2014-07-22 Rec Report (Revised) (Bangladesh) Accordia 05-24-14

WRAP CERTIFICATION PROGRAM
Facility Certification Recommendation
Monitor Report No. EDSL07042014 Factory’s WRAP ID No. 12999
To: WRAP Certification Board
We have conducted an independent compliance assessment of the facility listed below. As per WRAP
Certification Program requirements, we find that practices consistent with the WRAP Production Principles
have been in place for a period of not less than ninety (90) days prior to the inspection below.
Our independent assessment was made in conformance with the criteria of the WRAP Facility Self-
Assessment Handbook and the WRAP Monitors Manual, and done in keeping with the WRAP Policies for
Recognition of Monitoring Partners.
On 24-05-2014 Accordia Global Compliance Group, performed the

(Date of final inspection) (Monitoring firm)
WRAP compliance evaluation visit on the facility:
Eve Dress Shirts Ltd. (Bangladesh)

(Name and country of facility)
and hereby recommends it for certification under the WRAP Certification Program.
Md. Rokibul Islam 24 May 2014

Name of Independent Lead Monitor Date
Richard Ingrao
_____________________________________ ______________________
Authorized Signature for Independent Monitoring Firm Name of Authorizing Official
Date of Initial Compliance Visit: 8 April 2014

Date(s) of Corrective Action Plan Visit(s), (if relevant): ______________
Document Name: Facility Certification Recommendation

Issue Date: April 2010 Document Owner: Director of Compliance
Internal Audit CAP
Date.:. 17.04.2014
SL Non Compliance Issues Management Complete Date

No. Comments
01 Out of 22 fan
We will replace that 01
1 regulator is broken in 02 days
fan regulator
1st floor sewing section.
Sewing line no. 07 is We will keep clean our
2 01 day
not clean all sewing line
01 out of 08 toilet
We will re[lace that 01
03 water tap is broken in 01 day
1St water tap
floor male toilet
03
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SL• Nc ............. Particulars . ...&.........___Observation"
. Scoring
____ ____ Remarks
____ ________
N/A yes No
Fire Related Mater
Fire Bells are easily Accessible & clearly labeled & Identified
01
VIUMOM 7k7w 9fT13VqM t 5T 'imi 5fl 1NT '3 t gIc i
Required number of fire exitinguisher are placed in floor (As per Law 1 for 1000 sqm)
02
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Fire Extinguisher is Accessible placed according to country law properly marked & inspected.
03
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Evackuation Plan are Posted on every floor in native language
04
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Workers are aware about evacuation plan
05
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Does Organization Maintain Monthly Fire Drill?
06
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Fire Drill Record is propedy Maintained

07
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Fire Hose Pipe installed is working properly
08
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Trained Worker is available in the floor about fire hose pipe
09
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Emergency Exit Sign are visible with English & Local Language
10
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Does Emergency Exit light are connected with the Solar.
11
Are Emergency light installed in proper area / Location
12
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Personal Safety Related Matter
Metal Hand Gloves Supplied to the cutting Dept
01
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Worker of cutting Room Using Metal Hand Gloves
02
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Hand Gloves are fit With Hand
03 ___ ____ __ .
Needle Guard are properly fixed & in use
04
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* Qbservation ; ri Rernaks ,
Particu1ars' '-r- N
I '-y" Yes No N/A yes,
Rubber Mat & Eye Protector are available with the machine.
kii fl t Cff1rM1WMT ijcij 1% c*1t1 it I
Ferst Aid box accessible with contents as per the law.
06
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Electrical Related Matter
Electrical equipment wiring & outlets are properly set up, run, protected from elements
01
z1r qmr, 'snft .s fficfiir ft ?Ira, 51t ''M, 1, '3 1°ni W FFM
Individual electrical equipment such as work station lighting, sewing machines & Iron properly wired so
02 as not to interfere With'vork of worker
tP W1T lci c'ajcIt 1fc'bjcl TTTZT tiic fl licM ik'ti ' ¶tI1t gç' r 911
Electrical switch, socket, etc seen ok & safety 01 Cli P d 22 rc
03 -v brco)ç 'n- u i4 F oorr ec
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Fuse breaker boxes labeled closed at all times & accessible
04
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Are cutting machineselectrical lines properly connected?
05
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Environment
Adequate ventilation in production area maintenance, packing floor.
01
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Outside drainage & wastage area are clean & ditty.
02 cqicz.cii frWt19 '3 3Jt 3WU fi f1lq '8 iRwa I
All extraction systems where filled are functioning in other area of the production floor.
03 ic'°i ftiv'R -Vi1 R tvt199 cski °f4T1t Uflt91 q1M I
Broken needle register maintaining & broken needle instruction posted clearly visible at all production.
04
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Does company have environrnaentel certificate form government?
0-5 reIC f* ctw ',ri4t 'tfttM ?HW 'oc?
Does environmental heajth &safety committee conduct meeting & keep meeting minutes.
06
/
I Observation Scoring Remarks
SL Noj Particulars
V?
House keeping & material handling
Aisles are rightly marked with visible color?
01
i' °wi 'TFt n ki 1rs rn 7cqw fin?
Aisles mark is bloccked with carton/garbage?
02
ccti i?i t ciica17 WftU4Thi 'qc?
Stairs have proper rails, illuminated and clear of obstructions?
03 ___
Fired extinguisher is blocked with carton or othr materials.

04 flU tflIRf*RI?
I'Zg9 cqltg
worker personal items kept in designated area
05 I
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Electrical lines a& light fittings close to racks fabrics to be checked
06 ____
Fabric & materials are cleans & free from dirty

07 11 '°OTR 4O( Tq 7kTu
Are the stores clean & free from insects dirty
08 il mst cs aw
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Health & safety related matter
Safe drinking water supplied at production floor
01
Drinking water testing for any authorized organization

02 aii k1cd*91?
nInhIick
Drinking water test for available for work station
03
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Production floor clean & hygienic Seci Li iw- Mo
04 'Silljfl? 'V E CI
Are there adequate no of toilets ? Are there cleaned properly? 0101 4 4- —0 & t 0u2. a4&rc-t4
05
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Are the floor & other areas of factory is clean/Mopped/dry?
06 Pi1'& c'wi 74 fRI?
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Covered rubbish bihs. are .cleared daily?
07
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All toilets are neat & clean ?
08
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Observation Scoring _Remarks
/ SL. No particulars Yes j No N!A INo
Security Related Matter
Are Contoiner/ Coverdvan loading after Seven Point Check by Security lncharge
t kT fr
01 ffifcfIii 'Qiwt rnI CP 4tlll cit ItiS fl l'ilil tW cQdN/t1' SWt C'11I
02 unauthorized person entrance at container/ coverdvan loading time?
WS C9'tBTT flfr?
cM/5l'iH cnft 'M Prn 'QBPc g$1R3' 1'T S
Store Incharge & Security lncharge are do Jointly Bolt sealed after loading exportable goods in
I container/Coverdvan _______ _____ _____
03 ' ciS 31114 ¶4 T4 Q'*ie pr;s .101tc CV4 7021 /
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04 Seven Point check Ihspéction record are keep in register? - y

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Are information Access Control Policy & Procedure Implementation? -
05 .piqi aff{ cjf43 111k ifrk'i rfry
Observation Remarks
Particulars Yes
Others
Personal file maintain with legal! relevant documents

01 ejQjq ,jcq jfc(.'1i Pen *rM '9
02 Company has one MBBS doctors & nurse
rIi 4ie1 2M '3 21fWT ciftc1 fr 'U?
03 Are the facility maintains 48 Hrs, of work in a week & 02 Firs. 03 a day
i 7r= 8b W1 T1 'ul4. 4Si Ok Ss r$ flfi P1T tW fr
04 Is there any child labor is working below of 18
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OS Is the factory paying minimm wages as per government law? FS
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Auditor Signature & ate
Signature & Chop

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Facility Audit Report
Audit Details
WRAP Registration #: 12999
Monitor REPORT #: EDSL07042014
Report Type: Recommendation CAP
Audit Type: First-time certification Re-certification CAP follow up Desktop PCA
st th th th
Audit Date(s): 1 audit: 7 April 2014 & 8 April 2014 Follow up 1: 24 May 2014 Desktop Follow
up 2 Follow up 3
Was the audit unannounced? Yes No If No, please state the reason (s) why:
Was the Facility’s Self- Yes No

Assessmentreviewed by the lead auditor If No, why not?
before the audit?
Monitoring firm name and address: Accordia Global Compliance Group
House # 15/A, Road # 8, Gulshan 1, Dhaka, Bangladesh.
Auditor Name(s) and role(s): Lead auditor: Md. Rokibul Islam
Audit team members: Abdullah Al Maruf, Nazia Nusrat.
Technical experts:
Trainee auditors*:Amin Sharif
Others:
* Trainee auditors are only allowed to observe WRAP audits; they are not allowed to take any active
part in the audit. Only WRAP accredited auditors’ time will count towards the man-day requirements
for the audit.
Report written by: Md. Rokibul Islam
Report reviewed by: Bob Green
Report issue date: 12 Apr 2014
Time in and out of the facility: Day 1 in: 09:30am Day 2 in 08:40amDay 3 in Day 4 in
Day 1 out 03:20pm Day 2 out 04:30pmDay 3 out Day 4 out
Total number of man-days for this audit: 3.5
If a follow up audit, was a facility tour Yes No
conducted? If No, why not? Desktop Follow up
Facility Name: Eve Dress-Shirts Ltd.
Country: Bangladesh
Facility Main Contact and Title: Nurul Abrar
Director
Who signed and agreed CAP? Jahangir Kabir
(Name and title): Manager Compliance
Full Address of Site covered in this Ashulia, Savar, Dhaka- 1341
audit:
Registered Business name and address Eve Dress-Shirts Ltd.
(in English, and, if needed, local
language): Ashulia, Savar, Dhaka- 1341
Are these the same as the facility name and address covered in this audit?
Yes No
If No, please explain:
Applicable business and other legally Trade License: 85(2013/15), Issued Ashulia Union Porishad, Issue date: 6th July 2014;
required license numbers: Valid till: 30th June 2015
Document Name: WRAP Audit Report

Issue Date: September 2013 1
Fire License Dhaka- DD/Dhaka/ 19040/2005, Issued by Deputy Director, Fire Service &
Civil Defense Authority Renew date: 1stth July 2013; Valid till: 30th June 2014 applied for
the renewal 26th June 2014
Export License: Raw 80110, Renew date: 03th July 2013 valid till:30th June 2014 applied
for the renewal
Import License: Ba- 0164257, Renew date: 03th July 2013 valid till:30th June 2014 applied
for the renewal
EPB: BD 04705 Renew date: 1stth July 2013; valid till 30th June 20142014 applied for the
renewal
Certificate of Incorporation: C- 56540(3223)/05
Customs & Bond License: 704/CUS-SBW/2006 Renew Date 12th October 2013 and Bond
license renewal fee covers 2 years.
BGMEA Membership: # 4173 Renew date: 26th January 2014; Valid till: 31st December
2014
Group Insurance Certificate Number: SLICL-514, Issue date: 8th May 2014 every two
months interval employee update list provided, Valid till: 06th May 2015
Factory License: 12706/Dhaka. Renew date: 19th December 2013, Valid till: 31st
December 2014
Boiler License: Ba:Bo: 4196. Renew date: 10th February 2014 Valid till: 10th August 2014
Boiler Operator: Cert No: 2010/122/3160; 2nd division.
BERC: Bangladesh Energy Regulatory Commission. Cert No: LWC-0025/0036/1061,

Renew date: 28th April 2013 Valid till: 11th April 2014. Facility already applied for the
renewal certificate.
Facility Phone #: (+88)-02-7741720

Site E-Mail: jahangir@evegroupbd.com
Products / Activities at site e.g. garment Woven Garments.
manufacture, packing, service, etc.
(please state):
Audit results reviewed with facility Yes No
management? If No, please explain:

Policy and Procedures Table
Was the facility in compliance with the requirement to have:

Policy and procedures Written Policies? Written Procedures?
1 Compliance with Laws and Workplace Regulations Yes No Yes No
2 Prohibition of Forced Labor Yes No Yes No
3 Prohibition of Child Labor Yes No Yes No
4 Prohibition of Harassment or Abuse Yes No Yes No
5 Compensation and Benefits Yes No Yes No
6 Hours of Work Yes No Yes No
7 Prohibition of Discrimination Yes No Yes No
8 Health and Safety Yes No Yes No
9 Freedom of Association and Collective Bargaining Yes No Yes No
10 Environment Yes No Yes No
11 Customs Compliance Yes No Yes No
12 Security Yes No Yes No

Non-Compliance Table
Area of Non-Conformity
Issue (Only check box when there is a non-conformity)
WRAP Principles Local or National Law
1 Compliance with Laws and Workplace Regulations
2 Prohibition of Forced Labor
3 Prohibition of Child Labor
4 Prohibition of Harassment or Abuse
5 Compensation and Benefits
6 Hours of Work
7 Prohibition of Discrimination
8 Health and Safety
9 Freedom of Association and Collective Bargaining
10 Environment
11 Customs Compliance
12 Security
Historic Non-Compliance Table
Area of Non-Conformity
Issue (Only check box when there is a non-conformity)
WRAP Principles Local or National
Law
1 Compliance with Laws and Workplace Regulations
2 Prohibition of Forced Labor
3 Prohibition of Child Labor
4 Prohibition of Harassment or Abuse
5 Compensation and Benefits
6 Hours of Work
7 Prohibition of Discrimination
8 Health and Safety
9 Freedom of Association and Collective Bargaining
10 Environment
11 Customs Compliance
12 Security

Audit Overview
Site Description:
(Include size, location, age, structure, number of buildings)
Full description of the building(s) and surroundings:
The company is located in Ashulia Savar, Dhaka which is rural area. Though it is a rural area there are various type factories
in this Ashulia area. For this area, approving authority is RAJUK (Rajdhani Unnoyon Kartripokkha: Capital City
Development Authority), Authorized Officer RAJUK.
In the compound:
There is two buildings, one is 07 storied concrete building, where Eve Dress - Shirts Ltd. is operating ground to 3rd floor, 4th
floor to 5th floor is for Eve Garments Ltd. Which operation is not started yet. And another 3 shade building. And another 3
storied under construction building.
Total 121,000 sq. ft. area covered. Fire License covered all area.
Building 1:
Floors Operations/Activity Observed Declared in Approved Layout
Gound Floor Cutting section, Cutting Pass Check room, Cutting section, Cutting Pass Check room,
Embroidery section, Sample section, Bonded Embroidery section, Sample section, Bonded
ware house, Medical room, Admin Office, ware house, Medical room, Laboratory room,
Accessories room, Compliance room, Time Accessories room, Compliance room, Time
section, Office dinning, Fabric Inspection section, Office dinning, Fabric Inspection
room. room.
1st Floor Sewing section (total 6 line), Finishing, Office Sewing section (total 6 line), Finishing, Office
room, Spot Removing room, Maintenance room, Spot Removing room, Maintenance
room room
2nd Floor Sewing section (total 3 line), Finishing, Sewing section (total 6 line), Finishing,
Laboratory room, Spot Removing room, Laboratory room, Spot Removing room,
3rd Floor Packing section, Fusing section, Bonded ware Packing section, Fusing section, Bonded ware
house, Accessories store, Training room, Office house, Accessories store, Training room,
Office
4th Floor Ready for Eve Garments Ltd which operation Eve Garments Ltd.
is not started yet.
5th Floor Dining 35 % Eve Garments Ltd.
6th floor Roof Top Corporate office 27% and 73% are free Corporate office
Note: In the ground floor, declare laboratory room is actually operating as admin office. And also observed that in 5th floor
total floor is declare for Eve Garments Ltd. But 35% is using Eve Dress – Shirts Ltd. For dining.
Building 2:
Ground Floor: Generator,
1st Floor: Under contraction.
2nd Floor: Under contraction.
Shade 1:
Boiler

Shade 2:
Childcare
Shade 3:
Solid Wastage
Building Approval:
Both 3 storied and 7 Storied Building approved with roof top and currently all floors have been constructed and operated
only ground to 3rd floor & 35% of the 5th floor and 27% of 6th floor (rooftop) . The approval is for Commercial Building.
Building is approved by Chairman, Ashulia Union Porishad. Approval covers all the floor currently constructed and in use.
Total area covered 121000 sq. ft.(Including all shades.)
Approval Date: 17th May 2005
NOTE: It was observed that, the facility is under the RAJUK DAP (Detail Area Plan) area. Facility applied for RAJUK
approval on 10th May 2013 And RAJUK Concern authority already visited the factory, but the factory didn’t get the
approval yet. As the original approval copy is under RAJUK observation, so facility did not able to show the original copy
to the auditors.
It was observed that facility did a third party building inspection by Unicorn Service Ltd. Engr Shaikh Monirul Islam (IEB-
23323) conclude in his report that the structural stability of the building is safe for the operation of the existing garments
factory activities.
Factory is a member of Alliance, and Alliance already done Initial Onsite Electrical Assessment and given a
ECAP(Electrical Corrective Action Plan) for Immediate action and noted all the minor issue. Date: 31st March 2014
Layout Approval:
The operations and activities carried out on all floors and roof top were found as per the layout.
Eve Dress - Shirts Ltd. Building layout approved from Department of Factory & Establishment, Bangladesh by Md. Abul
Hossain (Chief Inspector), approval date: 23rd January 2014
Fire License:
Fire License has been issued by Bangladesh Fire Service and Civil Defence Authority, (Deputy Director, Bangladesh Fire
Service and Civil Defence Authority) and is valid till 30th June 2014.
Fire license coveres all floors of the Eve Dress Shirts Ltd. (including roof top, description given above). Total area covered
for Eve Dress Shirts Ltd. Is 76000 sft & for Eve Garments Ltd. 45000 sft.
Number of years facility has been in operation at this location:
Factory established on 2006 and in operation for the last 8 years.
Does this facility share a building with other businesses? If yes, do they conduct joint evacuation drills? If no joint
evacuation drills were conducted, does the factory have plans to do so? No because sister concern Eve Garments Ltd is not
started operation yet.
If a rectification factory, have there been any changes since the last audit in the following categories:
a. Factory address/location? –N/A
b. Number of employees? – 323
c. Square footage size? Last year was in operation only ground to 1st floor now added 2nd floor to 3rd floor & 35% of
the 5th floor and 27% of 7th floor (rooftop). And all the floors are approved in the layout plan.

What were the overall attitudes of:
a. Management?- Positive & Co-operative: Management Personnel are well aware about the legal requirements of
social compliance. During the audit it was found that manager’s intension is positive and cooperative towards this
audit.
Additional auditor remarks:
Workers are found aware about their rights and organizational practices and happy with the management approach as they
are getting on time salary, medical facility, child care facility, attendance bonus, festival bonus, paid leave and other
statutory benefits. They are happy with the behavior of management. No negative comments came in the interview from the
workers.
Management Personnel are well aware about the legal requirements of social compliance. During the audit it was found that
manager’s intension is positive and cooperative towards this WRAP Audit and they have taken all the observations very
positively and committed to take action against the observations.
Process Overview:
(Include products being produced, main operations, number of production lines, chemicals – either for production, cleaning
or fuel – used, main equipment used)
Process: Cutting, Embroidery, Sewing, Ironing, QC and Finishing.
The factory produce Woven (top) items.
Per month production capacity 220,000 Pcs per month
Production Line: 9
Chemical use:
Machine Oil in maintenance for spot lifter 833 Spot removing.
List of Machinery:
Single Needle Lock Stitch, Two Needle Lock Stitch, Single Needle Chainstitch, Three Needle Chian Stitch, Eye-Let Hole
One Step Zigzag,Over Lock, Thread Sucker Mechine, Flat Lock Machine, Top Centre Machine, Button Hole Machine, Bar
Tack Machine, Eyelet Hole Machine, Chain Stich Machine, Pocket Design, Cuff colar Machine, Saddle Stich, Auto
Strapping Machine, Fusing Machine, Label Heat Seal Machine, Pipeing Cutter Machine, Metal Detector Machine, Sanap
B/A Machine, Cutting Machine, Steam Iron, Polo Finisher, Tread Sucking M/C, Belco Tape Cut etc.
Worker analysis
Permanent Temporary Migrant workers Agency Home
(domestic or foreign) workers
Worker numbers (male) 375 X X X x
Worker numbers (female) 667 X X X x
Total manpower (including other (1042+76+25) = 1143
personnel)

Other personnel
Management 3rd party Security Agency Agency Others (please state)
service personnel cleaners canteen staff
providers
76 25 - - -
Worker interviews conducted
Permanent Temporary Migrant workers Agency Home workers

(domestic or foreign)
Number of individual interviews 17 N/A N/A N/A N/A
Number of groups interviewed 3*6= 18 N/A N/A N/A N/A
Site information
Month(s) of peak season Round the Normal Work Days: Saturday to Thursday and
(if applicable): year same e.g. Mon ─Sat Friday is weekly holiday.
Were appropriate records available to verify Yes No
hours of worker and wage compliance?
Describe nature of any inconsistencies found: Poor record keeping No records Multiple records
What was management’s attitude in response Management was positive minded. Specially regarding new requirement
to an inconsistency finding, if any? which is raised as Observation management informed they will take
required action.
What is the level of lowest wages paid? Below legal minimum At legal minimum Above legal
minimum
What is the % of piece rate workers? N/A
Are the correct overtime premiums paid? Yes No
Is there any night production work at the Yes No
facility?
What is the % of workers living in facility N/A
provided accommodation?
Age of youngest worker found: Above 18
Are workers under 18 subject to hazardous Yes No
work assignments?
What form of worker representation is there Union (name) Worker Committee Other ( Worker
on site? Participate Committee)
If workers have grievances, how do they bring Grievance boxes have been placed. It opened once a week i.e. every
them about to the facility management? Saturday. If any type of complaint came from worker then the complaint
is noted in the complaint register.
The company has an open door policy. Workers are aware of Grievance
procedure.
If suggestion box(es) are used, where are they Toilets.
located?

Is internal system monitoring conducted by Yes No
the facility on a regular basis?

PRINCIPLE 1
COMPLIANCE WITH LAWS AND WORKPLACE REGULATIONS
Objective Evidence/Comments
AUDIT QUESTIONS YES NO NA If a non-conformity is raised please state N/C

number and document the N/C at the end of
this section.
The facility obtains current information on local

and national laws and regulations concerning
WRAP principles through training program
and posters posted on production floors in
1.1 Does the facility obtain current information on
Notice boards and in front of main entries.
all relevant laws and regulations concerning each of
Responsible Person for communicating changes
the Principles and incorporate this information in its
of laws and regulations and incorporating in the
business practices?
business practices. Factory had copies of
Labour Law 2006, Customs Act 1969 &
Bangladesh Environment Conservation Act,
1995 and SRO No. 237-Law/2007.
1.1a Does the facility have written policies and Social Manager System Policy and Procedure –
procedures for current information on all relevant includes policies & procedures pertaining to all
laws and regulations on each of the following 12 principles of WRAP. Each policy refers to
WRAP Principles? the applicable laws & regulations.
Compliance with Laws and Workplace Regulations
Prohibition of Forced Labor Social Manager System Policy and Procedure
Prohibition of Child Labor Social Manager System Policy and Procedure
Prohibition of Harassment or Abuse Social Manager System Policy and Procedure
Compensation and Benefits Social Manager System Policy and Procedure
Hours of Work Social Manager System Policy and Procedure
Prohibition of Discrimination Social Manager System Policy and Procedure
Health and Safety Social Manager System Policy and Procedure
Freedom of Association & Collective Bargaining Social Manager System Policy and Procedure
Environment Social Manager System Policy and Procedure
Customs Compliance Social Manager System Policy and Procedure
Security Social Manager System Policy and Procedure
Jahangir Kabir, Manager Compliance keeps

1.2 Does the facility have a qualified person close liaison with BGMEA, Labour Department
responsible for informing the facility of changes to and Environment Departments to keep the
laws and regulations, or access to current company up to date with applicable labour laws
publications on all relevant labor laws? and environmental laws. For Customs
Compliance Maruf Hasan, Manager


this section.
Merchandizing is responsible to liaison with

Customs Department.
The Procedure against WRAP Principle 1 Law

1.3 Does the facility update its practices to and Workplace Regulation describes how the
incorporate revision to existing laws and regulations policies & procedures need to be revised and
in a timely fashion? training imparted in case any applicable law or
regulation is revised.
Facility has policy to undertake Internal audit

and last Internal audit conducted on 30th march
2014 but it was noted Principle 12 of WRAP
1.4 Does the facility undertake internal monitoring
i.e. Security not covered in last Internal audit.
of its management system (internal audits) to satisfy
itself that the written procedures and processes are
Follow up Method: Desktop Date:24th May
meeting the requirements of local law and WRAP
2014
Principles?
Security part is now covered in the internal
monitoring part. Documents taken as evidence
verified & accepted.
1.5 During the previous two years, has the facility No evidence found for such notice issued to
had any notices of noncompliance levied against it factory. During worker interviews also the
(including any legal proceedings or outstanding workers did not inform of any unrest in factory
allegations concerning the facility’s operations)? or made such allegation against the factory.
The procedure requires the Jahangir Kabir,

Manager Compliance to provide training to all
concerned and also to update the Policy &
Procedure Manual of Eve Dress-Shirts Limited.
1.6a Is there a program to train relevant individuals
Facility has system to discuss this issue with
regarding any new laws or revisions to existing
Mid Management and Changes are
laws and regulations?
communicated to the WPC to further convey
the changes to all workers. Welfare Officer is
responsible to communicate with all workers as
part of regular training process.
1.6b Are the materials used for this purpose Training is provided against the documented
appropriate? Policy and procedure.
1.7. List the exceptions to all relevant laws, rules,

and regulations other than those specifically N/A
documented elsewhere in this report.
Social Manager System Policy and Procedure

1.8 Does the facility have a written operating policy includes policy, procedure for each WRAP
manual that includes the following: Principle. It also refers to the relevant
a. Relevant laws and regulations pertaining to applicable laws & regulations. Further detailed
the Principles? procedures (where) required have been listed in
the appendix of the Policy Manual.


this section.
The policies and procedures pertaining to the

b. The facility’s policies and procedures Principles have been documented which are
pertaining to the Principles? used for implementation and to comply with
law and workplace regulations.
The facility has a policy to review and update

the written operating procedures to comply with
existing laws and regulations as soon as any
c. Routine updates for revisions to existing
revision takes place and therefore maintains
laws and regulations?
close liaison with Bangladesh Garment
Manufacturers and Employers Association
(BGMEA) for information on changes.
Subcontracting
1.9. Does the facility sub-contract any of its Facility not doing any sub-contracting work
production operations? outside of the facility.
1.10 Does the facility sub-contract any other

Not applicable.
operations?
1.11 How has the facility informed the sub-

contractor of their obligations under the local labor Not applicable.
law and WRAP Principle requirements?
1.12 Does the facility keep evidence of how the Not applicable.
sub-contractor(s) has/have been made aware of
these requirements?
1.13 Does the facility keep receipt of sub-contractor Not applicable.

acknowledgement of these requirements?
1.14 Does the facility regularly review its list of

Not applicable.
sub-contractors to make sure it is up to date?
Best practices observed:
1. COMPLIANCE WITH LAWS

AND WORKPLACE Facilities will comply with laws and regulations in all locations
REGULATIONS where they conduct business.
Non-compliances raised against this Principle:
1. Facility has policy to undertake Internal audit and last Internal audit conducted on 30th
march 2014 but it was noted Principle 12 of WRAP i.e. Security not covered in last Internal
audit.
Follow up Method: Desktop Date:24th May 2014

Security part is now covered in the internal monitoring part. Documents taken as evidence verified & accepted.
2.
3.
4.
5.
Historic Non-compliances raised against this Principle:
1.
2.

PRINCIPLE 2
FORCED LABOR

number and document the N/C at the end of this
section.
2.1 Does the facility have a qualified person

responsible for communicating, deploying, and
Name: Jahangir Kabir, Manager Compliance.
monitoring the practices of effectively prohibiting
involuntary or forced labor?
Facility have a program and materials used to train

2.2 Does the facility have a program and materials relevant individuals, including all individuals
used to train relevant individuals, including all responsible for the hiring process, on the facility’s
individuals responsible for the hiring process, on the policies and procedures prohibiting forced or
facility’s policies and procedures prohibiting forced involuntary labor. Total member of recruitment
or involuntary labor? committee is 14. Documented training record available
of recruitment committee.
A person seeking employment in the facility is

required to send signed application form to HR &
Admin Department. After the recruitment procedure
has been Completed and if the applicant has been
selected for a job, he/she, at the time of appointment, is
given an appointment letter where he/she has to
provide a declaration that he/she is joining the factory
at his/her own free will without any undue pressure
2.3 Are all employees working at the facility from anybody. This declaration forms a part of the
voluntarily? contract and every employees has to sign before
acceptance of the job. The hiring staffs also inform
each newcomer that he/she is under no compulsion to
join the company and is also free to leave after
complying with the company regulations as per the
terms of the appointment letter. Interviews, document
review and visual walkthrough of the facility did not
reveal any form of indentured, bonded, or forced
labour.
The facility has defined a policy on freedom of

movement and allows employees to visit toilets,
2.4 Are there any indications that people's medical center, drinking water stations and to say their
movements are being restricted? prayers as and when necessary. Also it was verified
workers is free to leave facility during the lunch break.
During the worker interview verified.
Security guards only posted at locations where needed

for security purposes. Security forces are employed
only for guarding the property and personnel of the
2.5 Are there exaggerated security measures or
company. During the facility visit, no exaggerated
logistics being employed in the facility?
security measures or
Logistics were noticed. Security guard found aware
about job responsibility.


section.
2.6 Were there any overt signs of fear or exaggerated The atmosphere in the facility appeared normal and no
obedience displayed by employees during the facility sign of fear or exaggerated obedience displayed by
inspection? employees was noticed.
No such incidence was observed during factory tour.

During worker interviews the workers did not
2.7 Do security personnel act in a non-threatening complain about bad behavior by Security guards.
manner? Treating workers with respect is mentioned in security
guards’ job responsibilities. Training records of
security guards verified and found ok.
Security guards posted for normal security reasons in a

proportionately logical number, security guards found
2.8 Are security guards posted for normal security well aware about company security, force labor, child
reasons, in a proportionately logical number? labor, harassment and abuse policy. Walk through of
the facility did not reveal any excessive security being
deployed.
Doors and gates remain open during the operational

hours. Only areas where any additional security is
2.9 Are the doors and gates of the facility locked only required and normally kept under lock and key, e.g
for normal business and housing security reasons and Bonded Warehouse was found locked, all other
in compliance with applicable fire codes? exits/doors were observed to be open. Factory runs
through Saturday to Thursday and during overtime
hours as needed.
The management personnel in the facility are well

aware of the facility’s policy on forced labour and the
need to eradicate the presence of forced labour in the
facility in any form. The management staffs,
supervisors and line in-charges have signed
undertaking that they have received the facility policy,
2.10 Does the facility prohibit all relevant understood and shall obey it. Management prohibits
individuals, including any person under the facility's all section in-charges and department heads from
direction (such as security guards), from coercing unevenly persuading or unnecessarily limiting
employees in any way, or unnecessarily limiting employee’s freedom of movement except that it may
employees' freedom of movements? affect the routine production of the facility or any
danger to the assets of facility or safety of the workers
Security forces are employed only for guarding the
property and personnel of the company. During the
audit no evidence noted of coercing employees in any
way or unnecessary limiting employees’ freedom of
movement.
2.11 Is employee freedom of movement unimpeded

Verified during the worker interview and floor visit.
upon their shift's conclusion?
The appointment letter includes all terms & conditions

2.12 Does the facility require all hiring documents
related to the job and include a statement that the
(e.g. an employment application or contract) to:
worker has read and understood all terms and accept to


section.
1) include a statement affirming that applicants are join on voluntarily basis. The appointment letter is
seeking employment voluntarily and are not under signed both by the workers and the factory. Verified
threat of any penalty, randomly selected 35 personnel file.
2) be signed by each applicant, and
3) be maintained in the employee’s personnel file?
Facility obtain national ID Card or Birth Certificate as

2.13 Does the facility obtain proof that anyone
proof that workers seeking employment is legally
seeking employment is legally entitled to work in the
entitled to work in the country of manufacture in
country of manufacture in accordance with national
accordance with national immigration laws. 35
immigration laws?
personnel file verified.
2.14 Does the facility obtain an executed statement

from all labor brokers/agents used by the facility Facility obtain an executed statement from all labor
stating that the brokers/agents are not supplying labor brokers/agents. Agreement copy available with loader
that is involuntary or forced, and has the right to supplier. Training record available.
work in this country?
Security guards job description is free of any language

or terminology that may imply the existence of forced,
2.15 Are all security service agreements free of any
indentured or involuntary labour conditions.
language or terminology that may imply the
Documented training record available. Verified during
existence of forced, indentured or involuntary labor
the security guard interview. Security guard found well
conditions?
aware about Job Description and Harassment abuse
Policy.
The job description of security personnel was reviewed

which was located in policy and procedure file and
personnel file and it was noted that protection of
2.16 Do job descriptions or individual contracts for
property and personnel, goods in - goods out control,
security employees limit their tasks to normal
vehicle movement control & checking of
security matters such as protection of facility
incoming/outgoing vehicles, visitor movement control
property or facility personnel?
etc, are their normal duties. They are found to be
involved in routine security tasks only. Security guard
found well aware about job responsibility.
2.17 Does the facility issue wages/compensation

directly to employees, or in an unambiguous system
Facility issues wages/compensation directly to
that clearly shows that the employee controls the
employees.
destination of his/her wages, and access to his/her
wages?
2.18 Does the facility hold identification papers, No original documents of any nature are retained by
travel documents or passports of their employees? the company. The facility only checks Voters
If yes, please provide commentary on whether it is at Identification Card (of those who have it) for age
the request of the employee and with the employee verification purpose and is not retained. After
maintaining complete access. verification, the original is returned. Only photocopy is


section.
retained. Documents such as travel documents or

passports are not required for any purpose and are not
held by the facility. During interview it was verified
and also during inspection of personal file no evidence
of retaining any type of original documents was found.
2.19 Does the facility require any employee deposits No such system noted during the audit period, also
or have any payment withholding practices? verified in workers interview.
2.20 Is any prison labor used in this facility?

No such system noted during the audit period, also
If so, please explain & provide information on all verified in workers interview.
relevant laws and industry standard(s).
Workers and factory sign appointment letter that

2.21 Are all work contracts signed by both parties includes all terms & conditions related to employment.
(employer and employees)? 1 copy appointment letter is issued to worker and 1
For countries with at-will employment and/or no copy is retained in personnel file. This was verified
formal contracts, include a statement to that effect. during worker interviews and all workers confirmed
receipt of appointment letters.
2. FORCED LABOR Facilities will not use involuntary, forced or trafficked labor.
Forced Labor: Refer to Article 7 given in the Preamble of The Constitution of the People’s Republic
of Bangladesh and mentioned below*. Article 34(1) of the Constitution prohibits forced labour; ILO
Convention 105, Abolition of Forced Labor 1957 provides for measures to prevent compulsory or
forced labour. Chapter 10 LLA 2006 Ss 121 and 125(1), also states that wages shall be paid
regularly and prohibits methods of payment, which deprive the worker of a genuine possibility of
terminating employment.
1.
2.
3.

4.
5.
1.
2.

PRINCIPLE 3
CHILD LABOR

section.
3.1 Describe how the facility manages the hiring

process. Include how the facility documents the age Facility is keeping age verification certificates of workers as well as Voter ID
of potential employees with official country specific Card, birth Certificate, Chairman or Commissioner Certificate, and Blood
documents (e.g., birth certificates, identification Group Report. Facility declared recruitment committee of 14 members where
cards, school records and/or immigration papers, representative from each section is available beside medical officer, nurse
medical records). and compliance person also included in recruitment committee.
Employee files contain all correspondence related to

the work history of the employees, i.e. application
3.2 Does the facility obtain proof of age form to salary increment letters. So the file maintains
documentation from all potential workers and review information regarding how long an employee has been
the documentation for authenticity prior to hiring? working at the facility, verified during inspection of
randomly selected personnel files. Randomly checked
35 personnel file.
3.3 Does the facility retain proof of age for each

Facility retain proof of age for each employee and
employee and maintain the information in the
maintain the information in the employee’s personnel
employee’s personnel file for the length of time as
file for the length of time as required by law.
required by law?
3.4 Does the facility assess the authenticity of age The hiring personnel and Admin officer check the
documentation and make comparisons with sample photocopies of the documents with originals and retain
documents? the photocopies of the original document in the
personal files, and return the originals to the
Apply extra diligence in territories where child labor applicants. The facility responsible person then gives
is common. the verified sign to all Photo copies of the certificate.
3.5 Does the facility ascertain the employee’s stated

age through the interview process? As part of hiring process all workers go through age
verification and skill level process by the company’s
Verify that the physical appearance of employees own doctor and recruitment committee and obtains an
selected is consistent with their age and employment age verification certificate and employment history.
history as documented in their personnel file.
All applicants fill Job application forms providing

3.6 Does facility document the existence of an basic information that is further verified during worker
employment interview (e.g. a checklist indicating interviews. Documented checklist record available for
that the required questions were asked of the all newly recruited workers. Based on interview check
applicant)? list grade of workers and salary finalized by
recruitment committee.
3.7 Does the facility require a completed and signed All workers need to submit an application form and
employment application or contract that includes the also sign appointment letter that shows employee
date of birth (inclusive of the employee signature, photo, employee ID and also employee date that
employee identification number and signature date)? includes the date of birth or age.


section.
3.8 Has the facility formally designated a qualified

person with responsibility for communicating,
Name: Jahangir Kabir, Manager Compliance
deploying and monitoring child labor practices as
they relate to the above requirements?
Recruitment committee is responsible to ensure

employee’s assigned tasks are appropriate for their
3.9 Does the facility verify that the responsible age. Recruitment team available. And recruitment
person ensures that employee’s assigned tasks are team is well aware about company’s child labor,
appropriate for their age, where applicable? discrimination, harassment abuse, compensation and
benefits policy, Security Policy. Job description of all
workers communicated with all.
3.10 Review the facility’s communications made to

all facility employees regarding child labor policies
and procedures. Age certificate or birth certificate and national ID Card
Do communications address each of the following copy is available for all workers working in the
requirements?: company, each copy keep in the personnel file of each
worker.
3.10a. Proof of age documentation from all potential
workers prior to hiring.
3.10b. Examination of the authenticity of age Medical officer is responsible, also included this
documentation. element as training programs.
3.10c. Question the authenticity of age

Training program included.
documentation not conforming to facility practices.
Age documentation retained in employee personnel

3.10d. Age documentation retained in employee
files. Checked and verified 35 personnel files. Age
personnel files.
certificate issued by Medical officer of the Facility.
3.10e. Interviews with all prospective employees. Documented record available.
3.11 Do the programs and materials used to train Documented policy is used as training material
relevant individuals on the child labor practices, especially while briefing the individuals responsible
including all individuals responsible for the hiring for hiring so that no aspect of policy is missed. Further
process, cover the requirements to: obtain age a sample personnel file is shown to all during training
documentation, review age documentation for to make them familiar with required documentation.
authenticity, and interview all prospective Hiring policy is available and communicated with all
employees? personnel of the recruitment Team.
3.12 Do all employees in the facility appear to be All worker personnel files including age verification
above the minimum age? documents were found in respective files. During the
If a reasonable suspicion exists that there are age- monitoring visit, it was observed that the entire
borderline employees, be extremely cautious and employee population appeared to be above the age of
attentive to assessing this compliance. If you suspect 18 years. In addition, any young looking employee
the age of any individual(s) you view working in the noticed on the floor was included in the list of


section.
facility, you MUST seek to include them in the review interviews and a subsequent verification and review
process for age authentication, including employee was conducted. Checked 35 personnel randomly
interview. selected workers file.
3. CHILD LABOR
Facilities will not hire any employee under the age of 14 or under
the minimum age established by law for employment, whichever is
greater, or any employee whose employment would interfere with
compulsory schooling.
1.
2.
3.
4.
5.
1.
2.

PRINCIPLE 4
HARASSMENT OR ABUSE

section.
Included in the Social Manager System Policy and

4.1 Has the facility adopted a written policy on the Procedure and also translated in the local language.
prohibition of harassment, abuse, and corporal The facility does not engage nor support the use of
punishment? corporal punishment, mental or physical pressure and
any kind of verbal abuse.
Non-compliant behavior and management

policy/Policies towards them have been defined by
management. They have been printed in the Company
Policy Manual. The policies and procedures
discourage the use of verbalism or gestures regarding
4.2 Are the definition(s) of the non-compliant
sexual harassment towards its female staff and
behavior(s) and management policy(ies) consistent
workers. Sexual, physical, psychological harassment,
with the intent to prohibit all forms of this behavior?
threatening or insulting behaviour, verbal abuse and
cruel attitude, inhuman or degrading treatment is not
permitted. During awareness training these topics are
discussed, the policy and procedure discourages the
use of verbalism regarding sexual harassment.
4.3 Does the policy include reasonable punitive Harassment & abuse policy, grievance policy and
repercussions for non-compliance and repeated non- employee termination policy are all documented.
compliance? Management has declared that for any non-
Note: The policy must apply to the behavior of all conformance, punitive action will be taken as per the
employees with special emphasis placed upon law of the country and shall apply to all of the
supervisory personnel. employees.

person with the responsibility for communicating,
deploying, and monitoring the harassment and abuse
policies and procedures as prescribed by labor law?
4.5 Has the facility’s management signed statements

affirming their understanding of the facility’s anti-
harassment and abuse policies? Signed statement affirming understanding anti-
harassment and abuse policy is available. Under taking
Note: If the facility has not required signed collected from all mid management personnel as a part
statements in the past, evidence of statements signed of regular training program of mid management.
on a prospective basis, i.e., from a certain date
forward, is acceptable.
The policy states that all forms of harassment, abuse

4.6 Does the facility effectively prohibit all forms of
and corporal punishment are prohibited. Management
harassment, abuse, and corporal punishment through
Personnel found well aware of harassment and abuse
written policies and procedures?
policy.
4.7 Does the facility communicate the policy on the Facility communicated harassment and abuse polity to


section.
prohibition of harassment and abuse to workers and workers and third party service i.e. all suppliers,
third party services (e.g., security guards, kitchen wastage disposal company. Training included as part
services) that will have significant contact with of regular training program.
facility employees?
Suggestion boxes have been placed; suggestion and

complaint box opened once a every 15 days i.e.twice
in a month. If any type of complaint came from worker
then the complaint is noted in the complaint register.
4.8a Does the facility encourage employees to report
The company has an open door policy. Worker
instances of harassment or abuse, without fear of
training is conducted encouraging the employees to
retribution, through effective communication of
report any problem they face in the factory. This was
facility policies?
verified during interviews. Workers are aware of
Grievance procedure. Documented training record
available on the subject of Grievance Procedure also
verified in worker interview.
4.8b If any incidents of harassment or abuse were Nothing raised to note. Also verified in worker
reported, were they resolved in a timely manner? interview.
4.9 Does the facility have an effective and mandatory

program to train relevant individuals, including all
individuals responsible for the supervision of
Included in training program.
workers, on the facility’s policies and procedures
prohibiting all forms of harassment, abuse and
corporal punishment?
4.10 Are all the materials used for this purpose Documented procedures and policies, Training Manual
appropriate for this training? are used as training materials.
4.11 While inspecting the plant, were any signs noted During the facility visit and interviews session, no
of physical abuse (including but not limited to shared evidence was found of harassment, abuse or
physical characteristics evident in many workers), threatening behavior. The employees were found to be
such as: highly satisfied with facility environment and no
negative comments was offered with regards to
a. bruising? harassment or abuse.
b. obvious physical injuries (casts, or other

No such conditions were observed during the facility
corrective wraps, an exaggerated repetition of
visiting
the same medical condition)?
No such conditions were observed during the facility

c. isolated employees?
visiting
d. overt sights of corporal or psychological No such conditions were observed during the facility
punishment? visiting

4. HARASSMENT OR ABUSE Facilities will provide a work environment free of supervisory or co-
worker harassment or abuse, and free of corporal punishment in any
form.
Harassment or Abuse: In general harassment and abuse apply through criminal laws under the
provision of the Constitution of Bangladesh; however Article 32 of The Constitution of Bangladesh
states measures for protection of right to life and personal liberty.
1.
2.
3.
4.
5.
1.
2.

PRINCIPLE 5
COMPENSATION AND BENEFITS

section.
5.1 Has the facility formally designated a

qualified person with responsibility for
communicating, deploying and monitoring the
system and ensuring that the wage rates and
compensation calculations are adequately
communicated to all workers in the facility?
Facility have practices to ensure employees are

5.2 Does the facility have practices to ensure compensated consistent with their terms of
employees are compensated consistent with their employment and in accordance with local laws and
terms of employment and in accordance with regulations. Facility communicated legal salary
local laws and regulations? structure to all worker through hand book, regular
training program, and notice board.
Grade 7: 5300/-
Grade 6: 5678/-
Grade 5: 6042/-
5.3 Does the lowest record of payment by the Grade 4: 6420/-
facility meet (or exceed) the legal minimum Grade 3: 6805/-
compensation? Grade 2: 10900/-
Grade 1: 13000/-
Meets legal minimum.
The Salary structure as per law has been

5.4 Does the facility post legal minimum wage
communicated to all workers and a notice was
rates, benefit policies, and additional payment
found in all workers personnel files. Compensation
information in the native language(s) of the
policy and new salary structure was also displayed
facility workers?
on notice board in local language.
5.5 Does the facility utilize and maintain an

Attendance is done by using Time Card
organized system of record keeping?
Payroll is generated using software. Hard copy of

5.6a Does the facility produce and retain payroll payroll with revenue stamp is retained by
records to support compensation, including Department of HR and Compliance. Payroll
overtime? checked for selected 35 workers (March 2014,
May 2013, December 2013)
5.6b In the case the facility pays its employees

through wire transfers, does the facility produce
and retain proof of bank statements showing all
Salary is paid in Cash directly to the worker.
the transactions in a verifiable way?
Note: The name of the employee, salary amount,
and the date of the transaction must appear on


section.
the bank slip showing the transaction, as well as

the recipient’s bank name and account.
5.7 Does the facility provide all employees with

Pay slip is issued to all workers with detailed
a pay record or stub that lists the components of
breakdown of salary including deductions if any.
the wages paid?
5.8 Are all legally mandated withholdings (e.g.,

taxes, social security, etc) remitted to the 10 taka revenue stamp
government?
5.9 Are there any piece rate workers in the

facility?
If so, review a sampling of the documentation for Workers are paid salary on monthly basis only.
piece rate workers as compared to wage rate
workers to ensure compliance with this
Principle.
5.10 Does the facility have a written and

coherent policy on piece rate compensation and
does the piece rate compensation at least satisfy No piece rate worker in factory
the minimum compensation prescribed by law?
5.11 Do employees sign off on material counts or

Not applicable as not worker working as piece rate
random independent recounts for piece rate
condition.
systems?
5.12 Are employees provided with adequate

communication of their legally mandated Included in regular training program.
minimum compensation rights?
a. a detailed description of the employees

compensation and benefits at the time of
5.13 Does the policy communication include all employment through Worker Handbook and
of the following: Orientation Training program.
a. a detailed description of the employees
compensation and benefits at the time of b. both a written and verbal explanations of wage
employment? calculations provided at the time of employment
through Worker Handbook and Orientation
b. both a written and verbal explanations of Training program.
wage calculations provided at the time of
employment? c. a requirement that changes relating to
c. a requirement that changes relating to compensation rates or methods of wage
compensation rates or methods of wage calculations will be communicated timely and
calculations will be communicated timely effectively through Worker Handbook and
and effectively? Orientation Training program.
Documented record available.

Wages analysis:
Wage periods checked December 2013 May 2013 March 2014
Sample size 35 35 35
Legal minimum wage for standard time 5300/- 5300/- 5300/-
Actual minimum wage paid at this facility 5300/- 5300/- 5300/-
Lowest wage paid in sample 6,951.40/- 3,946.92 /- 7077.50/-
Highest wage paid in sample 10978.80/- 9175.39/- 10478.80/-
What deductions are required by law? Unauthorized absent and revenue stamp 10 taka
Have all of these been made? Yes No
Have they been forwarded to the appropriate authority? Yes No
Legal overtime premium for weekdays: Double of the Basic
Legal overtime premium for rest days: Double of the Basic
Legal overtime premium for holidays: Double of the Basic
Social Insurance analysis:

Type(s) of social insurance(s) required by local law Coverage (# of employees and % age of total)
Group Insurance 100%
5. COMPENSATION AND
BENEFITS Facilities will pay at least the minimum total compensation required
by local law, including all mandated wages, allowances & benefits.
Minimum Wage: Chapter 10 LLA 2006, establishes the process to set minimum wage rates, which are
published in the Official Government publications. The minimum wage has been set at Tk. 3000.00 salary per
month. Chapter 2 LLA 2006, Section 9(1) & (2): As per this section the factory shall maintain a register of
fines, register of deduction for damage or loss) and Register of Wages and shall be preserved for twelve
months after the date of last entry. The section gives clear guidelines about maintenance of forms of records
and registers, wage slips and master rolls.
Chapter 12 LLA 2006, Compensation for Accidents at Workplace provides for compensation against accident
of worker in workplace.
Overtime hours and overtime rate: Chapter 9 LLA 2006 S 108(1) The section requires employers to pay
covered employees not less than twice the regular rates of pay for all hours worked in excess of 8 hours in a
day or more than 48 hours in a workweek, unless the employees are otherwise exempt.
Leave & Holidays with wages: Chapter 9 LLA 2006 Ss 118-119; adult worker will be eligible for annual leave
after the completion of one years’ service at the rate of one day per 18 days of working for the next 12
months. This also provides for festival leave at least 11 days in a year; however under S 118 (3) of the same
Act S 108 states that a worker may be asked to work but s/he has to be paid the wages of two(2) full
working days, along with compensatory leave and a granted alternative day for holiday.
Workers are to have casual leave at least 10 days in a year and sick leave at least 14 days in a year for half

average wage.
1.
2.
3.
4.
5.
1.
2.

PRINCIPLE 6
HOURS OF WORK
AUDIT QUESTIONS YES NO NA

If a non-conformity is raised please state N/C number
and document the N/C at the end of this section.

deploying and monitoring that no employee works Name: Jahangir Kabir, Manager Compliance
more hours per day and per week than the legal
limits?
The facility policy on working hours, the legal

maximum working hours, overtime hours and days of
rest has been prominently displayed on all the notice
6.2 Does the facility have a program and relevant boards in the native language Bangla. Also it has been
materials to train all individuals, including all printed in the employee hand books. Periodic
individuals responsible for production coordination awareness training is held for all supervisory personnel
and scheduling, to ensure that employees work no responsible for production coordination and scheduling
more than the legal maximum, including overtime as well as those who are in supervisory roles to ensure
ceilings? that the workers are not worked more that the legal
maximum hours per day, per week and per month.
Documented training record available for workers
regarding compensation policy.
At the time of hiring, all new recruits are informed

6.3 Are all employees are made aware, at the time of
about the legal requirements and the limitations on the
hiring, of facility policies and procedures,
working hours, both regular and overtime, by
specifically the legal limitations on the maximum
Providing induction training on the policies and
hours of work per day, week and month, both regular
procedures of the facility. They are also provided a
and overtime, and the maximum number of
hand book containing all the details. Documented
consecutive days they can legally be required to
training record available for all newly recruited
work?
employees.
Factory has issued Time Card to all workers to use for

6.4 Does the facility retain time records that reflect
attendance. The attendance is recorded in the software
the day and date employees worked, the number of
During the worker interview all workers are happy
hours worked each day, and the employees’
with the factory working hour and it was noted worker
acknowledgements of the same?
aware about Time Card.
6.5 Does the facility have a written, rational and well Emergency business needs policy available.
communicated policy defining "urgent business Urgent business needs as under:
needs"?
Strike, road blockade in the city or country, Electricity
Note: The definition of 'urgent business needs’ failure, Stoppage of port, Urgent Shipment, political
cannot be vague or open ended. It must be limited to situation, Natural calamity like flood, Over rain, earth
delays/interruptions in production caused by natural quake, cyclone etc or any unforeseen circumstances, to
calamities, non-repetitive production deadlines or meet urgent shipment
unforeseen circumstances beyond the employer’s
control. A coherent and consistent rationale must be Number of days urgent business needs occurred during
evident in the definition and infrequent deployment of the past year: nothing to report.
'urgent business needs'.

AUDIT QUESTIONS YES NO NA

If a non-conformity is raised please state N/C number
and document the N/C at the end of this section.
6.6 Are notifications of maximum regular and

overtime hour policies visibly posted in the native
Displayed on notice board in local language.
language(s) of the facility's workers and management
personnel?
6.7 Are all new workers, at the time of hiring,

Facility has system to training all newly joined
required to be made aware of the facility's policies on
workers. Documented training record available.
required hours of labor?
Hours of Work Analysis
Review Periods # of Weekly avg hours Weekly max hours Frequency of occurrence of max
samples for this period for this period hours (# of workers from samples &
reviewed (including overtime) # of weeks worked at max hours per
period)
December 2013 35 53.96 Hour 60 Hour 4 times
May 2013 35 55.06 Hour 60 Hour 4 times
March 2014 35 56.26 Hour 60 Hour 4 times
Legal standard work week for this country/industry 48 Hour

Contracted standard work-week at this facility (hrs) 48 Hour
Actual standard work-week averaged over sample (hrs) 55.09 Hour
Actual weekly overtime hours (averaged over entire sample) 07.09 Hour
Range of weekly overtime hours over all workers Review period1 Review period2 Review period3
(quote highest and lowest) H 12 hrs L 0 hrs H 12 hrs L 0 hrs H 12 hrs L 0 hrs
Lowest regular weekly hours worked in sample 54 Hour
Highest regular weekly hours worked in sample 60 Hour
Legally permitted overtime hours 2 hours in a Day
Any local waivers for this site? No
6. HOURS OF WORK Hours worked each day, and days worked each week, shall not
exceed the limitations of the country’s law. Facilities will provide at
least one day off in every seven-day period, except as required to
meet urgent business needs
Maximum daily/weekly hours: Ss 100-119 LLA 2006 Chapter 9 establishes standards for minimum
wages, overtime pay.
Weekly hours are 48 hours per week with not more than 8 hours a day for adults. But S 108 provides
that a worker may work for up to 10 hours in a day. Additionally maximum total is 60 hours per

week, but average for the year shall be not be more than 56 hours per week.
No female worker can be asked to work from 10 p.m. at night till 6 a.m. at dawn without her consent.
Interval for rest, or meal: Chapter 9 LLA 2006 S 101 states: At least a one-hour break is to be given
for working more than 6 hours, or at least half an hour break is to be given for working more than 5
hours. A minimum of two breaks or above is to be given for working more than 8 hours.
Overtime hours and overtime rate: Chapter 9 LLA 2006 S 108(1) The act requires employers to pay
covered employees not less than twice times the regular rates of pay for all hours worked in excess of
8 hours in a day or more than 48 hours in a workweek, unless the employees are otherwise exempt.
1.
2.
3.
4.
5.
1.
2.

PRINCIPLE 7
DISCRIMINATION

section.
The facility has a documented antidiscrimination

policy that explicitly prohibits discrimination. It is the
7.1 Does the facility have a written policy that
company’s policy to ensure affirmative action
explicitly prohibits discrimination?
in providing equal opportunities without regard to
race, relation, creed, color, sex, age or national origin
7.2 Does the facility have procedures and practices to The facility has developed procedures and practices to
ensure compliance and remediation with the facility ensure that facility’s antidiscrimination policy is
policy? effective.
The facility has prominently posted the policy written

7.3 Does the facility have their written policy visibly in local language on factory notice boards, printed in
posted in the language(s) of the employees and employees hand book and held training programs to
management personnel? create awareness among all employees including the
management personnel.

Name: Jahangir Kabir, Manager Compliance
deploying, and monitoring the non-discrimination
policy?
Regular training programs are arranged to train

7.5 Does the facility have an effective program and relevant individuals such as management staff,
materials used to train relevant individuals, including supervisory personnel and Admin, HR & Compliance
all individuals responsible for the supervision of staff on the anti-discrimination policy and practices of
workers and for the hiring process, on their the facility. The training materials prepared by
discrimination policy and practices? responsible persons were reviewed and found
appropriate.
The management posts facility policy on all factory

notice boards, prints in employees hand book and
7.6 Are the facility’s policy, practices and procedures provides awareness training programs to all staff and
on discriminatory behavior effectively workers to create awareness on facility’s policy,
communicated to all employees? practices and procedures on discriminatory behavior. It
is observed that policy, practices and procedures have
been communicated effectively to all employees.
7.7 Does the facility effectively communicate in

writing the requirements of this Principle to third The factory is not situated in any such area. Company
parties (industrial parks, export processing zones, recruits employees directly and not through any third
free trade zones, etc.) that may recruit and screen party.
applicants its behalf?
7.8 Has the facility had any discrimination charges No discrimination charge was filed against the facility


section.
filed against it by employees, regulatory agencies or by employees, regulatory agencies or any outside
any outside agency during the past two years? agency since its inception.
If so, please provide details.
As a part of its policy on prohibition of discrimination,

7.9 Does the facility explicitly prohibit mandatory
mandatory pregnancy testing as a condition of
pregnancy testing as a condition of employment or
employment or continued employment has been
continued employment?
prohibited by the management.
During the review of salary records and other related

documents it was observed that the employees are
remunerated and promoted on the basis of their ability
7.10 Are workers with the same job and seniority to perform the job without regard to gender, age and
paid the same rate, irrespective of gender, age, or other characteristics.
other characteristics?
Worker Selection Interview form record available for
all newly recruit workers. Record kept by HR &
Compliance Department
7.11 Do all employees sign statements (statements

may be included in an employment application or
Statement signed by all employees was available in all
contract), written in the native language(s) of the
personnel files.
employees, affirming their receipt and understanding
of the facility’s antidiscrimination practices?
7. DISCRIMINATION
Facilities will employ, pay, promote, and terminate workers on the
basis of their ability to do the job, rather than on the basis of
personal characteristics or beliefs.
Discrimination: Industrial Relations Ordinance 1969, section 15 prohibits unfair labor practices on the part
of the employees. Minimum Wage Rule 1961 (Sec 14) sets the principle of equal remuneration that requires
equal wages for male and female workers engaged in similar work.
1.

2.
3.
4.
5.
1.
2.

PRINCIPLE 8
HEALTH & SAFETY
AUDIT QUESTIONS YES NO NA COMMENTARY
HEALTH & SAFETY OVERVIEW
During the factory tour it was observed that the

facility is following the applicable laws and
regulations regarding health & safety and ensuring
a safe and hazard free workplace. Emergency fire
8.1 Does the facility comply with all relevant health
alarms, fire exists, fire extinguishers, other fire
and safety laws and regulations?
fighting appliances, first aid boxes, personal protective
equipment, sanitary toilets etc. were found in proper
places and adequate quantities. And the records
verified indicated that the factory is fully compliant.
Facility established on 2005, Building approval taken

from Local Authority Ashilia Union Porishod, Savar
Dhaka date is 17/04/2005. Archtechts was Mohammad
Habib Hasan B. Arch (BUET), Rajuk Registration No:
A-2029. IAB Registration No-H-085, Engineer Was
Md. Fazlur Rahman, B.Sc. Engineer (Civil) (BUET),
8.2 Are all relevant government health, safety, and IEB Registration number - 7045. Building assessment
fire safety certificates / permits, insurance policies conducted by Private Engineering Firm Unicon
and any relevant correspondence or documents from Service Ltd. Engineer Mr. Shiek Manirul Islam, B.Sc.
government officials in order? Engineer (Civil), IEB No: 23323 date June 29, 2013
where it’s clearly mentioned that soil condition as per
Please identify and report any irregularities. soil test report on the basis of what the design has
been evaluated, also it was mentioned structarul
stability of the building is safe for the operation of the
existing garments factory activities.
Facility already applied to RAJUK on 21/05/2013. But

facility haven’t received any update from Rajuk.
Facility undertake internal monitoring of its health and

safety systems, including fire safety, to ensure it is
8.3 Does the facility undertake internal monitoring of
following the written procedures and processes and
its health and safety systems, including fire safety, to
meeting the requirements of all relevant laws.
ensure it is following the written procedures and
Frequency of internal audit is 6 month. Facility
processes and meeting the requirements of all
developed a check list for fire safety, H & S which is
relevant laws?
used to check the health and safety condition on
weekly basis.
During audit it was observed that risk assessment was

not carried out for the process operation of fusing,
8.4 Have risk assessments been carried out placket, and embroidery.
throughout the facility, including fire risk
assessments? Corrective action taken, risk assessment established
for fusing, placket and embroidery section. Copy taken
as evidence.
8.5 If there were any risks or deficiencies that were Documented record available.
identified by the health, safety, and fire risk

assessment, were they corrected?
8.6 Is a regular occupational health check arranged

Documented record available.
for hazardous job duties, if any?

person (or persons) with responsibility for
Name(s): Md. Jahangir Kabir, Manager Compliance
communicating, deploying, and monitoring all health,
safety, and fire safety policies and practices?
8.8 Does the facility properly track health, safety, and Facility properly track health, safety, and fire
fire incidents? incidents. Documented record available.
Facility have a program and materials to train relevant

8.9 Does the facility have a program and materials to
individuals, including all individuals responsible for
train relevant individuals, including all individuals
the supervision of workers, on all of the relevant
responsible for the supervision of workers, on all of
occupational health and safety. Documented training
the relevant occupational health and safety issues?
record available.
8.10 Does the facility have a written safety program, Emergency response procedure in-case of fire and
including written emergency procedures to handle earth quake and boom thread is defined etc are
natural disasters, fire safety, and emergencies and defined. Fire emergency action plan is displayed in the
industrial accidents? facility.
8.11 Are the following safety documents maintained

by the facility?
a. Health and safety reports Record available.
b. Heavy machinery inspection (boilers, Boilers, Compressors, Generator maintenance record

compressors, etc.). available.
Production related machinery inspection record

c. Maintenance reports
available.
Monthly monitoring documented record available

d. Fire extinguisher records, noting date of
which is attached with fire extinguisher. Management
inspection and expiration
informed facility has system of visual daily monitor.
Date of fire drill: 29/03/2014

e. Emergency drill records, noting date and Time: 02 min 10 second
detailed results Date of fire drill: 19/02/2014,
Time: 02 min 18 second
f. Work injury reports Accident register.
g. Clinic logs, noting date and reason for visit Patient visit record.
8.12 Have any government agencies inspected the

facility for compliance with safety and health
regulations during the past two years? No such type documented noted.
If yes, please list the findings.

8.13 Does the facility address the following

occupational health and safety needs required by the
relevant laws and regulations for the following?
a. heat stress/extreme temperatures Documented procedure and record available.
Exhaust fan for ventilating at spot removing area was

b. paint spray/spot cleaning booths
found.
c. welding safety No Welding allowed inside the factory premises
d. respirator safety No Welding allowed inside the factory premises
e. blood borne pathogen program Gas mask is available
f. hearing (noise control program) Noise lavel test report available .
g. indoor air quality Indoor air supply is enough.
h. cotton dust ventilation Ventilation fan.
i. sanitary waste disposal Wastage disposal policy and wastage disposal record
GENERAL BUILDING REQUIREMENTS
Facility was observed conforming to the requirement

in respect of building safety. Alliance had visited the
facility on 31st of March 2014 for electrical safety
assessment and will visit again on 10 April 2014 for
8.14 Does a visual inspection of the entire facility
building safety assessment.
premises suggest any concerns about the physical
It was also observed that facility had conducted the
integrity of the facility?
building structural safety assessment by a private firm
Unicon Services Ltd on June 29, 2014 at company’s
own interest. Reports showed conformity to safety
requirement.
8.15 What is the overall general appearance of this

facility:
General the factory was well maintained and kept
Excellent
clean. Emergency exits are marked, machine layout is
good with sufficient space between operating lines.
Good All floors had sufficient lighting, ventilation and space
for workers to work in a safe and healthy manner. The
Fair factory has fulltime cleaners who are continuously
cleaning the floors and toilets.
Unacceptable
8.16 Is the overall general appearance of the

maintenance shop acceptable and not in a condition Found conforming to the requirements
that can cause serious injury or harm?

8.17 Is trash properly disposed of both inside and Separate and segregated wastage area is available in
outside the facility? the ground floor.
8.18 Are the toilets and washrooms in the facility in Toilets are meeting minimum quantity required
sanitary and serviceable condition and meeting established by relevant law. Total number of toilets129
minimum quantity required established by relevant are out of 65 toilets for female and 44 toilets for male
law? and 20 toilets for staff.
8.19 Are exits unlocked during times when the

Exits were found un-blocked and free from any
facility is occupied to allow free, unobstructed exit
obstacles
from the facility?
8.20 During the facility visit, were any aisles blocked

Aisles found free from blockage.
or restricting easy access to emergency exits?
8.21a Has the facility appropriately identified areas

Facility management does not allow smoking in the
that, for fire safety purposes, should be designated as
factory.
“non-smoking”?
Inside the factory premises facility management does

8.21b. Is the facility properly enforcing the “non-
not allow smoking and also as per law of Bangladesh
smoking” policy for areas so designated?
in Open Place no one is allowed to smoke.
8.22a Does the facility maintain first aid supplies as

required by law or if no legal requirement exists, as As per legal requirement first aid supplies available.
recommended by a local medical provider?
8.22b. Are these first aid supplies available and First aid supplies were available as by the required
accessible to all areas of the facility? number and specification as per law.
8.23 Is there clean drinking water that is easily

Clean drinking water available with test report.
accessible at the facility?
8.24 Is drinking water provided at no cost to

Drinking water free to all workers.
employees?
8.25 Is the facility’s crèche/child-care area operated

Childcare room located in a separate shade.
and maintained in a safe and healthy manner?
8.26 Is the facility’s canteen/cafeteria operated and Canteen, dining operated and maintained in safe
maintained in a safe and healthy manner? healthy manner.
PERSONAL PROTECTION EQUIPMENT (PPE)
8.27 Does the facility conduct hazard assessments to Documented hazard assessment available also
determine if any PPE are required? displayed in production floor for workers awareness.
8.28 If PPE are required, is it provided to affected

Workers get PPE free of cost.
employees at no cost?
8.29 Are the PPE appropriate and adequate for the PPE Provided as per defined hazard assessments.

workers’ job and in good condition?
ELECTRICAL SAFETY
8.30 Is there a qualified electrician in the facility

Facility’s Electrical engineer, Md,. Moshiur Rahma is
responsible for maintaining electrical safety? If not,
responsible to maintaining electrical safety.
what is the facility doing to ensure electrical safety?
8.31 Does a visual inspection of the wiring indicate

the following? Cables are well protected
a. Good general condition of cabling
b. Tidy Enough tidy
c. No exposed or loose wires During the facility tour no loose wire were found
8.32 Does a visual inspection of the electrical boxes

and cabinets verify: Complete enclosures with covers of electrical boxes
and cabinets were found in facility tour.
a. Complete enclosures with covers provided?
b. Switches and outlets maintained in good Switches and outlets maintained found in good
working order? working
c. All knockouts/trips in place? All knockouts/trips are also found in place
WORKER SAFETY AWARENESS
8.33 Does the facility maintain a safety committee The safety committee was formed comprising of
comprised of workers and management, which holds management and workers.
regular meetings and keeps minutes of proceedings?
8.34 Does the facility conduct an orientation health Fire safety and health safety training conducted on
and safety and fire training for all new employees? orientation program.
8.35 Does the training cover the following in regards

to fire safety:
Included in regular training program.
a. workers are informed of the locations of fire
alarm pull and button stations
b. workers are informed of the locations of fire

extinguishers in and near their work area
c. workers have specific training concerning the

dangers of smoke inhalation
d. workers are informed of location of nearest

exits and assembly points
8.36 Is employee training conducted for first aid and

Documented training record available.
safety?

8.37 Are the first aid responders/emergency safety First aid and emergency fire team were identified by
personnel properly identified and trained? the separate dress code
Selected employees been trained on the proper use of

8.38 Have selected employees been trained on the
firefighting equipment, documented training record
proper use of firefighting equipment?
available.
8.39 Have all employees who have any contact with

chemicals been trained on how to safely handle and
Documented training record available.
dispose of the specific chemicals and eliminate fire
risk?
During facility visit it was observed that MSDS was

not found displayed for the spot lifter 833.
8.40 Are MSDS available (in appropriate
language(s)) for all chemicals used by the facility? Corrective action taken, MSDS posted for spot lifter
833. Onsite verification done Photograph taken as
evidence.
FIRE SAFETY
8.41 Does the facility have an emergency evacuation Evacuation plan posted in production floor in native
plan in the native language(s) posted in view of the language. Workers are well aware about evacuation
facility's workers? plan. Verified in workers interview.
8.42 Does the facility conduct regular emergency Date of fire drill: 29/03/2014
evacuation drills (at least semi-annual)? Time: 02 min 10 second
List at least two drill dates (whether conducted Date of fire drill: 19/02/2014,
and/or planned) Time: 02 min 18 second
8.43 Does a facility tour verify that there are an

adequate number and location of unimpeded
Sufficient exit available as per legal requirements.
emergency exits that open outwards and lead to a safe
assembly point?
8.44 Does a facility tour verify that safety equipment

are: All fire safety equipments are found in in place &
visible.
a. visible
b. appropriate in functionality and number Available as legal requirements.
c. properly distributed throughout the facility All equipments are properly distributed
d. easily accessible Fire equipments are easily accessible
e. properly mounted Also found properly mounted
All equipments are found unblocked and free of

f. unblocked and free of obstruction
obstruction
g. fire extinguishers are appropriate for the As per legal requirements available.

class(es) of fires expected in the area
8.45 Are the fire-fighting water hoses and

Tested in floor visit and found operative.
connections in usable condition?
Facility does not have auto hydrant and sprinkler heads

8.46 Does the facility have appropriate measures to neither it was required by current fire licenses.
ensure adequate water pressure for fire-fighting water Current hose rills are connected to overhead water
hoses and sprinkler systems? tank. Management has approved the plan for
implementing auto hydrant water system.
Sprinkler Valves
8.47 Do sprinkler valves appear in good working

order? It was not required by facility’s current fire license
8.48 Are all sprinkler heads kept unobstructed from

storage or other materials? It was not required by facility’s current fire license
Fire Alarm Boxes
8.49a Are fire alarms clear, unobstructed, and During the floor visit it was noted fire alarms found
identified? clean, unobstructed and identified.
As part of regular preventive maintained schedule

8.49b. Does the facility have a test schedule for
facility maintain regular monitoring system to check
all fire alarm boxes?
fire alarm boxes. Frequency of fire alarm boxes test is
State how the facility maintains this schedule.
monthly.
8.50 Are combustible scrap, debris, and waste

materials stored in covered metal receptacles, and
removed from the work site promptly? If not, explain Wastage area found properly identified &
how they are stored. segregated.
EMERGENCY EVACUATION
8.51 Are lighting and alarm systems adequate and Lighting and alarm systems adequate and fitted with
fitted with back-up systems? back-up systems. Verified during the floor visit.
8.52 Emergency Lighting
8.52a. Is appropriate lighting in place in the facility? Appropriate lighting is in place.
8.52b. Is the emergency power system working and Emergency power system found working in good
in good condition? condition.
8.52c. Does the facility regularly conduct a test to Facility regularly conducts a test to ensure the system
ensure the system is functioning properly? is functioning properly.
8.53 Stairwells
8.53a. Are all stairwell handrails in good condition? All stairwell handrails found in good condition.

8.53b. Are all stair treads in good condition? All stair treads found in good condition.
8.53c. Are all stair widths in compliance with

All stair widths in compliance with legal requirements.
requirements of all relevant laws?
8.53d. Are the stairways provided with artificial and It was noted stairways provided with artificial and
emergency lighting? emergency lighting.
8.53e. Are stairwells completely clear of

Stairwells found completely clear.
obstructions?
8.53f. Does the facility ensure stairwells are not used

Found free.
for storage?
CHEMICAL SAFETY
Facility does not require hazardous chemicals.

8.54 Does the facility have a chemical safety Only for sweing machine, machine oil are using & for
program? spot removing spot lifter 833 are using which are
defined in the chemical safety program.
8.55 Where applicable, does the facility properly

N/A
store hazardous/toxic materials?
8.56 Does the facility have the required government

N/A
storage and usage permits for chemicals, if required?
8.57 Does the facility maintain documentation for

chemical labeling (including fire safety), chemical Available in the chemical store area.
usage warnings, and proper handling instructions?
8.58 Does the facility ensure that all solvent wastes

and flammable liquids are properly stored (including Facility does not realese any solvent wastes and
being kept in closed containers when not in use) at all flammable liquid.
times and kept away from potential ignition sources?
8.59 Are the chemical storage areas free of ignition Only mechine oils are using and found stored properly
sources? no ignition sources were noticed.
8.60 Are all lamps and lights away from combustible Yes all lamps and lights are away from combustible
chemicals? chemicals
BOILER & COMPRESSOR ROOMS
8.61 Is the location of the boiler and compressor

Location of the boiler and compressor room consistent
room consistent with all relevant requirements? (If no
with all relevant requirements. Verified during the
local or national laws apply, please describe the
floor visit.
location of the boiler and compressor room.)
8.62 Are there housekeeping and maintenance Housekeeping and maintenance procedures in place
procedures in place for the boiler and compressor for the boiler. Mr. Iqbal is responsible for boiler
rooms? operation and maintenance. As per documented

procedure it was noted facility maintaining regular

monitoring system for boiler. Documented record
available.
8.63 Are there any fuel leaks? No such condition observed.
8.64 Are the boilers and compressors inspected and

Periodic record available.
serviced periodically?
8.65 Are the boiler licenses valid and authentic? Boiler license and boiler operator license available.
8.66 Is the boiler operator certificate valid and

Verified and found ok.
authentic?
DORMITORIES (If Applicable)
8.67 Are all national and local government health,

safety, and fire safety certificates / permits, insurance
policies and any relevant correspondence or N/A
documents from government officials in order for the
dormitories?
Please identify and report any irregularities.
8.68 Does the dormitory have a written safety

program, including written emergency procedures to
N/A
handle natural disasters, fire safety, and emergencies
and industrial accidents?
8.69 What is the overall general appearance of this

dormitory:
Excellent
Not Applicable.
Good
Fair
Unacceptable
8.70 Does a visual inspection suggest concerns N/A

regarding the physical integrity of the dormitory
building, proper lighting and ventilation, sanitary
toilet areas, or clean dormitory facilities?
8.71 Does the facility have an emergency evacuation N/A

plan of the dormitories in the native language(s)
posted in view of the facility's workers?
8.72 Does the facility conduct regular emergency N/A

evacuation drills (at least semi-annual) in the
dormitories?

8.73 Does a dormitory tour verify that safety N/A

equipment are:
a. visible
b. appropriate in functionality and number N/A
c. properly distributed throughout the facility N/A
d. easily accessible N/A
e. properly mounted N/A
f. unblocked and free of obstruction N/A
g. fire extinguishers are appropriate for the N/A

class(es) of fires expected in the area
8.74 Are exits unlocked during times when the N/A

dormitories are occupied to allow free, unobstructed
exit from the dormitories?
8.75 During the dormitory visit, were any aisles

N/A
blocked or restricting easy access to emergency
exits?
8.76 Emergency Lighting
8.76a. Is appropriate lighting in place in the N/A

dormitory?
8.76b. Is the emergency power system working N/A

and in good condition?
8.76c. Does the facility regularly conduct a test N/A

to ensure the system is functioning properly?
8.77 Are all stairwell handrails in good condition N/A

within the dormitories?
8.78 Are all stair treads in good condition within the N/A
dormitories?
8.79 Are the stairways in the dormitories provided N/A

with artificial and emergency lighting?
8.80a Are stairwells in the dormitories completely N/A

clear of obstructions?
8.80b. Does the facility ensure stairwells in the N/A

dormitories are not used for storage?

8.81 Are the assembly points for the dormitories N/A

located in safe locations?
8.82 Is there clean drinking water that is easily N/A

accessible in the dormitories?
8.83 Are the toilets and washrooms in the dormitories N/A

in sanitary and in serviceable condition?
8.84 Is trash properly disposed of both inside and N/A

outside the dormitory facilities?
8. HEALTH & SAFETY Facilities will provide a safe and healthy work environment. Where
residential housing is provided for workers, facilities will provide
safe and healthy housing.
1. Bangladesh local law 2006.

2. Bangladesh Local law 1965.
3. Bangladesh Factory Rules 1979.
4. Bangladesh Construction Act 2008.
5. Bangladesh national building code 2006.
6. A Compilation Environmental laws.
7. BGMEA notice.
8. Fire Defense Rules 1999.
9. The Bangladesh power Development Boards Order 1972( President order no 59)
10. Fire prevention & oblation law 2003
11. Latest fire license.
1.

2.

PRINCIPLE 9
FREEDOM OF ASSOCIATION & COLLECTIVE BARGAINING
9.1 Does the facility have written policies and The management has documented policy, procedures
procedures that recognize and respect the right of and practices to recognize and respect the lawful
employees to exercise their lawful rights of free rights of free association and collective bargaining of
association? workers.
9.2 Has the facility designated a qualified person

with responsibility for communicating, deploying
and monitoring the freedom of association practices Name: Jahangir Kabir, Manager Compliance
as prescribed by labor law?
9.3 Does the facility have a union, association or

collective representation of employees? No-union in the factory but company has a 23
members (07 from Management, 16 from Workers)
Note: You are required to indicate whether there
Worker participation Committee (WPC) has been
exists or not an informal or formal association of
formed to settle the issues of the workers and to
employees. If a lawful association of employees
convey any complain/demand to the top
exists, include a representative of such association
management.
in the interview process.
9.4 If a union or collective association which

represents the employees exists, does the facility
consult with the worker representatives on any
N/A
issues that are a requirement by law such as facility
disclosures, mass lay-offs, restructuring of the
business etc.?
9.5 If the workers do have an organized group that

addresses workplace issues, does this workers’ Workers Participation Committee (WPC) operates in
group operate free from coercion or illegal the facility free from coercion or illegal restrictions to
restrictions to its operations? its operations.
9.6 If a lawful association of employees exists, is

there any bargaining agreement or labor- No
management negotiation on workplace issues?
9.7 Are there formal communication procedures

Documented procedure available.
between worker representatives and management?
9.8 Does the facility enter into discussions with the Discussion with the worker representative is an open
workers representatives in an open manner and manner, after the meeting, minutes circulated in the
within the terms of local law? notice board.
Frequency of Meeting is monthly. Meeting minutes

9.9 Are the minutes of facility / worker
displayed on the notice board to communicate with
representative meetings documented and available
all workers, also facility has a system to use PA
to the workers?
system to communicate easily to all workers.
Workers representatives elected on a free and

9.10 Are workers representatives elected on a free
confidential basis by the workers.

and confidential basis by the workers?

If not, what is the election process?
9.11 Does the facility discriminate against

employees who form or participate in lawful No
associations?
9.12 Does the facility discriminate against those

who choose not to join any association? No
9.13 Does the facility communicate its policies and

practices pertaining to this Principle to all facility
employees and third parties (e.g., free zone office
services, employment agencies) that may perform
recruitment or screening of applicants? Facility is communicating its policies and practices
pertaining to this Principle to all facility employees.
a. Facility Employees
b. Third Parties
9. FREEDOM OF ASSOCIATION Facilities will recognize and respect the right of employees to
& COLLECTIVE BARGAINING exercise their lawful rights of free association and collective
bargaining.
Freedom of Association and Collective Bargaining: Article 34 of The Constitution of Bangladesh
states measures for freedom of association. However if and when the country is in a state of emergency trade
unions cannot be formed, refer S 4 of the EMERGENCY ORDINANCE 2007 RULE, published by the
Bangladesh Gazette as of Thursday, 25th MARCH 2007.
1.
2.
3.

4.
5.
1.
2.

PRINCIPLE 10
ENVIRONMENT
10.1 Does the facility have an environmental

Environmental management system is available.
management system relevant to its industry?

deploying, and monitoring the environment practices Name: Jahangir Kabir, Manager Compliance
elaborated upon in the environmental management
system?
Training program available for material safety.

10.3 Does the facility have a program and materials
Documented training record available. All workers
to train relevant individuals on each practice of the
related with chemical handling are well aware about
environmental management system?
chemical safety program.
10.4 Does the facility assess its ability to prevent and

control harmful releases of industrial waste into the There is no process in the factory that would generate
environment as a part of the environmental any harmful releases.
management system?
10.5 Does the facility maintain a detailed plan for

There is no process in the factory that would generate
handling accidental release or discharge of
any harmful releases.
environmentally dangerous materials?
10.6 Does the facility maintain records of emission There is no process in the factory that would generate
events? any harmful releases.
10.7 Does the facility’s environmental management

system address where and how solid, chemical, Separate wastage area available.
sanitary, and wastewater substances are disposed of?
10.8 Does a review of all local government

environmental inspection reports,
certificates/permits, notices of deficiencies, and
corrective action notices or plans held by the facility,
as well as any correspondence from government N/A
officials, reveal any irregularities?
If so, please comment on how the facility has
addressed them.
Local and national laws and regulation displayed in the

10.9 Does the facility adequately communicate to all
notice board. As applicable to the facility processes,
facility employees the relevant local and national
the management communicates to the employees the
laws and regulations as well as pertinent facility
relevant local and national laws and regulations
procedures concerning the environment Principle?
through training programs.

10. ENVIRONMENT Facilities will comply with environmental rules, regulations and
standards applicable to their operations, and will observe
environmentally conscious practices in all locations where they
operate.
Environment: The Environmental Court Law 2000, Bangladesh Environmental Conservation Act 1995 &
Rules 1997 provides for the conservation of the environment and improvement, control and mitigation of
environmental pollution.
1.
2.
3.
4.
5.
1.
2.

PRINCIPLE 11
CUSTOMS COMPLIANCE
11.1 Does the facility keep copies of all

Customs Compliance Act
applicable customs laws and regulations?
11.2 Do the facility’s policies and procedures on

customs compliance cover the following
requirements?
a. Facility complies with all applicable
The company policy is documented and is part of
customs laws and maintains practices to
Polices On Compliance & Human Rights It addresses
comply with customs laws regarding illegal
all requirements of WRAP Principle 11
transshipment of products (in the event
possible illegal transshipment activity,
appropriate host government agency will be
notified).
The style and PO numbers are stated on all documents

b. Monitors its productions on a per style
used to control from receipt of raw materials to
basis.
delivery of finished goods.
c. Traces country of origin using records

such as production, shipping, verification The policy lists documents maintained throughout the
reports, quality control reports, and confirmation of order till delivery of finished goods.
individual piecework sheets, for all inputs.
d. Verifies production on an on-going basis

Production reports are maintained.
on-site and at sub-contracting facilities.
e. Maintains a facility machine inventory Up to date list of Machines was available and is
and updates it annually. regularly updated.
f. Ensures that the proper category

Product category designation is made of carton
designation is determined for all goods
labeling.
destined for the US market.
Detailed process control and monitoring records were

11.3 Does the facility maintain an organized available throughout the production process. PO/Style
system of production documentation? number ref was available in all documents.
11.4 Are the following records maintained? Country of Origin is issued by Chittagong Chamber of
a. Records of the country of origin for all Commerce & Industry and is included with shipment
goods produced in the facility. documents.
b. A production profile of any

subcontracting facility (the facility requests
documents from the subcontractors when N/A
questions regarding goods produced at those
facilities arise).

c. Production/purchase orders (with

information such as conditions of PURCHASE ORDER 00109298, REF 1C359601
production, payment, and finished product MIXD DELI, COONEEN DEFENCE LTD. UK
specifications).
d. Raw material invoices (indicating PURCHASE ORDER 00109298, REF 1C359601

country/origin/manufacturing facility). MIXD DELI, COONEEN DEFENCE LTD. UK
e. Shipping/receiving documents (outgoing PURCHASE ORDER 00109298, REF 1C359601

and incoming records of components/ inputs MIXD DELI, COONEEN DEFENCE LTD. UK
sent to or received from another facility).
f. Employee work records – accurate records PURCHASE ORDER 00109298, REF 1C359601
of employee work hours that can be linked MIXD DELI, COONEEN DEFENCE LTD. UK
to the production of specific products.
g. Quality control records (which may PURCHASE ORDER 00109298, REF 1C359601
include facility name and address, purchase MIXD DELI, COONEEN DEFENCE LTD. UK
order number, style number, date of the
quality check, buyer, name, stamp or
signature of inspector, comments on
production).
h. Export documents (including, packing

list, manifest, bill of lading/airway bill from
truck, ship, plane or train indicating the PURCHASE ORDER 00109298, REF 1C359601
export date, exporting entity, destination, MIXD DELI, COONEEN DEFENCE LTD. UK
shipping lines, importing entity, and any
charges incurred).
i. Outward processing production (if

applicable, copies of the outward processing
program designated by the domestic
government, copies of compliance review
reports, documentation demonstrating the
flow of goods from one facility to another).
j. Number of units produced marked with a PURCHASE ORDER 00109298, REF 1C359601
traceable mark. MIXD DELI, COONEEN DEFENCE LTD. UK
k. Machine inventory records, updated at PURCHASE ORDER 00109298, REF 1C359601

least once a year. MIXD DELI, COONEEN DEFENCE LTD. UK
l. Documented confirmation of the correct

category and country of origin for goods
through verification of correct country of
PURCHASE ORDER 00109298, REF 1C359601
origin such as binding rulings from the US
MIXD DELI, COONEEN DEFENCE LTD. UK
Customs Service, confirmation with
purchasing company, knowledgeable/trained
staff, etc.
m. Documentation on how the qualified Name: Maruf Hasan, Manager Merchandizing

person with responsibility for this Principle

communicates, deploys, and monitors the
facility’s customs compliance policies.
11.5a Do the facility’s production records

include verification of sub-contractor No sub-contracting.
performance?
11.5b What records are used?

Date and location of the verification
Product(s) verified
Purchasing company
Style number No sub-contracting.
Phase of production
Reference indicator for employee(s) performing

operation
Name/stamp or signature of verifying official
11.6 Has the facility designated a qualified

person with responsibility for communicating, Name: Maruf Hasan, Manager Merchandizing
deploying, and monitoring customs compliance?
11.7 Does the responsible person ensure that

origin determining documents are maintained for
Control of records-three years retention period
at least the period of record retention required by
law?
11.8 Does the responsible person ensure that all

Production manager kept production records & follow-
subcontracting facilities complete a production
up by commercial manager.
profile, and keeps such profiles on file?
11.9 Does the facility verify production at

subcontracting facilities when necessary through
the review of requested documentation or Supplier evaluation & inspection report
personal visits (recording such instances of
production verification and keeping on file)?
11.10 Does the responsible person stay current

with possible illegal transshipment activity in the
host country through communication with
The factory coordinates with the customers as the
appropriate bodies such as the host government,
factory does not have any direct contact with
trade association, contact with U.S. Customs,
regulatory bodies or US customs etc.
corporate importing office etc., and be
responsible for maintaining files on any known
transshippers or transshipment activities

determined to be in the host country or with a

country from which facility sources?
11. CUSTOMS COMPLIANCE Facilities will comply with applicable customs laws, and in
particular, will establish and maintain programs to comply with
customs laws regarding illegal transshipment of finished
products.
Customs Compliance: Custom Act 1969 (amended 2003). Establishes customs regulations governing
shipping, and requires close compliance with quotas that apply to exports.
1.
2.
3.
4.
5.
1.
2.

PRINCIPLE 12
SECURITY
Procedure available in Security Policy File and

12.1 Does the facility have practices to guard
Security gate. Policy included weapons, ammunition,
against the introduction of contraband (e.g. drugs,
explosives, narcotics and other contraband items are
explosives, biohazards, and/or other contraband)?
included in it. Such items are never covered by any
Any non-manifested cargo will be referred to as
document and are always illegal. Awareness poster
contraband
displayed with every security point.
12.2 Has the facility designated a qualified person

with responsibility for communicating, deploying, Jahangir Kabir, Manager Compliance
and monitoring security policies and procedures?
Container Inspection
Documented procedure in place to verify the physical

integrity of the container structure during the loading
time. Check point of container clearly identified and
security guard found well aware about container
inspection. Policy included, Container integrity
12.3a Does the facility have documented procedures maintained to protect against the introduction of
in place to verify the physical integrity of the unauthorized material and/or persons. At point of
container structure prior to loading? stuffing, procedures must be in place to properly seal
and maintain the integrity of the shipping containers.
A high security seal use to all loaded containers bound
for the U.S. All seals meet or exceed the current PAS
ISO 17712 standards for high security seals. Container
/Covered van inspection record available.
12.3b Does the procedure include the reliability of

Locking mechanism described in the procedure.
the locking mechanisms of the doors?

12.3c Does the facility conduct a seven-point

inspection process for all containers and keep
records of all inspections:
If the answer to any of these points is no, please

state the alternative method used.
Front wall
Left side Documented seven point inspection records available.

Security guard found well aware about Seven Point
Right side Check.
Floor
Ceiling/Roof
Inside/outside doors
Outside/Undercarriage
Trailer Inspection
12.4a Does the facility have procedures in place to

verify the physical integrity of the trailer structure Facility using container for transportation of finished
prior to loading, including the reliability of the goods.
locking mechanisms of the doors?
12.4b Is the facility following five-point inspection

process is recommended for all trailers?
Fifth wheel area - check natural compartment/skid

plate
Exterior - front/sides Facility using container for transportation of finished

goods.
Rear - bumper/doors
Front wall
Left side
Container and Trailer Seals
High security seal use on all loaded containers bound

12.5a Does the facility affix a high security seal to
all loaded trailers and containers bound for the
ISO 17712 standards for high security seals. Seals are
U.S.?
printed with unique identifier such as company name,

logo, bar-coding or holography.
High security seal use to all loaded containers bound

12.5b Do the seals meet or exceed the current ISO
ISO 17712 standards for high security seals.
17712 standards for high security seals?
Seals are printed with unique identifier number
12.5c Does the facility have documented procedures

Documented procedure available for the security
stipulating how seals are to be controlled and
safety of container and trailer.
affixed to loaded containers and trailers?
Facility has Procedure for Missing/lost cargo report is

12.5d Does the facility have documented procedures filed with local Police Station and the customer is
for recognizing and reporting compromised seals immediately informed and informed US Customs (if
and/or containers/trailers to US Customs and Border buyer is USA Based) dept hence. Therefore they will
Protection or the appropriate local authority? be informed in case of such incident. So far, no such
incident has ever occurred.
12.5e Does the facility have designated employees Store I/C Mr. Emdadul Hoque is responsible for the
for the distribution of seals for integrity purposes? distribution of seals for integrity purpose.
Container and Trailer Storage
12.6a Is the security of containers and trailers

Facility has secured loading unloading bay in front of
located within the facility maintained? Are they in a
the facility. 24 hour security guard present in loading
secure area to prevent unauthorized access and/or
unloading bay.
manipulation?
12.6b Does the facility have documented procedures

Documented procedure in place for reporting and
in place for reporting and neutralizing unauthorized
neutralizing unauthorized entry into containers or
entry into containers/trailers or container/trailer
container storage area.
storage areas?
Physical Access Controls
Physical access control procedure found in place.

12.7 Does the facility have a physical access control Photograph of authorized personnel in the packing
procedure? area, finished goods area, loading unloading area, is in
place.
Employees
Facilities have an employee identification system in

12.8a Does the facilities have an employee
place for positive identification and access control
identification system in place for positive
purposes. Access control system established in
identification and access control purposes?
packing area, finished goods area, bonded ware house.
During facility tour It was observed finished goods

stored at outside the finished goods storage area
12.8b Does the facility ensure that employees are
without any restricted access control.
only given access to those areas needed for the
performance of their duties?
Corrective action taken, finished goods removed to
restricted finished goods area. Photograph taken as

evidence.
facility ensured that employees are only given access

to those areas needed for the performance of their
duties
Facility has control of assurance and removal of

12.8c Does the facility control the issuance and employee, visitor and vendors identification badges.
removal of employee, visitor and vendor
identification badges? Documented procedure available for issuance, removal
and changing of access device.
Facility have an employee identification system in

12.8d Does the facility have documented procedures
place for positive identification and access control
for the issuance, removal and changing of access
purposes. Packing and finished goods access control
devices (e.g. keys, key cards, etc.)?
system found in place.
Visitors
12.9 Do visitors present photo identification for Guards at main gate ask all visitors and vendors for
documentation purposes upon arrival? their identity, if they get approval from the concerned
All visitors should be escorted and should visibly personnel then escort them to the reception area where
display temporary identification. there is a small meeting room for such purposes.
Deliveries (including mail)
12.10 Is vendor ID and/or photo identification

required to be presented for documentation purposes Written procedure available to check all incoming
upon arrival by all vendors? deliveries including mail. Security guard found well
Arriving packages and mail should be periodically aware about the policy. Practice found in place.
screened before being disseminated.
Challenging and Removing Unauthorized Persons
Guards at main gate ask all visitors and vendors for

12.11 Does the facility have documented procedures
their identity, if they get approval from the concerned
in place to identify, challenge and address
personnel then they escort them to reception where
unauthorized/unidentified persons?
there is a small meeting room for such purposes.
Personnel Security
Documented procedure in place, facility has system to

screen prospective employees and to periodically
12.12 Does the facility have documented procedures check current employees. Pre- employment
in place to screen prospective employees and to verification, background checks are to be performed.
periodically check current employees? Management has procedures in place to remove
identification, facility, and system access for
terminated employees.
Pre-Employment Verification
12.13 Does the facility verify application Documented procedure and record in place to verify
information, such as employment history and applicant information, working experience history,

references, prior to employment? reference, address.
Background Checks / Investigations
Facility conducting background checks and

investigations for all prospective employee and
12.14a Does the facility conduct background checks
Background checks and investigations by police
and investigations for prospective employees?
conducted for all packing personnel, security guard
and Loader.
12.14b Once employed, are periodic checks and Periodic checks and reinvestigations system found in
reinvestigations performed based on cause, and/or place for the workers working in Packing, Loading
the sensitivity of the employee’s position? unloading and Security section.
Personnel Termination Procedures
Documented policy found in place regarding

Termination of Personnel, Procedure included, if any
person is terminated from service, he/ she is to
complete some formalities: Termination of any
employee of company fills Clearance Form and is
acknowledged by all concerned departments.
Accounts Department responsible to make full and
final settlement of respective employee, Departmental
12.15 Does the facility have procedures in place to Head hand over charge including records, keys and
remove identification, facility, and system access others, Termination of employment, HR &
for terminated employees? Compliance Department responsible to issue circular
to all departments and one circular is pasted at Main
Entrance, Immediately HR & Compliance Department
issue termination letter to employee and communicate
to all concerned departments for clearance form, The
Identity Card provided by company/ institution will be
positively returned and recorded, Any key with him or
her will be returned and recorded, All the documents
with him should positively be retuned and recorded.
Documentation Processing
12.16 Are documented procedures in place to ensure Documented Procedure in place, policy included, to
that all information used in the clearing of ensure that all information used in the clearing of
merchandise/cargo, is legible, complete, accurate, merchandise/cargo, is legible, complete, accurate, and
and protected against the exchange, loss or protected against the exchange, loss or introduction of
introduction of erroneous information? erroneous information. Documentation control
Documentation control must include safeguarding includes safeguarding computer access and
computer access and information. information.
Manifesting Procedures
Documented procedure in place, Procedure included,

12.17 Are documented procedures in place to help
ensuring the integrity of cargo, procedures must be in
ensure the integrity of cargo and that information
place to ensure that information received from
received from business partners is reported
business partners is reported accurately and timely.
accurately and in a timely manner?
Cargo should be reconciled against information on the

cargo manifest. The cargo accurately described, and

the weights, labels, marks and piece count indicated
and verified. Departing cargo verified against purchase
or delivery orders. Drivers delivering or receiving
cargo to be positively identified before cargo is
received or released.
Shipping and Receiving
12.18a Is cargo that is being shipped reconciled

Record available.
against information on the cargo manifest?
The cargo is accurately described, and the weights,

labels, marks and piece count indicated and verified.
12.18b Is all cargo accurately described, and are the
Departing cargo verified against purchase or delivery
weights, labels, marks, and piece count indicated
orders. Drivers delivering or receiving cargo to be
and verified?
positively identified before cargo is received or
released.

12.18c Does the facility verify departing cargo Departing cargo verified against purchase or delivery
against purchase or delivery orders? orders. Drivers delivering or receiving cargo to be
released.

12.18d Are drivers delivering or receiving cargo
Departing cargo verified against purchase or delivery
orders. Drivers delivering or receiving cargo to be
released?
released.
12.18e Are documented procedures in place to track

the timely movement of incoming and outgoing Documented procedure found in place.
goods?
Cargo Discrepancies
Shortages, overages, and other significant

discrepancies or anomalies must be resolved and/or
12.19a Are all shortages, overages, and other
investigated appropriately. Customs and/or other
significant discrepancies or anomalies resolved
appropriate law enforcement agencies must be notified
and/or investigated appropriately?
if illegal or suspicious activities are detected - as
appropriate.
Shortages, overages, and other significant

discrepancies or anomalies must be resolved and/or
12.19b Are customs and/or other appropriate law
investigated appropriately. Customs and/or other
enforcement agencies notified if anomalies, illegal
appropriate law enforcement agencies must be notified
or suspicious activities are detected, as appropriate?
if illegal or suspicious activities are detected - as
appropriate.
Fencing

Perimeter fencing enclosed the areas around cargo

handling and storage facilities. Interior fencing within
a cargo handling structure to be used to segregate
domestic, international, high value, and hazardous
cargo. All fencing to be regularly inspected for
12.20a Is there perimeter fencing enclosing the integrity and damage. Gates through which vehicles
areas around cargo handling and storage facilities? and/or personnel enter or exit is under monitoring. The
number of gates to be kept to the minimum necessary
for proper access and safety. Buildings constructed of
materials that resist unlawful entry. The integrity of
structures maintained by periodic inspection and
repair.
12.20b Is interior fencing within a cargo handling

Cargo / covered van handing area segregated by stand
area used to segregate domestic, international, high
and chain.
value, and hazardous cargo?
12.20c Is all fencing regularly inspected for

As part of regular facility monitoring process.
integrity and damage?
Gates and Gate Houses
12.21 Are gates through which vehicles and/or

personnel enter or exit manned and/or monitored?
Main entry gate is under coverage of security guard.
The number of gates should be kept to the minimum
necessary for proper access and safety.
Parking
12.22 Are private passenger vehicles prohibited Private car entry prohibited to cargo handling and
from parking in or adjacent to cargo handling and storage areas. Separate space for private car parking is
storage areas? available.
Building Structure
It was noted from security interview that as part of

12.23a Are buildings constructed of materials that
regular duty security personnel is responsible to
resist unlawful entry?
visually inspect fencing of the building.
Buildings constructed of materials that resist unlawful

12.23b Is the integrity of structures maintained by
entry. The integrity of structures maintained by
periodic inspection and repair?
periodic inspection and repair.
Locking Devices and Key Controls
12.24 Are all external and internal windows, gates All external and internal windows, gates and fences
and fences secured with locking devices? secured with locking devices. Management or security
Management or security personnel must control the personnel control the issuance of all locks and keys.
issuance of all locks and keys. Officer of the factory is responsible to keep all key.
Lighting
12.25 Is there adequate lighting provided inside and Adequate lighting provided inside and outside the

outside the facility including the following areas: facility including the following areas: entrances and
entrances and exits, cargo handling and storage exits, cargo handling and storage areas, fence lines and
areas, fence lines and parking areas? parking areas.
Alarms Systems and Video Surveillance Cameras
12.26 Are alarm systems and video surveillance

Video surveillance cameras utilized to monitor
cameras utilized to monitor premises and prevent
premises and prevent unauthorized access to cargo
unauthorized access to cargo handling and storage
handling and storage area.
areas?
Password Protection
Automated systems are in place to use individually

assigned accounts that require a periodic change of
12.27a Does the facility have automated systems for password. IT security policies, procedures and
individually assigned accounts that require a standards are in place and provided to employees in
periodic change of passwords? the form of training. A system must be in place to
identify the abuse of IT including improper access,
tampering or the altering of business data.
12.27b Does the facility have documented IT

security policies, procedures, and standards in place
Documented policy and procedure is in place.
and provide them to employees in the form of
training?
Accountability
12.28 Does the facility have a system in place to

identify the abuse of IT including improper access,
tampering or altering of business data? Defined in the IT security policy & procedure
All system violators must be subject to appropriate
disciplinary actions for abuse.
Security Training and Threat Awareness
A threat awareness program established and

maintained by security personnel to recognize and
12.29a Does the facility have a threat awareness foster awareness of the threat posed by terrorists at
program in place and established and maintained by each point in the supply chain. Employees aware of
security personnel to recognize and foster awareness the procedures the company has in place to address a
of the threat posed by terrorists and contraband situation and how to report it. Additional training
smugglers at each point in the supply chain? provided to employees in the shipping and receiving
areas, as well as those receiving and opening mail.
Additionally.
12.29b Does the facility make employees aware of

the procedures the company has in place to address Reporting system found in place.
a security situation and how to report it?
12.29c Does the facility give additional training to Specific training offered to assist employees in
employees in the shipping and receiving areas, as maintaining cargo integrity, recognizing internal
well as those receiving and opening mail? conspiracies, and protecting access controls.

12.29d Does the facility undertake additional,

Training system found in place regarding maintaining
specific training to assist employees in maintaining
cargo integrity, recognizing internal conspiracies and
cargo integrity, recognizing internal conspiracies,
protecting access controls.
and protecting access controls?
12.29e Do these programs offer incentives for active Training program included incentives to active
employee participation? employee participation.
12. SECURITY Facilities will maintain facility security procedures to guard against
the introduction of non-manifested cargo into outbound shipments
(i.e. drugs, explosives biohazards and /or other contraband).
Security: Factories Act of 1965 requires factories to provide for the security of the workers. Homeland
Security Act of 2002. Customs Trade Partnership Against Terrorism (C-TPAT), WRAP Principle for Security.
1.
2.
3.
4.
5.
1.
2.
This report provides a summary of the findings and other applicable information found/gathered during the audit conducted
on the dates mentioned only. The 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 audit process
than is provided here. The audit process is a sampling exercise only and does not guarantee that the audited facility prior,
during or post-audit is in full compliance with WRAP Principles. WRAP Principles should not be used to prevent companies
from exceeding these requirements. Companies applying WRAP Principles are expected to comply with all relevant laws, and
where the provisions of law and WRAP Principles 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, unless the report is generated as
part of an unannounced audit visit. Release permission must be provided by the owner prior to release to any third parties.


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2014-07-22 Rec Report (Revised) (Bangladesh) Accordia 05-24-14

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WRAP CERTIFICATION PROGRAM

Facility Certification Recommendation

Monitor Report No. EDSL07042014 Factory’s WRAP ID No. 12999

To: WRAP Certification Board

On 24-05-2014 Accordia Global Compliance Group, performed the

WRAP compliance evaluation visit on the facility:

Eve Dress Shirts Ltd. (Bangladesh)

Md. Rokibul Islam 24 May 2014

Date of Initial Compliance Visit: 8 April 2014

Document Name: Facility Certification Recommendation

SL Non Compliance Issues Management Complete Date

Fire Drill Record is propedy Maintained

Fired extinguisher is blocked with carton or othr materials.

Fabric & materials are cleans & free from dirty

Drinking water testing for any authorized organization

04 Seven Point check Ihspéction record are keep in register? - y

Personal file maintain with legal! relevant documents

Auditor Signature & ate

Signature & Chop

Was the Facility’s Self- Yes No

Document Name: WRAP Audit Report

Certificate of Incorporation: C- 56540(3223)/05

Boiler Operator: Cert No: 2010/122/3160; 2nd division.

BERC: Bangladesh Energy Regulatory Commission. Cert No: LWC-0025/0036/1061,

Facility Phone #: (+88)-02-7741720

Document Name: WRAP Audit Report

Was the facility in compliance with the requirement to have:

2 Prohibition of Forced Labor Yes No Yes No

3 Prohibition of Child Labor Yes No Yes No

4 Prohibition of Harassment or Abuse Yes No Yes No

5 Compensation and Benefits Yes No Yes No

6 Hours of Work Yes No Yes No

7 Prohibition of Discrimination Yes No Yes No

8 Health and Safety Yes No Yes No

9 Freedom of Association and Collective Bargaining Yes No Yes No

10 Environment Yes No Yes No

11 Customs Compliance Yes No Yes No

12 Security Yes No Yes No

Document Name: WRAP Audit Report

Historic Non-Compliance Table

Document Name: WRAP Audit Report

Full description of the building(s) and surroundings:

Document Name: WRAP Audit Report

Number of years facility has been in operation at this location:

Factory established on 2006 and in operation for the last 8 years.

Document Name: WRAP Audit Report

Additional auditor remarks:

Process: Cutting, Embroidery, Sewing, Ironing, QC and Finishing.

The factory produce Woven (top) items.

Per month production capacity 220,000 Pcs per month

Machine Oil in maintenance for spot lifter 833 Spot removing.

Document Name: WRAP Audit Report

Worker interviews conducted

Permanent Temporary Migrant workers Agency Home workers

Document Name: WRAP Audit Report

Document Name: WRAP Audit Report

AUDIT QUESTIONS YES NO NA If a non-conformity is raised please state N/C

The facility obtains current information on local

Prohibition of Forced Labor Social Manager System Policy and Procedure

Prohibition of Child Labor Social Manager System Policy and Procedure

Prohibition of Harassment or Abuse Social Manager System Policy and Procedure

Compensation and Benefits Social Manager System Policy and Procedure

Hours of Work Social Manager System Policy and Procedure