Professional Documents
Culture Documents
Assessment Date(s):
Supplier Profile
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of: documents,
worker and management interviews, and/or visual observations. All information is based on conditions during the specific
assessment date(s), and does not guarantee compliance to law, industry standards, or client requirements. Furthermore, all
information referencing law is provided in a limited scope, and does not constitute legal advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
Contents
1. Assessment Overview
1.1 Summary of Activities
2. Labor
2.1 Postings
2.2 Terms of Employment
2.3 Wages and Benefits
2.4 Working Hours
2.5 Forced, Bonded, Indentured, Slave, Prison Labor and Human Trafficking
2.6 Child Labor and Young Workers
2.7 Abuse, Harassment and Disciplinary Action
2.8 Discrimination
2.9 Freedom of Association and Collective Bargaining
3. Health, Safety and Employee Housing
3.1 Licenses/Permits/Certifications
3.2 Postings
3.3 Risk Assessment
3.4 Risk Management
3.5 Governance
3.6 Education
3.7 Fire Safety and Emergency Evacuation
3.8 First Aid and Emergency Care
3.9 Personal Protective Equipment
3.10 Chemicals and Hazardous Materials
3.11 Equipment Safety
3.12 Electrical Safety
3.13 Noise
3.14 Ventilation and Lighting
3.15 Drinking Water
3.16 Sanitation
3.17 Food Preparation Areas and Meals
3.18 Child Care
3.19 Employee Housing
4. Environmental Management
4.1 Licenses/ Permits/Certifications
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
1. Assessment Overview
1.1 Summary of Activities
Opening Meeting:
Upon arrival to the facility, the Saulo Siesquén (Lead Auditor) was greeted by Janet Duran - HHRR Chief and escorted to
NOVAPERU SAC where an opening meeting was conducted with Janet Duran - HHRR Chief. The assessment
procedures, grading criteria and Statement of Integrity were explained, and the Statement of Integrity was signed by a
facility representative. Access to employees, facility and documentation was fully granted.
Facility management allowed the auditor Saulo Siesquen to take during the assessment.
Facility Walkthrough:
A health and safety walkthrough was facilitated by Janet Duran - HHRR Chief which provided an overview of the facility
work floor and employee interaction with each other and with the management team.
The auditor Mr. Saulo Siesquen assessed the following facility areas:
The company has recently moved to new premises, so it is a completely new construction.
The facility is made of noble material and has the legal permits required to operate, such as the operating license,
technical inspection of building safety, environmental permits and sanitary permits. It has an area of 14 000
square meters of which 5 000 square meters are built. The production processes are as follows: Raw material
reception area, washing, disinfection, packaging and Warehouse.
There was a total of 136 employees at this facility: 34 Administrative employees (20 males and 14 females) and
102 Operations employees (48 males and 54 females). The gender distribution is the following: Male: 47%.
Female: 53%.
Documentation Review:
After the walkthrough, facility management provided access to facility Environmental, Health and Safety (EHS)
documentation. The following EHS documentation was reviewed:
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contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
Furthermore, a payroll assessment was conducted and one full year of payroll and time records were made available for
the review and facilitated by Janet Duran - HHRR Chief. As part of the payroll review, Mr. Saulo Siesquén requested and
was provided with three payroll periods as the sample for the payroll assessment. In each period, 10 workers were
sampled.
The reviewed payroll records consisted of 10 records from February 2023 (current month), 10 records from June 2022
(random month), and 10 records from November 2022 (random month) payroll records issued to 0 hourly employees, 0
employees piece rate employees and 10 salaried employees salaried employees as well as record of retirement fund
payments, vacations, payment of health insurance, law life insurance, bonuses and compensation for time of service.
Payroll register displayed employee name, weekending date, all regular and overtime hours worked, hourly rates,
earnings, additions/deductions, net and gross earnings.
In addition to payroll and time records, the following records were also reviewed:
Record of Private Funds administration.
Health insurance payment records.
Law life insurance record.
Attendance dial record.
Payment of gratifications.
Deposit of Compensation for Time of Service (CTS).
Worker’s handbook.
Worker file.
Employment contracts.
Worker entry record.
Life insurance.
Employee Interviews:
The day on which the employee interviews were conducted, a total of 136 employees were present. A sample of 10
employees was selected to include 6 males and 4 females all Peruvians, all directly hired by the facility, the selected
workers work in the warehouse, maintenance and packaging. The facility provided a private space for interviews. 10
individual interviews were conducted. The workers were selected from the list provided by the HR Chief, the list contained
the workers who had attended work that day, who mark their attendance in a biometric record. The payroll of workers
contained the date of entry and date of birth. There was no evidence of the existence of underage workers. The youngest
worker was 18 years old.
Closing Meeting:
At the conclusion of the assessment a closing meeting was conducted with by Janet Duran - HHRR Chief. The
assessment outcome was communicated and reviewed in detail through presenting the Summary of Findings. Facility
management comments consisted of to thank for the contributions on the observations and the clarifications that were
made to the doubts of those responsible, as well as the reference to the laws that were being breached. The Summary of
Findings was signed by Janet Duran - HHRR Chief. Assessment team thanked the meeting participants for their time,
cooperation and assistance with the assessment process. The assessment was concluded at 17:00.
2. Labor
2.1 Postings
Are labor-related notices LAB-01 Client expects its Suppliers and ☒ Yes
posted in language(s) Facilities to comply, at a minimum, with ☐ No
understood by employees and all applicable labor, employment, health ☐ N/A
in accordance with other and safety, and environmental laws and Finding
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
regulations of the country where the
applicable standards? Merchandise is produced. Law:
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
in full compliance with the law and copies ☐ No
and maintenance of
of termination records shall be ☐ N/A
termination records executed
maintained. Finding Description:
in accordance with applicable
standards?
Law:
2.3 Wages and Benefits
☒ Yes
☐ No
Are payroll records available LAB-12 Accurate payroll and production ☐ N/A
for review? records shall be maintained. Finding Description:
Law:
Randomly sampled 10 employees’
payrolls and attendance records from
February 2023 (Peak & current month),
Payroll period(s) reviewed for
LAB-13 Information only June 2022 (Random month) and
assessment sample:
November 2022 (not peak month) for
further checking on status of wages and
working hours
☒ Yes
☐ No
Are reviewed payroll records
LAB-14 Accurate payroll and production ☐ N/A
maintained in accordance with
records shall be maintained. Finding Description:
applicable standards?
Law:
Does the facility maintain ☒ Yes
records on production output ☐ No
for employees who are e.g. LAB-15 Accurate payroll and production ☐ N/A
paid by piece or task in records shall be maintained. Finding Description:
accordance with applicable
standards? Law:
☒ Yes
Does the information in
☐ No
reviewed payroll records,
LAB-16 Accurate payroll and production ☐ N/A
records on production outputs
records shall be maintained. Finding Description:
(as applicable) and interviews
correspond?
Law:
Is the legal minimum wage ☒ Yes
guaranteed to employees in ☐ No
LAB-17 Employees shall be paid at least
accordance with applicable ☐ N/A
the legal minimum and overtime wages
standards? Finding Description:
for hours worked.
Law:
Are employees compensated ☒ Yes
at the rate dictated by the ☐ No
LAB-23 Employees shall be paid at least
applicable standard based on ☐ N/A
the legal minimum and overtime wages
their classification (e.g. Finding Description:
for hours worked.
salaried employee, temporary,
apprentice)? Law:
Are employees paid for "down LAB-24 Employees shall be paid at least ☒ Yes
time" in accordance with the legal minimum and overtime wages ☐ No
applicable standards? for hours worked. ☐ N/A
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
Finding Description:
Law:
LAB-25 Wages shall be paid directly to ☒ Yes
the Employee, or if the Employee has ☐ No
Is the payment method in
agreed otherwise, paid directly into an ☐ N/A
accordance with applicable
Employee-controlled account. Finding Description:
standards?
Law:
LAB-26 Wages shall be paid directly to ☒ Yes
the Employee, or if the Employee has ☐ No
Are wages paid directly to the
agreed otherwise, paid directly into an ☐ N/A
employee or an employee-
Employee-controlled account. Finding Description:
controlled account?
Law:
☒ Yes
☐ No
Is the pay frequency in LAB-27 Wages shall be paid at least
☐ N/A
accordance with applicable monthly or on a legally required
Finding Description:
standards? schedule, whichever is more strict.
Law:
☒ Yes
☐ No
Is the time of payment in LAB-28 Wages shall be paid at least
☐ N/A
accordance with applicable monthly or on a legally required
Finding Description:
standards? schedule, whichever is more strict.
Law:
☒ Yes
☐ No
LAB-29 Employees shall be paid at least
Is overtime paid in accordance ☐ N/A
the legal minimum and overtime wages
with applicable standards? Finding Description:
for hours worked.
Law:
Does the facility provide ☒ Yes
employees with an ☐ No
understandable wage LAB-30 An itemized wage statement for ☐ N/A
statement that, at minimum, all Employees shall be provided, which, Finding Description:
includes pay period, wages at a minimum, shall include pay period,
earned for pay period, rate of wages earned for pay period, rate of pay, Law:
pay, regular and overtime regular and overtime hours worked,
hours worked, deductions, and deductions, and benefits.
benefits in accordance with
applicable standards?
☒ Yes
☐ No
Are deductions from employee LAB-31 Unless required by law, there
☐ N/A
wages in accordance with should be no other deductions from
Finding Description:
applicable standards? wages.
Law:
Do employees receive LAB-33 Employees shall be provided all ☒ Yes
applicable benefits in legally mandated benefits, including ☐ No
accordance with applicable Social Security, parental leave, annual ☐ N/A
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contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
standards? leave, sick leave and statutory holidays. Finding Description:
Law:
2.4 Working Hours
Working hours: Production: 1/ Monday to
Standard hours of operation LAB-34 Information only
Saturday 08:00 – 17:00.
Number and duration of breaks 1 hours to lunch
LAB-35 Information only
during work day
☒ Yes
☐ No
Are time records available for LAB-36 Time records shall be available ☐ N/A
review? for review. Finding Description:
Law:
Randomly sampled 10 employees’
payrolls and attendance records from
Time record period(s) February 2023 (Peak & current month),
reviewed for assessment LAB-37 Information only June 2022 (Random month) and
sample: November 2022 (not peak month) for
further checking on status of wages and
working hours.
☒ Yes
☐ No
Are time records maintained in
LAB-38 Time records shall be maintained ☐ N/A
accordance with applicable
in compliance with applicable standards. Finding Description:
standards?
Law:
LAB-39 Employees’ combined regular ☒ Yes
and overtime working hours shall not ☐ No
exceed legal limits or 60 hours per week, ☐ N/A
Are employees working regular
whichever is more strict. Exceptions to Finding Description:
working hours (daily, weekly,
this requirement must be in compliance
monthly, other) in accordance
with the law and only due to exceptional Law:
with applicable standards?
circumstances, such as work that is
continuous in nature or in the event of an
emergency.
LAB-44 Employees’ combined regular ☒ Yes
and overtime working hours shall not ☐ No
exceed legal limits or 60 hours per week, ☐ N/A
Are employees working
whichever is more strict. Exceptions to Finding Description:
overtime hours (daily, weekly,
this requirement must be in compliance
monthly, other) in accordance
with the law and only due to exceptional Law:
with applicable standards?
circumstances, such as work that is
continuous in nature or in the event of an
emergency.
☒ Yes
☐ No
Does the facility have an LAB-45 Where required by law, overtime
☐ N/A
overtime waiver in accordance waivers approved by appropriate legal
Finding Description:
with applicable standards? authority must be obtained.
Law:
Are employees informed about LAB-50 If legal overtime is necessary ☒ Yes
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contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
due to the seasonal nature of the ☐ No
industry, Employees shall be informed ☐ N/A
and understand overtime
about overtime obligations prior to time of Finding Description:
obligations prior to
hire and in advance of the overtime shift,
employment and prior to
and be allowed to refuse to work Law:
working the overtime shift?
overtime without punishment, penalty or
disciplinary action.
LAB-51 Employees’ combined regular ☒ Yes
and overtime working hours shall not ☐ No
exceed legal limits or 60 hours per week, ☐ N/A
Do employees receive rest
whichever is more strict. Exceptions to Finding Description:
breaks during the day in
this requirement must be in compliance
accordance with applicable
with the law and only due to exceptional Law:
standards?
circumstances, such as work that is
continuous in nature or in the event of an
emergency.
LAB-52 Employees’ combined regular ☒ Yes
and overtime working hours shall not ☐ No
exceed legal limits or 60 hours per week, ☐ N/A
Do employees receive daily whichever is more strict. Exceptions to Finding Description:
rest in accordance with this requirement must be in compliance
applicable standards? with the law and only due to exceptional Law:
circumstances, such as work that is
continuous in nature or in the event of an
emergency
☒ Yes
☐ No
Do employees receive weekly
LAB-53 At least one day off in a seven- ☐ N/A
rest in accordance with
day workweek shall be provided. Finding Description:
applicable standards?
Law:
Maximum number of LAB-55 Information only 6 days
consecutive days worked at
the facility:
Does the facility prevent ☒ Yes
LAB-56 Offclock work or work taken
employees from taking work ☐ No
home, except when the Facility has
home to finish the task or ☐ N/A
official home work practices approved by
quota? Finding Description:
the appropriate legal authority, shall not
be allowed.
Law:
☒ Yes
Does the facility follow
☐ No
provisions on the number of
☐ N/A
women's working hours in LAB-57
Finding Description:
accordance with applicable
standards?
Law:
2.5 Forced, Bonded, Indentured, Slave, Prison Labor and
Human Trafficking
If applicable, does the facility LAB-58 Supplier and Facility shall only ☒ Yes
only use legally-recognized use legally recognized employment ☐ No
employment agencies with a agencies with a current license and shall ☐ N/A
valid and current license? ensure that recruitment of Employees, Finding Description:
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
whether directly or indirectly, is in
compliance with Applicable Laws and Law:
Regulations.
Do actual employment terms ☒ Yes
LAB-59 Employees shall not be subject
meet the job expectations ☐ No
to any forms of coercion, fraud,
promised at time of ☐ N/A
deception, or giving up control of their
recruitment? Finding Description:
person to another for the purpose of such
exploitation.
Law:
Are employees free from LAB-60 Employees shall not pay any ☒ Yes
paying charges for the purpose fees or other payments to the employer ☐ No
of recruitment or employment, or agent for the purpose of being hired or ☐ N/A
including fees (e.g. as a condition of employment. No such Finding Description:
recruitment, transportation), fees shall be deducted and withheld from
taxes, deposits or bonds (e.g. wages or otherwise passed on to the Law:
training bond)? Employees.
Highest recruitment cost as a 1.025 PEN
percentage of monthly wage
for standard working hours LAB-61 Information only
(not including overtime) for the
applicable employee:
LAB-62 All Employees shall work on a ☒ Yes
voluntary basis and not be subject to any ☐ No
Are employees free of debt
exploitation, such as forced, bonded and ☐ N/A
due to recruitment or
indentured labor, or sexual exploitation. Finding Description:
employment?
Law:
Highest amount of debt as a There is no overtime, overtime is
percentage of monthly wage voluntary.
for standard working hours LAB-63 Information only
(not including overtime) for the
applicable employee:
Do employees maintain LAB-64 Employees shall maintain ☒ Yes
custody of their original possession or have control of personal ☐ No
documents (e.g. passport, identity and travel documents. ☐ N/A
work permit, birth certification, Finding Description:
official ID card, driver's license,
family record book)? Law:
LAB-65 Employees shall maintain ☒ Yes
possession or have control of personal ☐ No
Did employees voluntarily identity and travel documents. ☐ N/A
relinquish their documents? Finding Description:
Law:
Are employees free from LAB-66 All Employees shall be treated ☒ Yes
pressure, coercion, or threats with dignity and respect. Physical, ☐ No
by any means to maintain sexual, verbal or mental abuse, coercion ☐ N/A
them in employment? or threats, corporal punishment, or any Finding Description:
form of harassment during hiring or
employment is prohibited. Law:
Were employees free from LAB-67 Employees shall not be subject ☒ Yes
pressure, coercion, or threats to any forms of coercion, fraud, ☐ No
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
by any means during ☐ N/A
deception, or giving up control of their
recruitment? Finding Description:
person to another for the purpose of such
exploitation.
Law:
LAB-68 Employees’ freedom of ☒ Yes
movement shall not be restricted, nor ☐ No
Are employees free to resign
shall Employees be prevented from ☐ N/A
employment in accordance
terminating employment. Finding Description:
with applicable standards?
Law:
LAB-69 All Employees shall work on a ☒ Yes
voluntary basis and not be subject to any ☐ No
exploitation, such as forced, bonded and ☐ N/A
indentured labor, or sexual exploitation. Finding Description:
Are employees free from
threats of illegal terminations
Foreign or migrant Employees shall: a) Law:
(e.g. threats of repatriation for
be employed in full compliance with the
foreign workers)?
laws of the host country, including
employment, labor and immigration laws;
and b) not be subjected to threats of
termination or deportation.
☒ Yes
LAB-100 Employees’ freedom of ☐ No
Are employees guaranteed
movement shall not be restricted, nor ☐ N/A
freedom of movement during
shall Employees be prevented from Finding Description:
and after working hours?
terminating employment.
Law:
Does the facility avoid ☒ Yes
withholding wages or requiring ☐ No
deposits of any kind during the LAB-101 Wages shall not be withheld ☐ N/A
employment relationship in except as mandated by law. Finding Description:
accordance with applicable
standards? Law:
☒ Yes
LAB-102 Employees shall not be
☐ No
Are employees free from daily mandated to work overtime hours or
☐ N/A
production quota requirements complete production quotas that result in
Finding Description:
prior to leaving the facility? a violation of legal working hour
requirements.
Law:
☒ Yes
Do employees voluntarily LAB-103 Employees shall not be
☐ No
agree to overtime and is mandated to work overtime hours or
☐ N/A
mandatory overtime complete production quotas that result in
Finding Description:
administered in accordance a violation of legal working hour
with applicable standards? requirements.
Law:
Is mandatory overtime Overtime is voluntary.
LAB-104 Information only
permitted by law?
If applicable, does the facility LAB-105 The use of prison or convict ☒ Yes
employ prison labor in labor must be consistent with laws where ☐ No
accordance with applicable the merchandise is manufactured, and ☐ N/A
standards? with the laws where it is imported. Finding Description:
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
Law:
2.6 Child Labor and Young Workers
Facility minimum hiring age 18 Years
LAB-106 Information only
standard (yrs):
Are employees currently ☒ Yes
LAB-107 All Employees shall be of at
employed at an age in ☐ No
least legal age established by local law. If
accordance with applicable ☐ N/A
the local law does not set a minimum
standards? Finding Description:
age, Employees must be at least
fourteen (14) years old.
Law:
☒ Yes
LAB-108 All Employees shall be of at
☐ No
At the time of hire, was the age least legal age established by local law. If
☐ N/A
in accordance with applicable the local law does not set a minimum
Finding Description:
standards? age, Employees must be at least
fourteen (14) years old.
Law:
LAB-109 Employees under the age of ☒ Yes
eighteen (18) shall not perform ☐ No
hazardous work that may jeopardize their ☐ N/A
Are working conditions (e.g. health, safety or morals. Hazardous work Finding Description:
task, hours) for employees includes, but is not limited to: work at
under the age of 18 in dangerous heights or in confined spaces; Law:
accordance with applicable work with hazardous substances,
standards? dangerous machinery, equipment and/or
tools; work that involves the manual
handling or transport of heavy loads; and
night work.
Are required medical tests LAB-110 The use of legitimate workplace ☒ Yes
before and during employment apprenticeship programs, which comply ☐ No
conducted for employees with Applicable Laws and Regulations, ☐ N/A
under the age of 18 in are permitted. Finding Description:
accordance with applicable
standards? Law:
Does the facility maintain ☒ Yes
permits, licenses, parental ☐ No
consent forms and other LAB-111 The use of legitimate workplace ☐ N/A
documents related to the apprenticeship programs, which comply Finding Description:
employment of apprentices, with Applicable Laws and Regulations,
trainees and employees under are permitted. Law:
the age of 18 in accordance
with applicable standards?
Are identified apprenticeship/ LAB-112 The use of legitimate workplace ☒ Yes
traineeships administered by apprenticeship programs, which comply ☐ No
the facility in accordance with with Applicable Laws and Regulations, ☐ N/A
applicable standards? are permitted. Finding Description:
Law:
Does the facility request LAB-113 Official and verifiable ☒ Yes
original, legal documentation documentation of each Employee’s date ☐ No
to verify the employee's age at of birth, or a legally recognizable means ☐ N/A
the time of hire? of confirming each Employee’s age, shall Finding Description:
be maintained.
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
Law:
Are copies of legal LAB-114 Employees’ age documentation ☒ Yes
documentation kept and shall be verified, and where allowed by ☐ No
maintained in accordance with law, copies of such documents shall be ☐ N/A
applicable standards? maintained for each Employee. Finding Description:
Law:
2.7 Abuse, Harassment and Disciplinary Action
Are employees free from any LAB-115 All Employees shall be treated ☒ Yes
form of abuse, harassment, with dignity and respect. Physical, ☐ No
coercion or corporal sexual, verbal or mental abuse, coercion ☐ N/A
punishment? or threats, corporal punishment, or any Finding Description:
form of harassment during hiring or
employment is prohibited. Law:
LAB-116 Written disciplinary policies and ☒ Yes
procedures and records of disciplinary ☐ No
Does the facility maintain
actions for all Employees shall be ☐ N/A
procedures on disciplinary
maintained.. Finding Description:
action?
Law:
☒ Yes
☐ No
Are disciplinary practices
LAB-117 Illegal or excessive disciplinary ☐ N/A
administered in accordance
actions or monetary fines are prohibited Finding Description:
with applicable standards?
Law:
☒ Yes
☐ No
Are security practices LAB-118 Abusive security practices,
☐ N/A
administered in accordance including opposite sex frisking and
Finding Description:
with applicable standards? removal of clothing, is prohibited.
Law:
2.8 Discrimination
LAB-119 Discrimination in hiring and ☒ Yes
employment practices based on race, ☐ No
color, religion, gender, age, national, ☐ N/A
social or ethnic origin, maternity, sexual Finding Description:
Are employees free from
orientation, political opinion, disability, or
discrimination in accordance
any other status or personal Law:
with applicable standards?
characteristic shall not be allowed.
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
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during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
2. Labor
practices? and Employee and Facility records. Finding Description:
Law:
Are employees hired and LAB-122 Employee medical tests that ☒ Yes
maintained in employment can be used to discriminate in hiring or ☐ No
regardless of pregnancy status employment practices shall not be ☐ N/A
or marital status? required. Finding Description:
Law:
Does the facility follow ☒ Yes
LAB-123 Client expects its Suppliers and
provisions on women's ☐ No
Facilities to comply, at a minimum, with
employment terms during ☐ N/A
all applicable labor, employment, health
pregnancy, maternity leave Finding Description:
and safety, and environmental laws and
and return from maternity
regulations of the country where the
leave in accordance with Law:
Merchandise is produced.
applicable standards?
2.9 Freedom of Association and Collective Bargaining
Are employees free to LAB-124 Employees who wish to join or ☒ Yes
associate and collectively not join trade unions and to bargain ☐ No
bargain in accordance with collectively shall not be interfered with, ☐ N/A
applicable standards penalized or retaliated against. Finding Description:
Law:
Where the ability to associate ☒ Yes
and collectively bargain are ☐ No
LAB-125 Employees who wish to join or
legally restricted, do ☐ N/A
not join trade unions and to bargain
employees have access to Finding Description:
collectively shall not be interfered with,
alternative means in
penalized or retaliated against.
accordance with applicable Law:
standards?
Are activities (e.g. elections, ☒ Yes
meetings) associated with ☐ No
LAB-132 Employees who wish to join or
workers' representation (union, ☐ N/A
not join trade unions and to bargain
workers' organization and Finding Description:
collectively shall not be interfered with,
other representation) permitted
penalized or retaliated against.
by the facility in accordance Law:
with applicable standards?
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
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requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
Law:
3.4 Risk Management
Does the facility maintain HS-06 Documentation includes, but is not ☒ Yes
management plans to mitigate limited to licenses, permits, certifications, ☐ No
or respond to H&S risks in policies and procedures, and Employee ☐ N/A
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requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
☒ Fire extinguishers
Types of firefighting ☒ Fire hoses
equipment used by facility: ☐ Sprinklers
☐ Hydrants
Other:___________________________
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requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
Law:
HS-14 Emergency exits shall be clearly ☒ Yes
marked, free of any obstructions, ☐ No
Are emergency exits
unlocked and provided with signs ☐ N/A
maintained in accordance with
understood by all Employees. Emergency Finding Description:
applicable standards?
exits shall open in the direction of travel
with a single release. Law:
Are emergency exit pathways ☒ Yes
HS-15 Emergency exit routes shall be
present and maintained in ☐ No
clearly marked with direction of travel,
accordance with applicable ☐ N/A
free of any obstructions and welllighted at
standards? Finding Description:
all times. Emergency exit routes shall
lead to a safe assembly area.
Law:
Are evacuation plans present, ☒ Yes
posted and maintained in ☐ No
HS-16 Evacuation plot plans shall be
accordance with applicable ☐ N/A
provided in Employee areas and along
standards? Finding Description:
emergency exit routes.
Law:
Are emergency assembly ☒ Yes
HS-17 Emergency exit routes shall lead
points present and maintained ☐ No
to a safe assembly area. The assembly
in accordance with applicable ☐ N/A
area should not be located near storage
standards? Finding Description:
of chemicals and/or hazardous materials
and equipment.
Law:
☒ Yes
HS-18 Emergency exit routes shall be ☐ No
Is emergency lighting present
clearly marked with direction of travel, ☐ N/A
and maintained in accordance
free of any obstructions and welllighted at Finding Description:
with applicable standards?
all times.
Law:
HS-19 Employees shall be trained on ☒ Yes
evacuation procedures in case of ☐ No
emergency. ☐ N/A
Are evacuation drills Fire and other emergency evacuation Finding Description:
conducted and documented in drills shall be conducted every twelve
accordance with applicable (12) months for all Employees on every Law:
standards? shift and floor or as required by law,
whichever is more strict. Emergency
evacuation shall be monitored by trained
Employees.
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
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requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
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documents, worker and management interviews, and/or visual observations. All information is based on conditions
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requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
Has the facility established a HS-36 Employees who work with or are ☒ Yes
policy/ code governing exposed to chemicals and hazardous ☐ No
chemicals and hazardous materials shall be trained on safe ☐ N/A
materials identification, use, handling, storage and disposal of these Finding Description:
maintenance and training in materials.
accordance with applicable Law:
standards?
Does the facility communicate ☒ Yes
HS-37 Employees who work with or are
and train employees (all ☐ No
exposed to chemicals and hazardous
levels) on the facility's ☐ N/A
materials shall be trained on safe
chemicals and hazardous Finding Description:
handling, storage and disposal of these
materials policy in accordance
materials.
with applicable standards? Law:
☒ Yes
Are employees handling the HS-38 Employees who work with or are
☐ No
chemicals and hazardous exposed to chemicals and hazardous
☐ N/A
materials at the facility in materials shall be trained on safe
Finding Description:
accordance with applicable handling, storage and disposal of these
standards? materials.
Law:
HS-39 Procedures shall be adopted and ☒ Yes
steps shall be taken to prevent accidents, ☐ No
injuries and the spread of diseases. ☐ N/A
Are materials labeled as Policies and procedures shall be Finding Description:
hazardous, combustible or implemented, and management shall
flammable and stored in identify a person or persons at the Facility Law:
accordance with applicable or work site to be responsible for
standards? monitoring and implementing, practices to
comply with all Applicable Laws and
Regulations and the Supplier Code of
Conduct.
Does the facility prepare HS-40 Procedures shall be adopted and ☒ Yes
chemicals and hazardous steps shall be taken to prevent accidents, ☐ No
materials for disposal in injuries and the spread of diseases. ☐ N/A
accordance with applicable Policies and procedures shall be Finding Description:
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requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
Law:
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
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documents, worker and management interviews, and/or visual observations. All information is based on conditions
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requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
Law:
Are emergency exits in the HS-69 Employee housing shall be ☒ Yes
dormitory maintained in separate from production and distribution ☐ No
accordance with applicable areas, and shall comply with all ☐ N/A
standards? Applicable Laws and Regulations. Finding Description:
Law:
Are emergency exit pathways HS-70 Employee housing shall be ☒ Yes
present in the dormitory and separate from production and distribution ☐ No
maintained in accordance with areas, and shall comply with all ☐ N/A
applicable standards? Applicable Laws and Regulations. Finding Description:
Law:
Are evacuation plans present HS-71 Employee housing shall be ☒ Yes
in the dormitory, posted and separate from production and distribution ☐ No
maintained in accordance with areas, and shall comply with all ☐ N/A
applicable standards? Applicable Laws and Regulations. Finding Description:
Law:
Are emergency assembly HS-72 Employee housing shall be ☒ Yes
points present at the dormitory separate from production and distribution ☐ No
and maintained in accordance areas, and shall comply with all ☐ N/A
with applicable standards? Applicable Laws and Regulations. Finding Description:
Law:
Is emergency lighting present HS-73 Employee housing shall be ☒ Yes
in the dormitory and separate from production and distribution ☐ No
maintained in accordance with areas, and shall comply with all ☐ N/A
applicable standards? Applicable Laws and Regulations. Finding Description:
Law:
Are evacuation drills HS-74 Employee housing shall be ☒ Yes
conducted in the dormitory separate from production and distribution ☐ No
and documented in areas, and shall comply with all ☐ N/A
accordance with applicable Applicable Laws and Regulations. Finding Description:
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requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
Law:
HS-76 While reasonable rules, ☒ Yes
regulations and curfews may be ☐ No
necessary for the safety and comfort of ☐ N/A
Are employees granted Employees, Employees shall be free to Finding Description:
freedom of movement and are leave the Facility grounds during non
their personal liberties working hours. Where curfews apply and Law: ☒ Yes
respected while accessing are allowed by law, Employees shall be ☐ No
and leaving the facility- notified of the curfew and instructed on ☐ N/A
provided premises? safety risks in and around Employee Finding Description:
housing.
Foreign or migrant Employees shall not Law:
be subject to lockin/lockout policies.
☒ Yes
☐ No
Are employees free to find
☐ N/A
their own accommodation if HS-77
Finding Description:
they desire to?
Law:
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advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
4. Environmental Management
4.1 Licenses/ Permits/Certifications
Does the facility have a policy or ENV-01 Documentation includes, but is ☒ Yes
system in place to identify and not limited to licenses, permits, ☐ No
maintain applicable environmental certifications, policies and procedures, ☐ N/A
permits/ licenses/ certifications? and Employee and Facility records. Finding Description:
Law:
4.2 General Waste
ENV-07 Documentation includes, but is ☒ Yes
Is the facility in possession of
not limited to licenses, permits, ☐ No
permits and licenses for onsite
certifications, policies and procedures, ☐ N/A
waste disposal that are current and
and Employee and Facility records. Finding Description:
in accordance with applicable
standards?
Law:
☒ Yes
ENV-08 In the event that hazardous or
☐ No
Does the facility maintain an outdoor polluting materials are discharged
☐ N/A
environment free of uncontrolled improperly, appropriate authorities shall
Finding Description:
refuse? be notified and immediate action shall be
taken to correct and remediate.
Law:
4.3 Hazardous Waste
The facility does not appear to The facility generates organic and
generate, report any generation, or inorganic wastes such as oil,
ENV-10 Information only
attest to any generation of grease and suspended solids, but
hazardous waste. also has a hazardous waste site.
☒ Yes
ENV-14 All chemicals and hazardous
☐ No
Does the facility prevent the direct materials, including wastewater and solid
☐ N/A
discharge of hazardous waste into waste generated from operations, shall be
Finding Description:
the environment? handled and disposed of using
environmentally responsible practices.
Law:
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
5. Audit Ethics
5.1 Bribery Attempt
☒ Yes
☐ No
ETH-01 Any and all forms of bribery,
Was the assessment free of any ☐ N/A
corruption, deception and falsification of
bribery attempt? Finding Description:
records are strictly prohibited.
Law:
5.2 Bribery and Facilitation Payments
ETH-02 Policies and procedures shall be ☒ Yes
implemented, and management shall ☐ No
Has the facility established a
identify a person or persons at the Facility ☐ N/A
policy/ code governing bribery
or work site to be responsible for Finding Description:
and facilitation payments in
monitoring and implementing, practices to
accordance with applicable
comply with all Applicable Laws and Law:
standards?
Regulations and the Supplier Code of
Conduct.
☒ Yes
Are employees who refuse to
☐ No
participate in bribery and ETH-03 Any and all forms of bribery,
☐ N/A
facilitation payments not corruption, deception and falsification of
Finding Description:
adversely affected (e.g. demotion, records are strictly prohibited.
termination)?
Law:
5.3 Employee Interviews
☒ Yes
☐ No
Was the assessment free of ETH-04 Prior coaching of interviewees is
☐ N/A
employee coaching for the not allowed, nor is any retaliation against
Finding Description:
purpose of the facility audit? any Employee or auditor.
Law:
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
6. Facility Profile
Facility Name in Local Language: NOVAPERU SAC
Facility Address in Local Language: MZ A. G LOTE. 2 H.U. PARQUE INDUSTRIAL
Facility Contact Name: Teresa Jannet Duran Torres
Facility Phone: 994034102
Facility Fax: NA
Facility Email: jduran@novaperu.pe
6.1 Facility Access
Can you access the facility?
☒ Yes
FPR-1 Supplier shall require that the Facility’s
☐ No
management provide access to the Facility and
☐ N/A
all books and records that will allow for a
Finding Description:
comprehensive Supplier Code of Conduct audit
to be conducted, including an opportunity for
Law:
confidential and private interviews with Facility’s
Employees selected by the auditor.
6.2 Certifications
Valid certifications or stakeholder initiative
participation:
6.3 Production Profile
Industry sector: PRODUCTION OF HYDROBIOLOGICAL PRODUCTS
Principal products: Manufacture of fish products
Production processes: Reception, production process, packaging, and dispatch
% of total production for Client: NA
% of total production for other current clients: NA
Labels viewed on production floor:
Is the facility operating at full capacity? Yes
6.4 Production Capacity Reported by Management
Current: Click or tap here to enter text.
Production capacity per season: Low Season: Click or tap here to enter text.
Peak Season : Click or tap here to enter text.
Current: Click or tap here to enter text.
Number of permanent employees per season: Low Season: Click or tap here to enter text.
Peak Season : Click or tap here to enter text.
Current: Click or tap here to enter text.
Number of temporary employees per season: Low Season: Click or tap here to enter text.
Peak Season : Click or tap here to enter text.
6.5 Personnel Profile
Total number of employees (excl. contracted
136
employees):
total male 68
total female 68
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
6. Facility Profile
permanent X
temporary (facility direct hire) X
homeworkers 0
employees under the age of 18 0
foreign imported/ foreign migrant x
hired by the facility through labor brokers 0
contracted employees working in production 102
contracted employees indirectly related to
0
production (e.g. security, maintenance)
prison or convict labor 0
age youngest employee: 19
nationalities of the employees: Peruvian, Venezuelan and Spaniards
6.6 License
☒ Yes
Does the facility possess a business license?
☐ No
☐ N/A
FPR-2 Documentation includes, but is not limited
Finding Description:
to licenses, permits, certifications, policies and
procedures, and Employee and Facility records.
Law:
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
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requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
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ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
8. Management Systems
8.1 Grievance Mechanism
Does the facility maintain MSY-05 If allowed by law, anonymous ☒ Yes
grievance procedures by which and confidential methods for all ☐ No
employees can confidentially Employees to raise concerns to senior ☐ N/A
and anonymously raise issues level management at the Facility without Finding Description:
of concern to management fear of retaliation shall be provided.
without fear of reprisal or Law:
negative repercussions?
Has the facility implemented a ☒ Yes
procedure to record, track, and ☐ No
MSY-06 Employees’ submissions and
communicate progress and ☐ N/A
the progress of their resolution shall be
individuals responsible for Finding Description:
tracked and recorded.
each grievance item reported
to the facility? Law:
8.Other
8.1 Other Code of Conduct Findings
Are other labor, health and OTH-01 Client expects its Suppliers and ☒ Yes
safety, environmental, ethics, Facilities to comply, at a minimum, with ☐ No
supply chain, and all applicable labor, employment, health ☐ N/A
management systems and safety, and environmental laws and Finding Description:
practices in compliance with regulations of the country where the
the Supplier Code of Conduct? Merchandise is produced. Law:
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Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
Labor
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Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
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Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
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Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
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Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
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Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
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documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
Luminaires Kitchen
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contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
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Facility Profile
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contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
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Other
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.
ASSESSMENT REPORT
Facility Name: NOVAPERU SAC Audited On: MARCH 28, 2023
9. Pictures
This report contains privileged or confidential information and cannot be distributed without Client consent. This report
contains information based on a defined scope informed by client requirements gathered through a sampling of:
documents, worker and management interviews, and/or visual observations. All information is based on conditions
during the specific assessment date(s), and does not guarantee compliance to law, industry standards, or client
requirements. Furthermore, all information referencing law is provided in a limited scope, and does not constitute legal
advice.