIMA Report reference:R-Cloud-XXXXXXX Date:XX-May-20XX 4

0A Universal Rights covering UNGP 0 0 None observed

0B Management systems and 0 1 0 Obs:

1. Freely chosen Employment 0 0 0 None observed

2 Freedom of Association 0 0 0 None observed

3 Safety and Hygienic Conditions 3 0 0 NC:

4 Child Labour 0 0 0 None observed

5 Living Wages and Benefits 0 0 0 None observed

6 Working Hours 0 0 0 None observed

7 Discrimination 0 0 0 None observed

Audit company: QIMA Report reference: R-Cloud-XXXXXXX Date: XX-May-20XX 5

8A Sub–Contracting and 0 0 0 None observed

9 Harsh or Inhumane Treatment 0 0 0 None observed

10A Entitlement to Work 0 0 0 None observed

10B4 Environment 4–Pillar 2 1 0 NC:

10C Business Ethics 1 0 0 NC:

General observations and summary of the site:

Audit company: QIMA Report reference: R-Cloud-XXXXXXX Date: XX-May-20XX 6

10B.4 Environment 4–Pillar

10C Business Ethics

Audit company: QIMA Report reference: R-Cloud-XXXXXXX Date: XX-May-20XX 7

Audit company: QIMA Report reference: R-Cloud-XXXXXXX Date: XX-May-20XX 8

A: Company Name: Anonymous

B: Site name: Anonymous

C: Applicable business and other Business License Number: XXXXXXXXXXXXXX

E: Site description: Company X is located at ABC Country.

In view of the facilities, the facility consisted of three 1-storey

For building details, please refer to below tables:

Warehouse Description Remark, if any

Production Description Remark, if any

Audit company: QIMA Report reference: R-Cloud-XXXXXXX Date: XX-May-20XX 9

Production Description Remark, if any

Dormitory Description Remark, if any

A total of 98 employees are currently working in the facility,

Visible structural integrity issues (large cracks) observed and

Audit company: QIMA Report reference: R-Cloud-XXXXXXX Date: XX-May-20XX 10

G: Month(s) of peak season: From Month X to Month Y

The main machineries of the facility include: 24 injection

I: What form of worker representation / Union (name)

J: Is there any night production work at Yes

K: Are there any on site provided Yes

L: Are there any off site provided worker Yes

M: Were the site provided Yes

Audit company: QIMA Report reference: R-Cloud-XXXXXXX Date: XX-May-20XX 11

B: Number of Auditor Days Used: 2 days *1 auditor = 2 man-days

C: Audit type: Full Initial

D: Was the audit announced? Announced

E: Was the Sedex SAQ available for Yes

F: Any conflicting information Yes

G: Who signed and agreed CAPR Mr. X/Administration Manager

H: Is further information available Yes

I: Previous audit date: XX-May-20XX

J: Previous audit type: Full initial

C: Worker remuneration (management _0__% employees on piece rate