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Document Name: Facility Certification Recommendation

Issue Date: April 2010 Document Owner: Director of Compliance

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): ______________

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 fan regulator

02 days 1st floor sewing section.

2 Sewing line no. 07 is We will keep clean our

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 floor male toilet

water tap

03 Factory Managemnt Represen ative

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SL• Nc ___ Observation". Scoring Remarks ____ ____ ____ ________ N/A yes No

............. Particulars . ...&. ........

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 gici 41*1 ot1iik (Dd.1 'i1) *'kiii C1 "fl4f9tl

Fire Extinguisher is Accessible placed according to country law properly marked & inspected. 03

'lIZfi 'iu uilii tSZ-'il t1 iQk 'ItT M1 CJC i1p'tci IWR't t RC4C I

04 Evackuation Plan are Posted on every floor in native language 'bIqcirP( IPT/$1W4't *tr Th51t lic WI M1 uic Ot iit*i rr i cic

05 Workers are aware about evacuation plan

tiffr/cnjcør rtt 1 I cccl 'tw 'iic I

06 Does Organization Maintain Monthly Fire Drill? Vriff Wfqw;mm wilc W 1RT I

07 Fire Drill Record is propedy Maintained ik fr cg ocici NT scc I

08 Fire Hose Pipe installed is working properly Sk ctw nitc i ici *T1t cic I

09 Trained Worker is available in the floor about fire hose pipe cPkE tt'zt pkig cm t°r biallom *ft erto ZtI* Z= I

10 Emergency Exit Sign are visible with English & Local Language -aivk MR cr e 1R

11 Does Emergency Exit light are connected with the Solar.

Are Emergency light installed in proper area / Location 12 eii4I WIQS tT vrt5rlt9t mcrz Personal Safety Related Matter

Metal Hand Gloves Supplied to the cutting Dept 01 ccr tws c's gtsr cw'srn 'tw

Worker of cutting Room Using Metal Hand Gloves 02

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03 Hand Gloves are fit With Hand

. ___ ____ __

04 Needle Guard are properly fixed & in use ictci ff t?QIRty

* Qbservation ; ri Rernaks , Particu1ars' '-r- N

No N/A I '-y" Yes 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 jlTh 2IMW n i1 &'uci '1ZW 1*91?

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 -v

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Fuse breaker boxes labeled closed at all times & accessible 04 t i4tl n 's 21T9fr I

Are cutting machineselectrical lines properly connected? 05 i tl c*tw 'j1,c 'itzmr AF 36w '1E T i

Environment

Adequate ventilation in production area maintenance, packing floor. 01

c'ishi, irtI '6 t'1199 çflq fI orft asjfclti sMl 'ik?

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

iwt ptc1 ci1eeiq t ncci frst 7q i arr ccv, 9APT ctv. ZttwiT VM i

Does company have environrnaentel certificate form government?

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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 I'Zg9 cqltg flU tflIRf*RI?

05 worker personal items kept in designated area

W I

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

08 Are the stores clean & free from insects dirty

dWt iRuni il mst cs aw Health & safety related matter

Safe drinking water supplied at production floor 01

Drinking water testing for any authorized organization 02 nInhIick aii k1cd*91?

Drinking water test for available for work station 03 ,4çiprj fj I1N ntfg i'k'l t903!oflc'1l 'ilcfi9t?

Production floor clean & hygienic Seci E

Li iw- Mo CI 04 'Silljfl? 'V

Are there adequate no of toilets ? Are there cleaned properly? 0101 4 4- —0 & t 0u2. a4&rc-t4 05 4.quwt '-". i6 6rcokeli b-) i L4f ,flYIQICTO;k

Are the floor & other areas of factory is clean/Mopped/dry? 06 *W* Pi1'& c'wi 74 fRI?

Covered rubbish bihs. are .cleared daily? 07

RK aPi c4.. w4t -,Tq1It? All toilets are neat & clean ?

08 141 Lnw'ib 'S

Observation

Yes j No N!A

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Observation

Yes

Scoring _Remarks

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Remarks

/ SL. No particulars

Security Related Matter

Are Contoiner/ Coverdvan loading after Seven Point Check by Security lncharge 01 ffifcfIii 'Qiwt rnI CP 4tlll cit ItiS fl l'ilil tW cQdN/t1' SWt C'11I t kT fr

02 unauthorized person entrance at container/ coverdvan loading time?

cM/5l'iH cnft 'M Prn 'QBPc g$1R3' 1'T S WS C9'tBTT fl fr?

Store Incharge & Security lncharge are do Jointly Bolt sealed after loading exportable goods in

I container/Coverdvan _______ _____ _____ 03 IiTh, ti ' ciS 31114 ¶4 T4 Q'*ie pr;s .101tc CV4 7021

04 Seven Point check Ihspéction record are keep in register?

&ic't tta cF1t9f'M cw$ ciMk.ii ffi9M'I Wt 4W? -

Are information Access Control Policy & Procedure Implementation? 05 .piqi aff{ cjf43 111k ifrk'i rfry

Particulars

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$ fl fi P1T tW fr

04 Is there any child labor is working below of 18

)br W011 ftu CPT PM 40M jc fr OS Is the factory paying minimm wages as per government law?

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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 Audit Date(s): 1st audit: 7th April 2014 & 8th April 2014 Follow up 1: 24th 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-Assessmentreviewed by the lead auditor before the audit?

Yes No If No, why not?

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 conducted?

Yes No 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? (Name and title):

Jahangir Kabir Manager Compliance

Full Address of Site covered in this audit:

Ashulia, Savar, Dhaka- 1341

Registered Business name and address (in English, and, if needed, local language):

Eve Dress-Shirts Ltd. 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 required license numbers:

Trade License: 85(2013/15), Issued Ashulia Union Porishad, Issue date: 6th July 2014; 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: [email protected] Products / Activities at site e.g. garment manufacture, packing, service, etc. (please state):

Woven Garments.

Audit results reviewed with facility management?

Yes No If No, please explain:


mailto:[email protected]

Policy and Procedures Table

Policy and procedures

Was the facility in compliance with the requirement to have:

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

Issue

Area of Non-Conformity

(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

Issue

Area of Non-Conformity

(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,

Embroidery section, Sample section, Bonded ware house, Medical room, Admin Office, Accessories room, Compliance room, Time section, Office dinning, Fabric Inspection room.

Cutting section, Cutting Pass Check room, Embroidery section, Sample section, Bonded ware house, Medical room, Laboratory room, Accessories room, Compliance room, Time section, Office dinning, Fabric Inspection room.

1st Floor Sewing section (total 6 line), Finishing, Office room, Spot Removing room, Maintenance room

Sewing section (total 6 line), Finishing, Office room, Spot Removing room, Maintenance room

2nd Floor Sewing section (total 3 line), Finishing, Laboratory room, Spot Removing room,

Sewing section (total 6 line), Finishing, Laboratory room, Spot Removing room,

3rd Floor Packing section, Fusing section, Bonded ware house, Accessories store, Training room, Office

Packing section, Fusing section, Bonded ware house, Accessories store, Training room, Office

4th Floor Ready for Eve Garments Ltd which operation is not started yet.

Eve Garments Ltd.

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

(domestic or foreign) Agency Home

workers Worker numbers (male) 375 X X X x Worker numbers (female) 667 X X X x Total manpower (including other personnel)

(1042+76+25) = 1143


Other personnel Management 3rd party

service providers

Security personnel

Agency cleaners

Agency canteen staff

Others (please state)

76 25 - - -

Worker interviews conducted

Permanent Temporary Migrant workers (domestic or foreign)

Agency Home workers

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 (if applicable):

Round the year same

Normal Work Days: e.g. Mon ─Sat

Saturday to Thursday and Friday is weekly holiday.

Were appropriate records available to verify hours of worker and wage compliance?

Yes No

Describe nature of any inconsistencies found: Poor record keeping No records Multiple records

What was management’s attitude in response to an inconsistency finding, if any?

Management was positive minded. Specially regarding new requirement 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 facility?

Yes No

What is the % of workers living in facility provided accommodation?

N/A

Age of youngest worker found: Above 18 Are workers under 18 subject to hazardous work assignments?

Yes No

What form of worker representation is there on site?

Union (name) Worker Committee Other ( Worker Participate Committee)

If workers have grievances, how do they bring them about to the facility management?

Grievance boxes have been placed. It opened once a week i.e. every 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 located?

Toilets.


Is internal system monitoring conducted by the facility on a regular basis?

Yes No


PRINCIPLE 1 COMPLIANCE WITH LAWS AND WORKPLACE REGULATIONS

AUDIT QUESTIONS YES NO NA

Objective Evidence/Comments

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

this section.

1.1 Does the facility obtain current information on all relevant laws and regulations concerning each of the Principles and incorporate this information in its business practices?

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 Notice boards and in front of main entries. Responsible Person for communicating changes of laws and regulations and incorporating in the 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 procedures for current information on all relevant laws and regulations on each of the following WRAP Principles? Compliance with Laws and Workplace Regulations

Social Manager System Policy and Procedure – includes policies & procedures pertaining to all 12 principles of WRAP. Each policy refers to the applicable laws & 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

1.2 Does the facility have a qualified person responsible for informing the facility of changes to laws and regulations, or access to current publications on all relevant labor laws?

Jahangir Kabir, Manager Compliance keeps close liaison with BGMEA, Labour Department and Environment Departments to keep the company up to date with applicable labour laws and environmental laws. For Customs Compliance Maruf Hasan, Manager





this section.

Merchandizing is responsible to liaison with Customs Department.

1.3 Does the facility update its practices to incorporate revision to existing laws and regulations in a timely fashion?

The Procedure against WRAP Principle 1 Law and Workplace Regulation describes how the policies & procedures need to be revised and training imparted in case any applicable law or regulation is revised.

1.4 Does the facility undertake internal monitoring of its management system (internal audits) to satisfy itself that the written procedures and processes are meeting the requirements of local law and WRAP Principles?

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.

1.5 During the previous two years, has the facility had any notices of noncompliance levied against it (including any legal proceedings or outstanding allegations concerning the facility’s operations)?

No evidence found for such notice issued to factory. During worker interviews also the workers did not inform of any unrest in factory or made such allegation against the factory.

1.6a Is there a program to train relevant individuals regarding any new laws or revisions to existing laws and regulations?

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. Facility has system to discuss this issue with Mid Management and Changes are 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 appropriate? Training is provided against the documented

Policy and procedure.

1.7. List the exceptions to all relevant laws, rules, and regulations other than those specifically documented elsewhere in this report.

N/A

1.8 Does the facility have a written operating policy manual that includes the following:

a. Relevant laws and regulations pertaining to the Principles?

Social Manager System Policy and Procedure includes policy, procedure for each WRAP Principle. It also refers to the relevant applicable laws & regulations. Further detailed procedures (where) required have been listed in the appendix of the Policy Manual.





this section.

b. The facility’s policies and procedures pertaining to the Principles?

The policies and procedures pertaining to the Principles have been documented which are used for implementation and to comply with law and workplace regulations.

c. Routine updates for revisions to existing laws and 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 revision takes place and therefore maintains 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 production operations? Facility not doing any sub-contracting work

outside of the facility.

1.10 Does the facility sub-contract any other operations? Not applicable.

1.11 How has the facility informed the sub-contractor of their obligations under the local labor law and WRAP Principle requirements?

Not applicable.

1.12 Does the facility keep evidence of how the sub-contractor(s) has/have been made aware of these requirements?

Not applicable.

1.13 Does the facility keep receipt of sub-contractor acknowledgement of these requirements?

Not applicable.

1.14 Does the facility regularly review its list of sub-contractors to make sure it is up to date? Not applicable.

Best practices observed:

1. COMPLIANCE WITH LAWS AND WORKPLACE REGULATIONS

Facilities will comply with laws and regulations in all locations 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



If a non-conformity is raised please state N/C 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 monitoring the practices of effectively prohibiting involuntary or forced labor?

Name: Jahangir Kabir, Manager Compliance.

2.2 Does the facility have a program and materials used to train relevant individuals, including all individuals responsible for the hiring process, on the facility’s policies and procedures prohibiting forced or involuntary labor?

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

2.3 Are all employees working at the facility voluntarily?

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 from anybody. This declaration forms a part of the 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.

2.4 Are there any indications that people's movements are being restricted?

The facility has defined a policy on freedom of movement and allows employees to visit toilets, medical center, drinking water stations and to say their prayers as and when necessary. Also it was verified workers is free to leave facility during the lunch break. During the worker interview verified.

2.5 Are there exaggerated security measures or logistics being employed in the facility?

Security guards only posted at locations where needed for security purposes. Security forces are employed only for guarding the property and personnel of the company. During the facility visit, no exaggerated security measures or Logistics were noticed. Security guard found aware about job responsibility.





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2.6 Were there any overt signs of fear or exaggerated obedience displayed by employees during the facility inspection?

The atmosphere in the facility appeared normal and no sign of fear or exaggerated obedience displayed by employees was noticed.

2.7 Do security personnel act in a non-threatening manner?

No such incidence was observed during factory tour. During worker interviews the workers did not complain about bad behavior by Security guards. Treating workers with respect is mentioned in security guards’ job responsibilities. Training records of security guards verified and found ok.

2.8 Are security guards posted for normal security reasons, in a proportionately logical number?

Security guards posted for normal security reasons in a proportionately logical number, security guards found well aware about company security, force labor, child labor, harassment and abuse policy. Walk through of the facility did not reveal any excessive security being deployed.

2.9 Are the doors and gates of the facility locked only for normal business and housing security reasons and in compliance with applicable fire codes?

Doors and gates remain open during the operational hours. Only areas where any additional security is required and normally kept under lock and key, e.g Bonded Warehouse was found locked, all other exits/doors were observed to be open. Factory runs through Saturday to Thursday and during overtime hours as needed.

2.10 Does the facility prohibit all relevant individuals, including any person under the facility's direction (such as security guards), from coercing employees in any way, or unnecessarily limiting employees' freedom of movements?

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, understood and shall obey it. Management prohibits all section in-charges and department heads from unevenly persuading or unnecessarily limiting employee’s freedom of movement except that it may 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 upon their shift's conclusion? Verified during the worker interview and floor visit.

2.12 Does the facility require all hiring documents (e.g. an employment application or contract) to:

The appointment letter includes all terms & conditions related to the job and include a statement that the worker has read and understood all terms and accept to





section.

1) include a statement affirming that applicants are seeking employment voluntarily and are not under threat of any penalty, 2) be signed by each applicant, and 3) be maintained in the employee’s personnel file?

join on voluntarily basis. The appointment letter is signed both by the workers and the factory. Verified randomly selected 35 personnel file.

2.13 Does the facility obtain proof that anyone seeking employment is legally entitled to work in the country of manufacture in accordance with national immigration laws?

Facility obtain national ID Card or Birth Certificate as proof that workers seeking employment is legally entitled to work in the country of manufacture in accordance with national immigration laws. 35 personnel file verified.

2.14 Does the facility obtain an executed statement from all labor brokers/agents used by the facility stating that the brokers/agents are not supplying labor that is involuntary or forced, and has the right to work in this country?

Facility obtain an executed statement from all labor brokers/agents. Agreement copy available with loader supplier. Training record available.

2.15 Are all security service agreements free of any language or terminology that may imply the existence of forced, indentured or involuntary labor conditions?

Security guards job description is free of any language or terminology that may imply the existence of forced, indentured or involuntary labour conditions. Documented training record available. Verified during the security guard interview. Security guard found well aware about Job Description and Harassment abuse Policy.

2.16 Do job descriptions or individual contracts for security employees limit their tasks to normal security matters such as protection of facility property or facility personnel?

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 property and personnel, goods in - goods out control, vehicle movement control & checking of incoming/outgoing vehicles, visitor movement control 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 that clearly shows that the employee controls the destination of his/her wages, and access to his/her wages?

Facility issues wages/compensation directly to employees.

2.18 Does the facility hold identification papers, travel documents or passports of their employees? If yes, please provide commentary on whether it is at the request of the employee and with the employee maintaining complete access.

No original documents of any nature are retained by the company. The facility only checks Voters Identification Card (of those who have it) for age verification purpose and is not retained. After 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 or have any payment withholding practices? No such system noted during the audit period, also

verified in workers interview.

2.20 Is any prison labor used in this facility? If so, please explain & provide information on all relevant laws and industry standard(s).

No such system noted during the audit period, also verified in workers interview.

2.21 Are all work contracts signed by both parties (employer and employees)? For countries with at-will employment and/or no formal contracts, include a statement to that effect.

Workers and factory sign appointment letter that includes all terms & conditions related to employment. 1 copy appointment letter is issued to worker and 1 copy is retained in personnel file. This was verified 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.

Non-compliances raised against this Principle: 1. 2. 3.


4. 5. Historic Non-compliances raised against this Principle: 1. 2.


PRINCIPLE 3 CHILD LABOR




section.

3.1 Describe how the facility manages the hiring process. Include how the facility documents the age of potential employees with official country specific documents (e.g., birth certificates, identification cards, school records and/or immigration papers, medical records).

Facility is keeping age verification certificates of workers as well as Voter ID Card, birth Certificate, Chairman or Commissioner Certificate, and Blood Group Report. Facility declared recruitment committee of 14 members where representative from each section is available beside medical officer, nurse and compliance person also included in recruitment committee.

3.2 Does the facility obtain proof of age documentation from all potential workers and review the documentation for authenticity prior to hiring?

Employee files contain all correspondence related to the work history of the employees, i.e. application form to salary increment letters. So the file maintains information regarding how long an employee has been 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 employee and maintain the information in the employee’s personnel file for the length of time as required by law?

Facility retain proof of age for each employee and maintain the information in the employee’s personnel file for the length of time as required by law.

3.4 Does the facility assess the authenticity of age documentation and make comparisons with sample documents? Apply extra diligence in territories where child labor is common.

The hiring personnel and Admin officer check the photocopies of the documents with originals and retain the photocopies of the original document in the personal files, and return the originals to the applicants. The facility responsible person then gives 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? Verify that the physical appearance of employees selected is consistent with their age and employment history as documented in their personnel file.

As part of hiring process all workers go through age verification and skill level process by the company’s own doctor and recruitment committee and obtains an age verification certificate and employment history.

3.6 Does facility document the existence of an employment interview (e.g. a checklist indicating that the required questions were asked of the applicant)?

All applicants fill Job application forms providing basic information that is further verified during worker interviews. Documented checklist record available for all newly recruited workers. Based on interview check list grade of workers and salary finalized by recruitment committee.

3.7 Does the facility require a completed and signed employment application or contract that includes the date of birth (inclusive of the employee signature, employee identification number and signature date)?

All workers need to submit an application form and also sign appointment letter that shows employee photo, employee ID and also employee date that includes the date of birth or age.





section.

3.8 Has the facility formally designated a qualified person with responsibility for communicating, deploying and monitoring child labor practices as they relate to the above requirements?

Name: Jahangir Kabir, Manager Compliance

3.9 Does the facility verify that the responsible person ensures that employee’s assigned tasks are appropriate for their age, where applicable?

Recruitment committee is responsible to ensure employee’s assigned tasks are appropriate for their age. Recruitment team available. And recruitment team is well aware about company’s child labor, 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. Do communications address each of the following requirements?: 3.10a. Proof of age documentation from all potential workers prior to hiring.

Age certificate or birth certificate and national ID Card copy is available for all workers working in the company, each copy keep in the personnel file of each worker.

3.10b. Examination of the authenticity of age documentation. Medical officer is responsible, also included this

element as training programs.

3.10c. Question the authenticity of age documentation not conforming to facility practices. Training program included.

3.10d. Age documentation retained in employee personnel files.

Age documentation retained in employee personnel files. Checked and verified 35 personnel files. Age 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 relevant individuals on the child labor practices, including all individuals responsible for the hiring process, cover the requirements to: obtain age documentation, review age documentation for authenticity, and interview all prospective employees?

Documented policy is used as training material especially while briefing the individuals responsible for hiring so that no aspect of policy is missed. Further a sample personnel file is shown to all during training to make them familiar with required documentation. Hiring policy is available and communicated with all personnel of the recruitment Team.

3.12 Do all employees in the facility appear to be above the minimum age? If a reasonable suspicion exists that there are age-borderline employees, be extremely cautious and attentive to assessing this compliance. If you suspect the age of any individual(s) you view working in the

All worker personnel files including age verification documents were found in respective files. During the monitoring visit, it was observed that the entire employee population appeared to be above the age of 18 years. In addition, any young looking employee noticed on the floor was included in the list of





section.

facility, you MUST seek to include them in the review process for age authentication, including employee interview.

interviews and a subsequent verification and review was conducted. Checked 35 personnel randomly 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.

Non-compliances raised against this Principle: 1. 2. 3. 4. 5. Historic Non-compliances raised against this Principle: 1. 2.


PRINCIPLE 4 HARASSMENT OR ABUSE




section.

4.1 Has the facility adopted a written policy on the prohibition of harassment, abuse, and corporal punishment?

Included in the Social Manager System Policy and Procedure and also translated in the local language. The facility does not engage nor support the use of corporal punishment, mental or physical pressure and any kind of verbal abuse.

4.2 Are the definition(s) of the non-compliant behavior(s) and management policy(ies) consistent with the intent to prohibit all forms of this behavior?

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 sexual harassment towards its female staff and workers. Sexual, physical, psychological harassment, 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 repercussions for non-compliance and repeated non-compliance? Note: The policy must apply to the behavior of all employees with special emphasis placed upon supervisory personnel.

Harassment & abuse policy, grievance policy and employee termination policy are all documented. Management has declared that for any non-conformance, punitive action will be taken as per the law of the country and shall apply to all of the employees.

4.4 Has the facility formally designated a qualified 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? Note: If the facility has not required signed statements in the past, evidence of statements signed on a prospective basis, i.e., from a certain date forward, is acceptable.

Signed statement affirming understanding anti-harassment and abuse policy is available. Under taking collected from all mid management personnel as a part of regular training program of mid management.

4.6 Does the facility effectively prohibit all forms of harassment, abuse, and corporal punishment through written policies and procedures?

The policy states that all forms of harassment, abuse and corporal punishment are prohibited. Management Personnel found well aware of harassment and abuse 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 third party services (e.g., security guards, kitchen services) that will have significant contact with facility employees?

workers and third party service i.e. all suppliers, wastage disposal company. Training included as part of regular training program.

4.8a Does the facility encourage employees to report instances of harassment or abuse, without fear of retribution, through effective communication of facility policies?

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. The company has an open door policy. Worker training is conducted encouraging the employees to report any problem they face in the factory. This was 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 reported, were they resolved in a timely manner? Nothing raised to note. Also verified in worker

interview.

4.9 Does the facility have an effective and mandatory program to train relevant individuals, including all individuals responsible for the supervision of workers, on the facility’s policies and procedures prohibiting all forms of harassment, abuse and corporal punishment?

Included in training program.

4.10 Are all the materials used for this purpose appropriate for this training? Documented procedures and policies, Training Manual

are used as training materials.

4.11 While inspecting the plant, were any signs noted of physical abuse (including but not limited to shared physical characteristics evident in many workers), such as:

a. bruising?

During the facility visit and interviews session, no evidence was found of harassment, abuse or threatening behavior. The employees were found to be highly satisfied with facility environment and no negative comments was offered with regards to harassment or abuse.

b. obvious physical injuries (casts, or other corrective wraps, an exaggerated repetition of the same medical condition)?

No such conditions were observed during the facility visiting

c. isolated employees? No such conditions were observed during the facility visiting

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

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. Non-compliances raised against this Principle: 1. 2. 3. 4. 5. Historic Non-compliances raised against this Principle: 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?


5.2 Does the facility have practices to ensure employees are compensated consistent with their terms of employment and in accordance with local laws and regulations?

Facility have practices to ensure employees are compensated consistent with their terms of employment and in accordance with local laws and regulations. Facility communicated legal salary structure to all worker through hand book, regular training program, and notice board.

5.3 Does the lowest record of payment by the facility meet (or exceed) the legal minimum compensation?

Grade 7: 5300/- Grade 6: 5678/- Grade 5: 6042/- Grade 4: 6420/- Grade 3: 6805/- Grade 2: 10900/- Grade 1: 13000/- Meets legal minimum.

5.4 Does the facility post legal minimum wage rates, benefit policies, and additional payment information in the native language(s) of the facility workers?

The Salary structure as per law has been communicated to all workers and a notice was found in all workers personnel files. Compensation policy and new salary structure was also displayed on notice board in local language.

5.5 Does the facility utilize and maintain an organized system of record keeping? Attendance is done by using Time Card

5.6a Does the facility produce and retain payroll records to support compensation, including overtime?

Payroll is generated using software. Hard copy of payroll with revenue stamp is retained by Department of HR and Compliance. Payroll 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 the transactions in a verifiable way? Note: The name of the employee, salary amount, and the date of the transaction must appear on

Salary is paid in Cash directly to the worker.





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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 a pay record or stub that lists the components of the wages paid?

Pay slip is issued to all workers with detailed breakdown of salary including deductions if any.

5.8 Are all legally mandated withholdings (e.g., taxes, social security, etc) remitted to the government?

10 taka revenue stamp

5.9 Are there any piece rate workers in the facility? If so, review a sampling of the documentation for piece rate workers as compared to wage rate workers to ensure compliance with this Principle.

Workers are paid salary on monthly basis only.

5.10 Does the facility have a written and coherent policy on piece rate compensation and does the piece rate compensation at least satisfy the minimum compensation prescribed by law?

No piece rate worker in factory

5.11 Do employees sign off on material counts or random independent recounts for piece rate systems?

Not applicable as not worker working as piece rate condition.

5.12 Are employees provided with adequate communication of their legally mandated minimum compensation rights?

Included in regular training program.

5.13 Does the policy communication include all of the following:

a. a detailed description of the employees compensation and benefits at the time of employment? b. both a written and verbal explanations of wage calculations provided at the time of employment? c. a requirement that changes relating to compensation rates or methods of wage calculations will be communicated timely and effectively?

a. a detailed description of the employees compensation and benefits at the time of employment through Worker Handbook and Orientation Training program. b. both a written and verbal explanations of wage calculations provided at the time of employment through Worker Handbook and Orientation Training program. c. a requirement that changes relating to compensation rates or methods of wage calculations will be communicated timely and effectively through Worker Handbook and 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. Non-compliances raised against this Principle: 1. 2. 3. 4. 5. Historic Non-compliances raised against this Principle: 1. 2.


PRINCIPLE 6 HOURS OF WORK



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

6.1 Has the facility formally designated a qualified person with responsibility for communicating, deploying and monitoring that no employee works more hours per day and per week than the legal limits?


6.2 Does the facility have a program and relevant materials to train all individuals, including all individuals responsible for production coordination and scheduling, to ensure that employees work no more than the legal maximum, including overtime ceilings?

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 boards in the native language Bangla. Also it has been printed in the employee hand books. Periodic awareness training is held for all supervisory personnel responsible for production coordination and scheduling as well as those who are in supervisory roles to ensure 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.

6.3 Are all employees are made aware, at the time of hiring, of facility policies and procedures, specifically the legal limitations on the maximum hours of work per day, week and month, both regular and overtime, and the maximum number of consecutive days they can legally be required to work?

At the time of hiring, all new recruits are informed about the legal requirements and the limitations on the working hours, both regular and overtime, by Providing induction training on the policies and procedures of the facility. They are also provided a hand book containing all the details. Documented training record available for all newly recruited employees.

6.4 Does the facility retain time records that reflect the day and date employees worked, the number of hours worked each day, and the employees’ acknowledgements of the same?

Factory has issued Time Card to all workers to use for attendance. The attendance is recorded in the software During the worker interview all workers are happy with the factory working hour and it was noted worker aware about Time Card.

6.5 Does the facility have a written, rational and well communicated policy defining "urgent business needs"? Note: The definition of 'urgent business needs’ cannot be vague or open ended. It must be limited to delays/interruptions in production caused by natural calamities, non-repetitive production deadlines or unforeseen circumstances beyond the employer’s control. A coherent and consistent rationale must be evident in the definition and infrequent deployment of 'urgent business needs'.

Emergency business needs policy available. Urgent business needs as under: Strike, road blockade in the city or country, Electricity failure, Stoppage of port, Urgent Shipment, political situation, Natural calamity like flood, Over rain, earth quake, cyclone etc or any unforeseen circumstances, to meet urgent shipment Number of days urgent business needs occurred during the past year: nothing to report.




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 language(s) of the facility's workers and management personnel?

Displayed on notice board in local language.

6.7 Are all new workers, at the time of hiring, required to be made aware of the facility's policies on required hours of labor?

Facility has system to training all newly joined workers. Documented training record available.

Hours of Work Analysis

Review Periods # of samples reviewed

Weekly avg hours for this period (including overtime)

Weekly max hours for this period

Frequency of occurrence of max hours (# of workers from samples & # 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 (quote highest and lowest)

Review period1 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. Non-compliances raised against this Principle: 1. 2. 3. 4. 5. Historic Non-compliances raised against this Principle: 1. 2.


PRINCIPLE 7 DISCRIMINATION




section.

7.1 Does the facility have a written policy that explicitly prohibits discrimination?

The facility has a documented antidiscrimination policy that explicitly prohibits discrimination. It is the company’s policy to ensure affirmative action 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 ensure compliance and remediation with the facility policy?

The facility has developed procedures and practices to ensure that facility’s antidiscrimination policy is effective.

7.3 Does the facility have their written policy visibly posted in the language(s) of the employees and management personnel?

The facility has prominently posted the policy written in local language on factory notice boards, printed in employees hand book and held training programs to create awareness among all employees including the management personnel.

7.4 Has the facility formally designated a qualified person with responsibility for communicating, deploying, and monitoring the non-discrimination policy?


7.5 Does the facility have an effective program and materials used to train relevant individuals, including all individuals responsible for the supervision of workers and for the hiring process, on their discrimination policy and practices?

Regular training programs are arranged to train relevant individuals such as management staff, supervisory personnel and Admin, HR & Compliance staff on the anti-discrimination policy and practices of the facility. The training materials prepared by responsible persons were reviewed and found appropriate.

7.6 Are the facility’s policy, practices and procedures on discriminatory behavior effectively communicated to all employees?

The management posts facility policy on all factory notice boards, prints in employees hand book and provides awareness training programs to all staff and workers to create awareness on facility’s policy, 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 parties (industrial parks, export processing zones, free trade zones, etc.) that may recruit and screen applicants its behalf?

The factory is not situated in any such area. Company recruits employees directly and not through any third party.

7.8 Has the facility had any discrimination charges No discrimination charge was filed against the facility





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filed against it by employees, regulatory agencies or any outside agency during the past two years? If so, please provide details.

by employees, regulatory agencies or any outside agency since its inception.

7.9 Does the facility explicitly prohibit mandatory pregnancy testing as a condition of employment or continued employment?

As a part of its policy on prohibition of discrimination, mandatory pregnancy testing as a condition of employment or continued employment has been prohibited by the management.

7.10 Are workers with the same job and seniority paid the same rate, irrespective of gender, age, or other characteristics?

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 to perform the job without regard to gender, age and 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 contract), written in the native language(s) of the employees, affirming their receipt and understanding of the facility’s antidiscrimination practices?

Statement signed by all employees was available in all personnel files.


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. Non-compliances raised against this Principle: 1.


2. 3. 4. 5. Historic Non-compliances raised against this Principle: 1. 2.


PRINCIPLE 8 HEALTH & SAFETY

AUDIT QUESTIONS YES NO NA COMMENTARY

HEALTH & SAFETY OVERVIEW

8.1 Does the facility comply with all relevant health and safety laws and regulations?

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 alarms, fire exists, fire extinguishers, other fire 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.

8.2 Are all relevant government health, safety, and fire safety certificates / permits, insurance policies and any relevant correspondence or documents from government officials in order? Please identify and report any irregularities.

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), IEB Registration number - 7045. Building assessment conducted by Private Engineering Firm Unicon Service Ltd. Engineer Mr. Shiek Manirul Islam, B.Sc. Engineer (Civil), IEB No: 23323 date June 29, 2013 where it’s clearly mentioned that soil condition as per 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.

8.3 Does the facility undertake internal monitoring of its health and safety systems, including fire safety, to ensure it is following the written procedures and processes and meeting the requirements of all relevant laws?

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

8.4 Have risk assessments been carried out throughout the facility, including fire risk assessments?

During audit it was observed that risk assessment was not carried out for the process operation of fusing, placket, and embroidery. 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 identified by the health, safety, and fire risk

Documented record available.



assessment, were they corrected?

8.6 Is a regular occupational health check arranged for hazardous job duties, if any? Documented record available.

8.7 Has the facility formally designated a qualified person (or persons) with responsibility for communicating, deploying, and monitoring all health, safety, and fire safety policies and practices?

Name(s): Md. Jahangir Kabir, Manager Compliance

8.8 Does the facility properly track health, safety, and fire incidents? Facility properly track health, safety, and fire

incidents. Documented record available.

8.9 Does the facility have a program and materials to train relevant individuals, including all individuals responsible for the supervision of workers, on all of the relevant occupational health and safety issues?

Facility have a program and materials to train relevant individuals, including all individuals responsible for the supervision of workers, on all of the relevant occupational health and safety. Documented training record available.

8.10 Does the facility have a written safety program, including written emergency procedures to handle natural disasters, fire safety, and emergencies and industrial accidents?

Emergency response procedure in-case of fire and earth quake and boom thread is defined etc are defined. Fire emergency action plan is displayed in the facility.

8.11 Are the following safety documents maintained by the facility?

a. Health and safety reports

Record available.

b. Heavy machinery inspection (boilers, compressors, etc.). Boilers, Compressors, Generator maintenance record

available.

c. Maintenance reports Production related machinery inspection record available.

d. Fire extinguisher records, noting date of inspection and expiration

Monthly monitoring documented record available which is attached with fire extinguisher. Management informed facility has system of visual daily monitor.

e. Emergency drill records, noting date and detailed results

Date of fire drill: 29/03/2014 Time: 02 min 10 second 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? If yes, please list the findings.

No such type documented noted.



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.

b. paint spray/spot cleaning booths Exhaust fan for ventilating at spot removing area was 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

8.14 Does a visual inspection of the entire facility premises suggest any concerns about the physical integrity of the facility?

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 building safety assessment. It was also observed that facility had conducted the 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:

Excellent

Good

Fair

Unacceptable

General the factory was well maintained and kept clean. Emergency exits are marked, machine layout is good with sufficient space between operating lines. All floors had sufficient lighting, ventilation and space for workers to work in a safe and healthy manner. The factory has fulltime cleaners who are continuously cleaning the floors and toilets.

8.16 Is the overall general appearance of the maintenance shop acceptable and not in a condition that can cause serious injury or harm?

Found conforming to the requirements



8.17 Is trash properly disposed of both inside and outside the facility? Separate and segregated wastage area is available in

the ground floor.

8.18 Are the toilets and washrooms in the facility in sanitary and serviceable condition and meeting minimum quantity required established by relevant law?

Toilets are meeting minimum quantity required established by relevant law. Total number of toilets129 are out of 65 toilets for female and 44 toilets for male and 20 toilets for staff.

8.19 Are exits unlocked during times when the facility is occupied to allow free, unobstructed exit from the facility?

Exits were found un-blocked and free from any obstacles

8.20 During the facility visit, were any aisles blocked or restricting easy access to emergency exits? Aisles found free from blockage.

8.21a Has the facility appropriately identified areas that, for fire safety purposes, should be designated as “non-smoking”?

Facility management does not allow smoking in the factory.

8.21b. Is the facility properly enforcing the “non-smoking” policy for areas so designated?

Inside the factory premises facility management does not allow smoking and also as per law of Bangladesh 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 recommended by a local medical provider?

As per legal requirement first aid supplies available.

8.22b. Are these first aid supplies available and accessible to all areas of the facility? First aid supplies were available as by the required

number and specification as per law.

8.23 Is there clean drinking water that is easily accessible at the facility? Clean drinking water available with test report.

8.24 Is drinking water provided at no cost to employees? Drinking water free to all workers.

8.25 Is the facility’s crèche/child-care area operated and maintained in a safe and healthy manner? Childcare room located in a separate shade.

8.26 Is the facility’s canteen/cafeteria operated and maintained in a safe and healthy manner? Canteen, dining operated and maintained in safe

healthy manner.

PERSONAL PROTECTION EQUIPMENT (PPE)

8.27 Does the facility conduct hazard assessments to determine if any PPE are required? Documented hazard assessment available also

displayed in production floor for workers awareness.

8.28 If PPE are required, is it provided to affected employees at no cost? Workers get PPE free of 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 responsible for maintaining electrical safety? If not, what is the facility doing to ensure electrical safety?

Facility’s Electrical engineer, Md,. Moshiur Rahma is responsible to maintaining electrical safety.

8.31 Does a visual inspection of the wiring indicate the following?

a. Good general condition of cabling Cables are well protected

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:

a. Complete enclosures with covers provided? Complete enclosures with covers of electrical boxes

and cabinets were found in facility tour.

b. Switches and outlets maintained in good working order? Switches and outlets maintained found in good

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 comprised of workers and management, which holds regular meetings and keeps minutes of proceedings?

The safety committee was formed comprising of management and workers.

8.34 Does the facility conduct an orientation health and safety and fire training for all new employees? Fire safety and health safety training conducted on

orientation program.

8.35 Does the training cover the following in regards to fire safety:

a. workers are informed of the locations of fire alarm pull and button stations

Included in regular training program.

b. workers are informed of the locations of fire extinguishers in and near their work area Included in regular training program.

c. workers have specific training concerning the dangers of smoke inhalation Included in regular training program.

d. workers are informed of location of nearest exits and assembly points Included in regular training program.

8.36 Is employee training conducted for first aid and safety? Documented training record available.



8.37 Are the first aid responders/emergency safety personnel properly identified and trained? First aid and emergency fire team were identified by

the separate dress code

8.38 Have selected employees been trained on the proper use of firefighting equipment?

Selected employees been trained on the proper use of firefighting equipment, documented training record available.

8.39 Have all employees who have any contact with chemicals been trained on how to safely handle and dispose of the specific chemicals and eliminate fire risk?

Documented training record available.

8.40 Are MSDS available (in appropriate language(s)) for all chemicals used by the facility?

During facility visit it was observed that MSDS was not found displayed for the spot lifter 833. 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 plan in the native language(s) posted in view of the facility's workers?

Evacuation plan posted in production floor in native language. Workers are well aware about evacuation plan. Verified in workers interview.

8.42 Does the facility conduct regular emergency evacuation drills (at least semi-annual)? List at least two drill dates (whether conducted and/or planned)

Date of fire drill: 29/03/2014 Time: 02 min 10 second Date of fire drill: 19/02/2014, Time: 02 min 18 second

8.43 Does a facility tour verify that there are an adequate number and location of unimpeded emergency exits that open outwards and lead to a safe assembly point?

Sufficient exit available as per legal requirements.

8.44 Does a facility tour verify that safety equipment are:

a. visible All fire safety equipments are found in in place &

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

f. unblocked and free of obstruction All equipments are found unblocked and free of 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 connections in usable condition? Tested in floor visit and found operative.

8.46 Does the facility have appropriate measures to ensure adequate water pressure for fire-fighting water hoses and sprinkler systems?

Facility does not have auto hydrant and sprinkler heads neither it was required by current fire licenses. Current hose rills are connected to overhead water 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 identified? During the floor visit it was noted fire alarms found

clean, unobstructed and identified.

8.49b. Does the facility have a test schedule for all fire alarm boxes?

State how the facility maintains this schedule.

As part of regular preventive maintained schedule facility maintain regular monitoring system to check fire alarm boxes. Frequency of fire alarm boxes test is 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 how they are stored.

Wastage area found properly identified & segregated.

EMERGENCY EVACUATION

8.51 Are lighting and alarm systems adequate and fitted with back-up systems? Lighting and alarm systems adequate and fitted with

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 in good condition? Emergency power system found working in good

condition.

8.52c. Does the facility regularly conduct a test to ensure the system is functioning properly? Facility regularly conducts a test to ensure the system

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 requirements of all relevant laws? All stair widths in compliance with legal requirements.

8.53d. Are the stairways provided with artificial and emergency lighting? It was noted stairways provided with artificial and

emergency lighting.

8.53e. Are stairwells completely clear of obstructions? Stairwells found completely clear.

8.53f. Does the facility ensure stairwells are not used for storage? Found free.

CHEMICAL SAFETY

8.54 Does the facility have a chemical safety program?

Facility does not require hazardous chemicals. Only for sweing machine, machine oil are using & for spot removing spot lifter 833 are using which are defined in the chemical safety program.

8.55 Where applicable, does the facility properly store hazardous/toxic materials? N/A

8.56 Does the facility have the required government storage and usage permits for chemicals, if required? N/A

8.57 Does the facility maintain documentation for chemical labeling (including fire safety), chemical usage warnings, and proper handling instructions?

Available in the chemical store area.

8.58 Does the facility ensure that all solvent wastes and flammable liquids are properly stored (including being kept in closed containers when not in use) at all times and kept away from potential ignition sources?

Facility does not realese any solvent wastes and flammable liquid.

8.59 Are the chemical storage areas free of ignition sources? Only mechine oils are using and found stored properly

no ignition sources were noticed.

8.60 Are all lamps and lights away from combustible chemicals? Yes all lamps and lights are away from combustible

chemicals

BOILER & COMPRESSOR ROOMS

8.61 Is the location of the boiler and compressor room consistent with all relevant requirements? (If no local or national laws apply, please describe the location of the boiler and compressor room.)

Location of the boiler and compressor room consistent with all relevant requirements. Verified during the floor visit.

8.62 Are there housekeeping and maintenance procedures in place for the boiler and compressor rooms?

Housekeeping and maintenance procedures in place for the boiler. Mr. Iqbal is responsible for boiler 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 serviced periodically?

Periodic record available.

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 authentic? Verified and found ok.

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 documents from government officials in order for the dormitories? Please identify and report any irregularities.

N/A

8.68 Does the dormitory have a written safety program, including written emergency procedures to handle natural disasters, fire safety, and emergencies and industrial accidents?

N/A

8.69 What is the overall general appearance of this dormitory:

Excellent

Good

Fair

Unacceptable

Not Applicable.

8.70 Does a visual inspection suggest concerns regarding the physical integrity of the dormitory building, proper lighting and ventilation, sanitary toilet areas, or clean dormitory facilities?

N/A

8.71 Does the facility have an emergency evacuation plan of the dormitories in the native language(s) posted in view of the facility's workers?

N/A

8.72 Does the facility conduct regular emergency evacuation drills (at least semi-annual) in the dormitories?

N/A



8.73 Does a dormitory tour verify that safety equipment are:

a. visible

N/A

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 class(es) of fires expected in the area N/A

8.74 Are exits unlocked during times when the dormitories are occupied to allow free, unobstructed exit from the dormitories?

N/A

8.75 During the dormitory visit, were any aisles blocked or restricting easy access to emergency exits?

N/A

8.76 Emergency Lighting

8.76a. Is appropriate lighting in place in the dormitory?

N/A

8.76b. Is the emergency power system working and in good condition?

N/A

8.76c. Does the facility regularly conduct a test to ensure the system is functioning properly?

N/A

8.77 Are all stairwell handrails in good condition within the dormitories?

N/A

8.78 Are all stair treads in good condition within the dormitories?

N/A

8.79 Are the stairways in the dormitories provided with artificial and emergency lighting? N/A

8.80a Are stairwells in the dormitories completely clear of obstructions?

N/A

8.80b. Does the facility ensure stairwells in the dormitories are not used for storage?

N/A



8.81 Are the assembly points for the dormitories located in safe locations? N/A

8.82 Is there clean drinking water that is easily accessible in the dormitories? N/A

8.83 Are the toilets and washrooms in the dormitories in sanitary and in serviceable condition?

N/A

8.84 Is trash properly disposed of both inside and outside the dormitory facilities?

N/A


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.

Non-compliances raised against this Principle: Historic Non-compliances raised against this Principle: 1.


2.


PRINCIPLE 9 FREEDOM OF ASSOCIATION & COLLECTIVE BARGAINING


9.1 Does the facility have written policies and procedures that recognize and respect the right of employees to exercise their lawful rights of free association?

The management has documented policy, procedures and practices to recognize and respect the lawful rights of free association and collective bargaining of workers.

9.2 Has the facility designated a qualified person with responsibility for communicating, deploying and monitoring the freedom of association practices as prescribed by labor law?


9.3 Does the facility have a union, association or collective representation of employees? Note: You are required to indicate whether there exists or not an informal or formal association of employees. If a lawful association of employees exists, include a representative of such association in the interview process.

No-union in the factory but company has a 23 members (07 from Management, 16 from Workers) Worker participation Committee (WPC) has been formed to settle the issues of the workers and to convey any complain/demand to the top management.

9.4 If a union or collective association which represents the employees exists, does the facility consult with the worker representatives on any issues that are a requirement by law such as facility disclosures, mass lay-offs, restructuring of the business etc.?

N/A

9.5 If the workers do have an organized group that addresses workplace issues, does this workers’ group operate free from coercion or illegal restrictions to its operations?

Workers Participation Committee (WPC) operates in the facility free from coercion or illegal restrictions to its operations.

9.6 If a lawful association of employees exists, is there any bargaining agreement or labor-management negotiation on workplace issues?

No

9.7 Are there formal communication procedures between worker representatives and management? Documented procedure available.

9.8 Does the facility enter into discussions with the workers representatives in an open manner and within the terms of local law?

Discussion with the worker representative is an open manner, after the meeting, minutes circulated in the notice board.

9.9 Are the minutes of facility / worker representative meetings documented and available to the workers?

Frequency of Meeting is monthly. Meeting minutes displayed on the notice board to communicate with all workers, also facility has a system to use PA system to communicate easily to all workers.

9.10 Are workers representatives elected on a free Workers representatives elected on a free and 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 associations?

No

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?

a. Facility Employees

b. Third Parties

Facility is communicating its policies and practices pertaining to this Principle to all facility employees.


9. FREEDOM OF ASSOCIATION & COLLECTIVE BARGAINING

Facilities will recognize and respect the right of employees to 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. Non-compliances raised against this Principle: 1. 2. 3.


4. 5. Historic Non-compliances raised against this Principle: 1. 2.


PRINCIPLE 10 ENVIRONMENT


10.1 Does the facility have an environmental management system relevant to its industry? Environmental management system is available.

10.2 Has the facility formally designated a qualified person with responsibility for communicating, deploying, and monitoring the environment practices elaborated upon in the environmental management system?


10.3 Does the facility have a program and materials to train relevant individuals on each practice of the environmental management system?

Training program available for material safety. Documented training record available. All workers related with chemical handling are well aware about chemical safety program.

10.4 Does the facility assess its ability to prevent and control harmful releases of industrial waste into the environment as a part of the environmental management system?

There is no process in the factory that would generate any harmful releases.

10.5 Does the facility maintain a detailed plan for handling accidental release or discharge of environmentally dangerous materials?

There is no process in the factory that would generate any harmful releases.

10.6 Does the facility maintain records of emission events? There is no process in the factory that would generate

any harmful releases.

10.7 Does the facility’s environmental management system address where and how solid, chemical, sanitary, and wastewater substances are disposed of?

Separate wastage area available.

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 officials, reveal any irregularities? If so, please comment on how the facility has addressed them.

N/A

10.9 Does the facility adequately communicate to all facility employees the relevant local and national laws and regulations as well as pertinent facility procedures concerning the environment Principle?

Local and national laws and regulation displayed in the notice board. As applicable to the facility processes, the management communicates to the employees the relevant local and national laws and regulations 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. Non-compliances raised against this Principle: 1. 2. 3. 4. 5. Historic Non-compliances raised against this Principle: 1. 2.


PRINCIPLE 11 CUSTOMS COMPLIANCE


11.1 Does the facility keep copies of all applicable customs laws and regulations? Customs Compliance Act

11.2 Do the facility’s policies and procedures on customs compliance cover the following requirements?

a. Facility complies with all applicable customs laws and maintains practices to comply with customs laws regarding illegal transshipment of products (in the event possible illegal transshipment activity, appropriate host government agency will be notified).

The company policy is documented and is part of Polices On Compliance & Human Rights It addresses all requirements of WRAP Principle 11

b. Monitors its productions on a per style basis.

The style and PO numbers are stated on all documents used to control from receipt of raw materials to delivery of finished goods.

c. Traces country of origin using records such as production, shipping, verification reports, quality control reports, and individual piecework sheets, for all inputs.

The policy lists documents maintained throughout the confirmation of order till delivery of finished goods.

d. Verifies production on an on-going basis on-site and at sub-contracting facilities. Production reports are maintained.

e. Maintains a facility machine inventory and updates it annually. Up to date list of Machines was available and is

regularly updated.

f. Ensures that the proper category designation is determined for all goods destined for the US market.

Product category designation is made of carton labeling.

11.3 Does the facility maintain an organized system of production documentation?

Detailed process control and monitoring records were available throughout the production process. PO/Style number ref was available in all documents.

11.4 Are the following records maintained? a. Records of the country of origin for all goods produced in the facility.

Country of Origin is issued by Chittagong Chamber of Commerce & Industry and is included with shipment documents.

b. A production profile of any subcontracting facility (the facility requests documents from the subcontractors when questions regarding goods produced at those facilities arise).

N/A



c. Production/purchase orders (with information such as conditions of production, payment, and finished product specifications).

PURCHASE ORDER 00109298, REF 1C359601 MIXD DELI, COONEEN DEFENCE LTD. UK

d. Raw material invoices (indicating country/origin/manufacturing facility). PURCHASE ORDER 00109298, REF 1C359601

MIXD DELI, COONEEN DEFENCE LTD. UK

e. Shipping/receiving documents (outgoing and incoming records of components/ inputs sent to or received from another facility).


f. Employee work records – accurate records of employee work hours that can be linked to the production of specific products.


g. Quality control records (which may include facility name and address, purchase 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 export date, exporting entity, destination, 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 traceable mark. PURCHASE ORDER 00109298, REF 1C359601


k. Machine inventory records, updated at least once a year. PURCHASE ORDER 00109298, REF 1C359601


l. Documented confirmation of the correct category and country of origin for goods through verification of correct country of origin such as binding rulings from the US 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 performance?

No sub-contracting.

11.5b What records are used?

Date and location of the verification

Product(s) verified

Purchasing company

Style number

Phase of production

Reference indicator for employee(s) performing operation

Name/stamp or signature of verifying official

No sub-contracting.

11.6 Has the facility designated a qualified person with responsibility for communicating, deploying, and monitoring customs compliance?

Name: Maruf Hasan, Manager Merchandizing

11.7 Does the responsible person ensure that origin determining documents are maintained for at least the period of record retention required by law?

Control of records-three years retention period

11.8 Does the responsible person ensure that all subcontracting facilities complete a production profile, and keeps such profiles on file?

Production manager kept production records & follow-up by commercial manager.

11.9 Does the facility verify production at subcontracting facilities when necessary through the review of requested documentation or personal visits (recording such instances of production verification and keeping on file)?

Supplier evaluation & inspection report

11.10 Does the responsible person stay current with possible illegal transshipment activity in the host country through communication with appropriate bodies such as the host government, trade association, contact with U.S. Customs, corporate importing office etc., and be responsible for maintaining files on any known transshippers or transshipment activities

The factory coordinates with the customers as the factory does not have any direct contact with regulatory bodies or US customs etc.



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. Non-compliances raised against this Principle: 1. 2. 3. 4. 5. Historic Non-compliances raised against this Principle: 1. 2.


PRINCIPLE 12 SECURITY


12.1 Does the facility have practices to guard against the introduction of contraband (e.g. drugs, explosives, biohazards, and/or other contraband)? Any non-manifested cargo will be referred to as contraband

Procedure available in Security Policy File and Security gate. Policy included weapons, ammunition, explosives, narcotics and other contraband items are included in it. Such items are never covered by any document and are always illegal. Awareness poster displayed with every security point.

12.2 Has the facility designated a qualified person with responsibility for communicating, deploying, and monitoring security policies and procedures?

Jahangir Kabir, Manager Compliance

Container Inspection

12.3a Does the facility have documented procedures in place to verify the physical integrity of the container structure prior to loading?

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 maintained to protect against the introduction of unauthorized material and/or persons. At point of 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 the locking mechanisms of the doors? Locking mechanism described in the procedure.



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

Right side

Floor

Ceiling/Roof

Inside/outside doors

Outside/Undercarriage

Documented seven point inspection records available. Security guard found well aware about Seven Point Check.

Trailer Inspection

12.4a Does the facility have procedures in place to verify the physical integrity of the trailer structure prior to loading, including the reliability of the locking mechanisms of the doors?

Facility using container for transportation of finished goods.

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

Rear - bumper/doors

Front wall

Left side

Facility using container for transportation of finished goods.

Container and Trailer Seals

12.5a Does the facility affix a high security seal to all loaded trailers and containers bound for the U.S.?

High security seal use on all loaded containers bound for the U.S. All seals meet or exceed the current PAS ISO 17712 standards for high security seals. Seals are printed with unique identifier such as company name,



logo, bar-coding or holography.

12.5b Do the seals meet or exceed the current ISO 17712 standards for high security seals?

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. Seals are printed with unique identifier number

12.5c Does the facility have documented procedures stipulating how seals are to be controlled and affixed to loaded containers and trailers?

Documented procedure available for the security safety of container and trailer.

12.5d Does the facility have documented procedures for recognizing and reporting compromised seals and/or containers/trailers to US Customs and Border Protection or the appropriate local authority?

Facility has Procedure for Missing/lost cargo report is filed with local Police Station and the customer is immediately informed and informed US Customs (if buyer is USA Based) dept hence. Therefore they will be informed in case of such incident. So far, no such incident has ever occurred.

12.5e Does the facility have designated employees for the distribution of seals for integrity purposes? Store I/C Mr. Emdadul Hoque is responsible for the

distribution of seals for integrity purpose.

Container and Trailer Storage

12.6a Is the security of containers and trailers located within the facility maintained? Are they in a secure area to prevent unauthorized access and/or manipulation?

Facility has secured loading unloading bay in front of the facility. 24 hour security guard present in loading unloading bay.

12.6b Does the facility have documented procedures in place for reporting and neutralizing unauthorized entry into containers/trailers or container/trailer storage areas?

Documented procedure in place for reporting and neutralizing unauthorized entry into containers or container storage area.

Physical Access Controls

12.7 Does the facility have a physical access control procedure?

Physical access control procedure found in place. Photograph of authorized personnel in the packing area, finished goods area, loading unloading area, is in place.

Employees

12.8a Does the facilities have an employee identification system in place for positive identification and access control purposes?

Facilities have an employee identification system in place for positive identification and access control purposes. Access control system established in packing area, finished goods area, bonded ware house.

12.8b Does the facility ensure that employees are only given access to those areas needed for the performance of their duties?

During facility tour It was observed finished goods stored at outside the finished goods storage area without any restricted access control. 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

12.8c Does the facility control the issuance and removal of employee, visitor and vendor identification badges?

Facility has control of assurance and removal of employee, visitor and vendors identification badges. Documented procedure available for issuance, removal and changing of access device.

12.8d Does the facility have documented procedures for the issuance, removal and changing of access devices (e.g. keys, key cards, etc.)?

Facility have an employee identification system in place for positive identification and access control purposes. Packing and finished goods access control system found in place.

Visitors

12.9 Do visitors present photo identification for documentation purposes upon arrival? All visitors should be escorted and should visibly display temporary identification.

Guards at main gate ask all visitors and vendors for their identity, if they get approval from the concerned personnel then escort them to the reception area where 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 upon arrival by all vendors? Arriving packages and mail should be periodically screened before being disseminated.

Written procedure available to check all incoming deliveries including mail. Security guard found well aware about the policy. Practice found in place.

Challenging and Removing Unauthorized Persons

12.11 Does the facility have documented procedures in place to identify, challenge and address unauthorized/unidentified persons?

Guards at main gate ask all visitors and vendors for their identity, if they get approval from the concerned personnel then they escort them to reception where there is a small meeting room for such purposes.

Personnel Security

12.12 Does the facility have documented procedures in place to screen prospective employees and to periodically check current employees?

Documented procedure in place, facility has system to screen prospective employees and to periodically check current employees. Pre- employment verification, background checks are to be performed. 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 information, such as employment history and

Documented procedure and record in place to verify applicant information, working experience history,



references, prior to employment? reference, address.

Background Checks / Investigations

12.14a Does the facility conduct background checks and investigations for prospective employees?

Facility conducting background checks and investigations for all prospective employee and Background checks and investigations by police conducted for all packing personnel, security guard and Loader.

12.14b Once employed, are periodic checks and reinvestigations performed based on cause, and/or the sensitivity of the employee’s position?

Periodic checks and reinvestigations system found in place for the workers working in Packing, Loading unloading and Security section.

Personnel Termination Procedures

12.15 Does the facility have procedures in place to remove identification, facility, and system access for terminated employees?

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 Head hand over charge including records, keys and others, Termination of employment, HR & 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 that all information used in the clearing of merchandise/cargo, is legible, complete, accurate, and protected against the exchange, loss or introduction of erroneous information? Documentation control must include safeguarding computer access and information.

Documented Procedure in place, policy included, to ensure that all information used in the clearing of merchandise/cargo, is legible, complete, accurate, and protected against the exchange, loss or introduction of erroneous information. Documentation control includes safeguarding computer access and information.

Manifesting Procedures

12.17 Are documented procedures in place to help ensure the integrity of cargo and that information received from business partners is reported accurately and in a timely manner?

Documented procedure in place, Procedure included, ensuring the integrity of cargo, procedures must be in place to ensure that information received from business partners is reported accurately and timely. 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 against information on the cargo manifest? Record available.

12.18b Is all cargo accurately described, and are the weights, labels, marks, and piece count indicated and verified?

The cargo is 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.

12.18c Does the facility verify departing cargo against purchase or delivery orders?


12.18d Are drivers delivering or receiving cargo positively identified before cargo is received or released?


12.18e Are documented procedures in place to track the timely movement of incoming and outgoing goods?

Documented procedure found in place.

Cargo Discrepancies

12.19a Are all shortages, overages, and other significant discrepancies or anomalies resolved and/or investigated appropriately?

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

12.19b Are customs and/or other appropriate law enforcement agencies notified if anomalies, illegal or suspicious activities are detected, as appropriate?

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

Fencing



12.20a Is there perimeter fencing enclosing the areas around cargo handling and storage facilities?

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 integrity and damage. Gates through which vehicles 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 area used to segregate domestic, international, high value, and hazardous cargo?

Cargo / covered van handing area segregated by stand and chain.

12.20c Is all fencing regularly inspected for integrity and damage? As part of regular facility monitoring process.

Gates and Gate Houses

12.21 Are gates through which vehicles and/or personnel enter or exit manned and/or monitored? The number of gates should be kept to the minimum necessary for proper access and safety.

Main entry gate is under coverage of security guard.

Parking

12.22 Are private passenger vehicles prohibited from parking in or adjacent to cargo handling and storage areas?

Private car entry prohibited to cargo handling and storage areas. Separate space for private car parking is available.

Building Structure

12.23a Are buildings constructed of materials that resist unlawful entry?

It was noted from security interview that as part of regular duty security personnel is responsible to visually inspect fencing of the building.

12.23b Is the integrity of structures maintained by periodic inspection and repair?

Buildings constructed of materials that resist unlawful entry. The integrity of structures maintained by periodic inspection and repair.

Locking Devices and Key Controls

12.24 Are all external and internal windows, gates and fences secured with locking devices? Management or security personnel must control the issuance of all locks and keys.

All external and internal windows, gates and fences secured with locking devices. Management or security personnel control the 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: entrances and exits, cargo handling and storage areas, fence lines and parking areas?

facility including the following areas: entrances and exits, cargo handling and storage areas, fence lines and parking areas.

Alarms Systems and Video Surveillance Cameras

12.26 Are alarm systems and video surveillance cameras utilized to monitor premises and prevent unauthorized access to cargo handling and storage areas?

Video surveillance cameras utilized to monitor premises and prevent unauthorized access to cargo handling and storage area.

Password Protection

12.27a Does the facility have automated systems for individually assigned accounts that require a periodic change of passwords?

Automated systems are in place to use individually assigned accounts that require a periodic change of password. IT security policies, procedures and standards are in place and provided to employees in 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 and provide them to employees in the form of training?

Documented policy and procedure is in place.

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? All system violators must be subject to appropriate disciplinary actions for abuse.

Defined in the IT security policy & procedure

Security Training and Threat Awareness

12.29a Does the facility have a threat awareness program in place and established and maintained by security personnel to recognize and foster awareness of the threat posed by terrorists and contraband smugglers at each point in the supply chain?

A threat awareness program established and maintained by security personnel to recognize and foster awareness of the threat posed by terrorists at each point in the supply chain. Employees aware of the procedures the company has in place to address a situation and how to report it. Additional training 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 a security situation and how to report it?

Reporting system found in place.

12.29c Does the facility give additional training to employees in the shipping and receiving areas, as well as those receiving and opening mail?

Specific training offered to assist employees in maintaining cargo integrity, recognizing internal conspiracies, and protecting access controls.



12.29d Does the facility undertake additional, specific training to assist employees in maintaining cargo integrity, recognizing internal conspiracies, and protecting access controls?

Training system found in place regarding maintaining cargo integrity, recognizing internal conspiracies and protecting access controls.

12.29e Do these programs offer incentives for active employee participation? Training program included incentives to active

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. Non-compliances raised against this Principle: 1. 2. 3. 4. 5. Historic Non-compliances raised against this Principle: 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.
