Overview of HRD and Compliance Performance of Readymade Garments Industry

Executive Summary:

The success of readymade garment exports from Bangladesh over the past two decades has surpassed the most optimistic expectations. The paper reviews the literature on this industry, presents recent data on the sector’s performance, and evaluates future trends in the international and domestic clothing industry. It concludes that although the impact of the flood was unexpectedly benign, the entrepreneurs face important challenges from the health of the domestic banking sector, the East Asian economic crisis, political unrest, worker unrest, corruption, and the deregulation of the global clothing business as a result of the phasing out of the Multi-fiber agreement in the year 2007.

The tremendous success of readymade garment exports from Bangladesh over the last two decades has surpassed the most optimistic expectations.  Today the apparel export sector is a multi-billion-dollar manufacturing and export industry in the country. The overall impact of the readymade garment exports is certainly one of the most significant social and economic developments in contemporary Bangladesh. Two million women workers employed in semi-skilled and skilled jobs producing clothing for exports, the development of the apparel export industry has had far-reaching implications for the society and economy of Bangladesh.

Bangladesh apparel exporters are likely to lose the protected market in the US and EU because of stiff competition from the major players, including China, India, Thailand and Pakistan during the post MFA era, according to the observers in the garments sector in Bangladesh. Once the quota regime passes into history, they feared, major buyers may not use Bangladesh as a source country on the ground that it has a handful of companies which serve the global market of the ready-made garments.

Bangladesh has already been facing tough competition in the US market from the Sub-Saharan and Caribbean countries due to USTDA-2000 (US Trade and Development Act-2000). A total of 72 Sub-Saharan and Caribbean countries have been enjoying this controversial advantage reducing Dhaka’s competitive edge.

Economists identified high lead time, less productivity comparing to other competing nations despite relatively low wages, poor law and order situation and infrastructure bottleneck as the major impediments for garment industries. In the absence of adequate number of backward linkage industries, duration of producing apparels take comparatively more time, as enterprises need to import raw materials and face an unnecessary delay due to bureaucratic Red Tape, sluggishness of customs formalities and the loading and unloading of ships. In order to shorten these periods, the garment manufacturers tend to force their workers into lengthy working hours when a large order comes in, but this arrangement, which ignores the workers basic right, is ineffective in both the short and long term in international business.

Introduction

Ready Made Garments (RMG) contributes 76% of total exports in Bangladesh. Major products of apparels include knit and woven shirts, blouses, trousers, skirts, shorts, jackets, sweaters, sports wears and many more casual and fashion items. The sector currently employs approximately 1.5 million workers, mostly females from underprivileged social classes (1). Clothing, being the largest industrial sector.

This is largely due to the simple level of technology needed by the industry. Moreover, relatively inexpensive and easily available machineries, requirement of smaller premises, abundant supply of cheaper work force, low tariffs on imported machineries and, most significantly, benefits of reserved markets by MFA quota have spurred the growth of the garment industry.

At present the country exports nearly 5 billion US$ per year to around 90 countries in the world which include USA, Canada, Germany, UK, France, Italy, Netherlands, Spain and Belgium. In fact, Bangladesh is the 6th largest supplier of apparels in the US market.

In order to export readymade garments, it is now almost mandatory for the exporters to disclose the quality parameters towards acceptance of the product as per the intended end use as decided by the Worlds leading brands. Knowledge in regulations pertaining to the area of flammability, care label and fiber products identification act are very important for export oriented garment trade, which is not only to satisfy the requirement of U.S. Federal Trade regulation but also to safeguard the interest of consumers. Performance evaluation of the garments is essential prior to shipment with a view to meet the specific requirement standards of the buyers. Working environment, wherein the garments are to be produced, is equally important to protect human rights and the code of conduct derives the basic objectives of social compliance issues. Thus, Bangladesh has a stiff challenge ahead to meet the demand of world market

The author during his pioneering work of setting up of an international laboratory i.e. MTL(now known as Bureau Veritas Consumer Product Services) inside the export processing zone in Dhaka, Bangladesh, had extensively glanced through the garment sector and in this paper he has made an attempt to highlight some of the essential international performance standards applicable to the export of RMG and the present quality status of export oriented apparels of Bangladesh. The code of conduct applicable to the workplace with particular reference to the creation of a better working environment in the apparel sector of Bangladesh has also been discussed by the author based on his practical experience in the social accountability.

Performance

In accordance with code of Federal Regulation, Title 16 CFR Part 1610 regulates flammability of general clothing textiles. This standard measures the speed and intensity of flame and ease of ignition. All items of wearing apparel must meet the criteria of Class 1, Normal Flammability. Fabrics classified as Class 2, intermediate flammability, although legal, are not acceptable for sale. Those that are Class 3, rapid and intense burning, can not be legally sold in the United States or imported into the United States from abroad.

Childrens sleepwear is covered under and must meet the requirements of 16 CFR Part 1615/1616 which measures fabric flammability by char length of burn. These standards protect children from serious burn injuries if they come in contact with an open flame, such as a match, lighter, or stove burner.

Garment samples were selected randomly for reputed brands of USA. Those samples were drawn from the bulk production by the experienced merchandisers of garment manufacturing units in Bangladesh and submitted for final testing. The Table 2 indicates that all the items are passed under Normal Flammability category with Class I standard. Burn code depicts the nature of burning character of the items. It is corroborated from the test results that flammability character of garments produced in Bangladesh is satisfactory according to the internationals.

Vendor Compliance

 Service Performance Survey

Dear Vendor Partner,

Divine textile ltd, and its employees, endeavor to maintain excellent standards of service, performance, and system integrity in all its activities.

In order to achieve such standards we have instituted a Service Performance Survey to obtain your valuable feedback. As a significant partner of Divine textile ltd, we believe it important to obtain our partners ongoing feedback in order to continually improve on the services that we provide.

Starting in January 2009, we plan to conduct routine and selective vendor surveys to obtain your valuable feedback on the quality, integrity and delivery of our services. The monthly surveys will be conducted by our Vendor Compliance team leaders and will include phone based and in-field (factory visits) assessments. Results from these surveys will aid in the continuing improvement and ongoing performance integrity of our services and will remain strictly confidential.

In the event that you are contacted to participate in this survey, we kindly ask that you provide us with a few short minutes of your time to assist us in this exercise. In the meantime, should you wish to contact us, please feel free to send us an e-mail at any one of the following addresses or call us at the following hotline: –

We very much appreciate your cooperation in ensuring that Divine textile ltd maintains excellent standards of performance, system integrity and service performance and look forward to our continued relationship and future growth together. Thank you.

Sincerely,

Middle Office – Vendor Compliance

 AUDITOR’S INSTRUCTION:

Employee Interview: (5 –10 minutes for each interviewees, the estimated time for whole interview process is about 40 minutes)

5 employees should be selected randomly for interview in order to obtain the evidence/information regarding the factory’s employment the labor conditions. Individual interview without the presence of factory management is recommended.

The questions should be asked in the interview will include but not limited to the following:

• What is your date of birth? (verify via ID/records)
• What is the date of hired by this factory?
• Is factory management withholding any of your salary/wages? Any evidence?
• Do you owe the factory any money? Any signed agreement?
• Does factory management hold your passport or identification card? Any receipt?
• Is overtime work optional or mandatory?
• What type of disciplinary practices does management employ? (Verbal /written warnings, required OT, monetary deductions)
• What is your regular and overtime rate of pay?
• Does your time card have all the time you worked including OT hours, rework?
• What are the most hours you work in a single day, week, month?
• Do you have at least one rest day per every 7 day period?

Remarks: The names of workers who have been interviewed should NOT be listed in the final audit reports while their names should only be recorded in the BV internal documents in case further verification is required from client.

2.    Employees’ personal files (For age verification and required paper work): (estimated time is about 20 minutes)

At least check 20% of employee files randomly for factories under 100 workers, and for factories with more than 100 workers, at least 20 employee files should be checked. If possible, copies of employee information reviewed should be kept.

Do not calculate the historical child labor.

3.    Hours of Work & Payroll Review: (estimated time is about 60 minutes)

At least 5 employees time cards & payroll records should be checked and recorded by the auditors. For the initial audit, the factory should provide one-year attendance record and less records will be accepted ONLY in some special cases with solid proof, e.g., new factory set up less than one year.

Time Cards / Records of most recent month should be checked firstly. The rest of the current year records (peak months) should be skimmed in order to find high hours of work and verify their compliance. If the factory have waiver for overtimes hours, the annual overtime hours should be calculated if necessary.

Time records must be verified with the production records or other relevant records (e.g., QC records, production quantity records…)

4.    Health & Safety issues

Auditors should look at the below issues during the factory tour:

•         Adequacy of fire extinguishers
•       Adequacy and accessibility of emergency exits in the factory (i.e., NOT blocked and locked during working hours)
•       Adequacy of functioning toilets
•       Presence of emergency shut off switches
•       Availability of clean drinking water
•       Proper conditions for dormitories
•       Proper conditions for dinning facilities
•       Proper conditions for medical facilities
•       Adequacy of well-stocked first aid kit

AUDIT PROCEDURES

Opening Meeting:

Short opening meeting should include the audit scope and criteria from Medona Fashions Ltd. and non-disclosure policy.

2.    Factory Tour Observation:

Production process

Quality Control Depart. – IQC, In process QC, Final QC.

Packaging Depart.

Warehouse/store – raw materials & finished goods

For Health & Safety issues, auditors should look at :

•         Adequacy of fire extinguishers
•         Adequacy and accessibility of emergency exits in the factory (i.e., NOT blocked and locked during working hours)
•         Adequacy of functioning toilets
•         Presence of emergency shut off switches
•         Availability of clean drinking water
•         Proper conditions for dormitories
•         Proper conditions for dinning facilities
•         Proper conditions for medical facilities
•         Adequacy of well-stocked first aid kit

3.    Document / record Review (if applicable):

Production records,

Machineries maintenance records, equipment calibration records

Training records, qualification certificates

Product test report/ functional test reports

Corrective & preventive action procedures and records,

Import / Export documents

Employee’s personal files

Attendance records (12 Months)

Payroll

Broken needle policy and records

Other relevant operation procedures and records,

4.    Employees Interviews:

Factory Manager – for quality assessment sections

Production personnel – for quality assessment sections

Quality Control personnel – for quality assessment sections

General Employee – for ‘Good Employment and Labor Practices’.

5.    Closing Meeting:

At the conclusion of the audit, the auditor must present/discuss all findings with factory management especially the corrective actions required. However, the audit result (e.g., Pass, Fail, Exemption Periods) should NOT present to the factory.

If applicable, auditor should fill out the “Summary of Factory Audit Findings” and ask the factory representatives to sign it on/after the closing meetings. Copy of the “Summary of Factory Audit Findings/ CAP” should be left to the factory.

All “yes” should carrying 1 positive marking.

CRITICAL POINTS:

Un authorized sub-contract.

Compensation/ benefits

Child/ Forced labour

Irregular Payment

Harassment and abuses

Weekend/ Holiday worked.

RESPONSIBILITY OF HRD DEPARTMENT

Management &  Administrative Work.

1.     Employee Required Requisition Approve by the Top Management.
2.     Employee Contract Form Approve by the Top Management
3.     Leave Application Approve by the Top Management
4.     Any kinds of the notice Approve by the Top Management
5.     Punch Card Issue & re-issue then transfer to the workers.
6.     Driver Attendance sheet cheek, holy day salary process and lunch bill process.
7.     Collect the complain letters from the complain boxes then communicate with the top management to solve the various problem.
8.     Any kinds of  mail receive & reply.
9.     All official format supply from HRD department.
10.                  Safety  Health & Work Environment Repot make monthly.
11.                  Monthly Training Attendance record collect from the floor and kept the file.
12.                  Training Plan Vis-à-vis Status Training Imparted make monthly.
13.                   Arrangement of paper advertisement about new man power required.
14.                  All format being printed through the printing press as a book let.VARIOUS RECORD MAINTAIN :

 Office Staff Personal File maintain.

1.     Maternity Leave file maintain.
2.     Various transfer file kept.
3.     Daily Check List File kept.
4.     Total employee punch card serial sheet kept.
5.     All COC Audit Result file maintain.
6.     Appointment Letter file kept.
7.     Various Meeting  Attendance Record file kept.
8.     Various Training Attendance record file.
9.     Company total manpower list file kept.
10.                      Various Format file kept.
11.                      Total Fire Extinguisher list file kept.
12.                      Total Company Machine List File kept.
13.                      Total Exit & Emergency Exit List.
14.                      Total Toilet List file kept.
15.                      Company bossier.
16.                      Company workers Hand Book maintain.
17.                      Job description file kept.
18.                      Minimum Competence Requirement file maintain.
19.                      Department wise Leave summary register.
20.                      Chemical & dyes List file.
21.                      Custom bond commitionaret file kept.
22.                      Disciplinary Action log file maintain.
23.                      Boiler Certificate File.
24.                      Fire License file
25.                      Environmental License file.
26.                      First Aid Boxes training file.
27.                      Fire fighting training record file.
28.                      Paper Advertisement file kept.
29.                      Employee out record file.
30.                      Mistake of punch card against the token issue maintain.
31.                      Various Notice file maintain.
32.                      Worker Register maintain etc.Various Meeting Arrangement :

1.     Floor wise Pre-Production Meeting.
2.     Floor wise Supervisor Meeting.
3.     Training Center meeting.
4.     Weekly Meeting About Production & others.
5.     Management Review Committee Meeting.
6.     Quality Control Meeting.
7.     Security Control Meeting.
8.     Neat & Clean (Nepcon) Meeting.
9.     Electrician Meeting.
10.                    Time Keeper Meeting.MANPOWER REQUIRED SYSTEM :

1.     Manpower Requisition Signature by Management Director and various Section.
2.     Paper circulation or Advertisement of new Employee.
3.     Manpower interview and post wise setup.
4.     Employee Appointment Letter or bio-data Verification and Signature by the Top management.
5.     name includes of Attendance Register or input the computer Data base system.
6.     New punch card issue.
7.     Attendance justification and Salary process.
8.     Salary Sheet Signature by HR Manager and hand over to A/C Department.
9.     Appointment Letter Issue to the employee.
10.  Attendance bonus sheet check & transfer to the A/C Department.
11.  Job Description Issue to the employee.Leave Work :

1.     All Leave entries to the Leave Register.
2.     Monthly Leave % count according to the section wise.
3.     Leave input to the computer data base system.
4.     Leave application signature by the authorized person.
5.     After allowing the leave then transfer to the various Dept/Section.
6.     Leave application kept the his/her personal file.
7.     To solve workers leave various problem.
8.     Maternity Leave Maintain.
9.     Special holy day notices draft and signature by top management then the notices hang to the particular notices board.Various Notice :
1.     Employee Awareness Notices.
2.     Government Holy day notice.
3.     Any kind of special holy day notice.
4.     Security Awareness Notices.
5.     Nepcon Awareness Notices.
6.     Any kinds of Company Audit Notices.
7.     Special General Duties Notices.
8.     Show cause Notices.
9.     Others Notices.Training :

1.     Fire Drill Training every month wise.
2.     New Employee Training Floor wise.
3.     First Aid boxes Training.
4.     Fire Fighting Equipment Training.
5.     Fire Extinguisher Handling Training.
6.     Unskilled Employee Training about Sewing Machine, Cutting Machine, QC Training, Supervisor Training.
7.     Kormojibi Nari Project Training.
8.     ISO 9001:2000 Training.COPLIANCE :

To solve the any kinds of workers problem.

1.     Water supply take care & assurance pure drinking water.
2.     Child Care Room take by HRD Department.Fire :

1.     Fire Alarm & Switch.
2.     Evacuation Procedures (Escape signs, Publish routes, Assemble Point).
3.     Fire Drill Schedules (Date, Time, Records etc).
4.     Fire Extinguisher (Worker condition/Qty, Unblocked/Access, Service Record, Training. Location Map Etc.)
5.     Water box, water & sent bucket.
6.     Auto Gas cylinder.
7.     Smoke Detector.
8.     Fire Blanket.
9.     Fire Fighting Equipment.Electrical :

1.     Register of equipment and safety certificate.
2.     No exposed wiring.
3.     Tripping hazards to be avoided.
4.     Isolation switches and area.
5.     Electrical Light Panels.
6.     Electrical Switch Board Area.
7.     Electrical Main Board Area.Needle :

1.     Floor Machine Check of needle.
2.     Needle Sheet Check of sub store.
3.     Broken needle kept point check.
4.     Fresh needle kept point check.Label :

1.     Label Check of of sub store.
2.     Label check of Garments Floor.
3.     Label Procedure Check.
4.     Order wise mark the label in the rack and kept it individually.Safety & Health.

1.     Full time Doctor & Trainee Nurse facility.
2.     Treatment Register Follow up.
3.     Medicine Register Follow up.
4.     Free medicine give the workers.
5.     Any workers to be accident at that time take Initiative sending to the hospital.First Aid Box.

1.     Training on First Aid Box by the Doctor and Nurse.
2.     First Aid Boxes check of each section.
3.     Medicine Requisition and kept the first aid boxes.CONSTRUCKTION WORK.

1.     Various Room partition.
2.     Various wall repairing.
3.     Various Furniture order and punches processing.
4.     Floor Road marking.
5.     Fire Extinguisher point selection & color marking.
6.     Any kinds of poster & notice binding & hanging in the particular place.
7.     Water supply tap setting & repairing.
8.     Toilet door repairing & coloring.
9.     Any kinds of COC equipment putting in the particulars place.(exit Light boxes, Exit board, etc.)FLOOR WORK :

Knitting Section :
1.     Section Name Follow up.
2.     Exit Light Box follow up.
3.     Evacuation Plan board check.
4.     Fire Alarm check.
5.     Lunch break Alarm check.
6.     First Aid box check.
7.     Attendance Cards or Register khata check.
8.     Employee absenteeism check.
9.     Road  marking  unblock.
10.              Floor neat & clean.
11.              Drinking water pot & glass check.
12.              Fire Extinguisher miter & date check and shout be unblock.
13.              Electrical board check & no exposed wiring.
14.              Auto fire Extinguisher check.
15.              Tally fire Extinguisher check.
16.              Electrical SDB board check.
17.              First Safety & No Smoking Board check.
18.               Broken needle box check.
19.              Workers personal box check.
20.              Exit board follow up.
21.              Any kinds of workers problem listen from the workers and solve the problem.
22.              Fire water box check & should be unblock.
23.              To kept the goods proper place.
24.              Enough toilet facility and neat clean.
25.              Soap, Sandal, Towel for toilet.
26.              Enough Complain & Advice boxes of toilet.
27.              Emergency road should be unblocked.
28.              Emergency Light box check.
29.               Emergency stair should be unblock.
30.              Ear sound pollution grade of knitting operator.
31.              Every window must be open.

Job Description As Compliance Officer

Check and ensure following are maintained:

1. Documentation :

• Copy of Minimum wage law.
• Wage structure for worker.
• Age verification procedure and certificate.
• Job application for workers.
• Child Labor law.
• Factories Employment policy and procedures.
• Workers terms and condition for employment (Contract)
• Corporate code of conduct.
• Appointment Letter.
• Termination letter.
• Letter for misconduct
• Minimum pay policy for piece rate workers.
• Maximum Daily working hours.
• Overtime for regular worker.
• Overtime for piece rate worker
• Leave policy

1. Leave register
2.   Casual leave.
3. Earned leave
4.  Medical leave
5.  Maternity leave
6.  Festival Holiday

• Group Insurance
• Fire Drill log
• Accident Log
• Training Register for Supervisor on Company policy, safety, awareness, supervisory procedures.
• Training register on Fire safety, First Aid, Evacuation team

      Workers Safety:

• Aisles to be kept clear and unblocked.
• Must have 1 extinguisher per 1000 square feet with traveling distance of 75 feet radius. Operating instruction in local language to be attached near the extinguisher and monthly check card to be attached with the extinguisher.
• Evacuation Floor plan in local language to be on floor.
• Battery operated EXIT lights to be posted on top of all exits.
• Floor to have proper aisle marking with arrow indication towards exits.
• Must provide 1 first aid box per 150 worker.
• Must have battery operated Fire alarm with activation procedure in local language
• Should have fully equipped First aid room with a full time nurse for a factory having workers above 500.
• Worker working with electrical heating elements, dry iron, etc to be provided with rubber mat.
• Rubber mat to be provided in front of all electrical distribution board.
• Danger sign to marked on all electrical distribution board.
• Yellow marking (box) in front of all exits, extinguishers, electrical distribution board to be done.
• Need to form proper trained uniformed fire fighters. Minimum 40% of the work force should also need to know how to use the extinguishers.
• Need to form proper uniformed First aid member, at least 2% of the work force need to be trained on First aid and CPR.
• Need to form proper uniformed Evacuation team member.
• All sewing machines to have pulley guards, needle guards. And any required guards that deemed to be required.
• Total use of THINNER is to be avoided.
• All workers to be provided with mask.
• Workers to be trained on health issues.
• Need to conduct one fire drill per month.
• Workers working on job by standing need to be provided with floor mats.

Health , Hygiene & Welfare:

• Need to provide safe drinking water.
• Need to provide clean toilets, requirement :
  • Female one toilet per every 25 worker.
  • Male 1^st hundred 4 toilet and next every 50 workers one toilet.
  • Sink or taps one sink or tap for every 50 workers.
  • Crèche for factory with more than 50 female workers.
  •  Need to provide dining space for workers.
  • Toilet should be cleaned at regular intervals and should use proper disinfectants.
  • Lights in production area should be between 50-60 foot candles.
  • Factory should have proper ventilations.
  • Temperature should not be above 86˚ Fahrenheit.

 Product Safety:

• Need to maintain Broken needle, replaced needle log.
• Maintain pin distribution procedure.
• ]Trimmers, scissors and pointers to be tied with draw string.
• No broken needle, pins etc should be inside machine oil bath.
• Machine maintenance card to be used.

The duties as Welfare officer shall be:

1. To establish contacts and hold consultations with a view to maintaining harmonious relations between the management of the factory and the workers.
2. To bring to the notice of the management of the factory the grievance of workers, individuals as well as collective, with a view to securing their expeditious redress.
3. to study and understand the point of view of the workers and to help the management and the workers to resolve their difference in the spirit of understanding and cooperation.
4. To watch industrial relations with the view to using his/her influence in the event of dispute arising between the management and workers and to help to bring about a settlement through mutual discussion and joint consultations.
5. To deal with wages and employment matters by joint consultation with the management and the workers representative body.
6. To promote health labor management practices.
7. To keep co-ordination with the medical officer of the factory for better services and treatment of workers.
8. To encourage the formation of work committee and joint production committee, co-operative societies and welfare committee and to supervise their working.
9. To look after the provision of amenities, such as dining, Crèche, adequate and clean latrine facility, drinking water and the like;

10. To help the management in regulating the grant of leave with wages and explain to workers the provision relating to leave with wages and leave privileges and to guide the workers in the matters of submission of applications for grant of leave and for regulating authorized absence.

11. To suggest Female workers on procedure on availing of maternity leave and how to get the maternity benefits and to keep tracks of  workers on Maternity leave and to check out the reason if workers does not join after availing the maternity leave and also check out the well being of workers those plan to avail maternity leave.

12. To suggest measure which will serve to raise the working and living conditions of the workers and promote their general well being.

13. To advise and brief workers on Use of PPE, Machine guarding, Sanitation, OSH, Fire Safety etc.

14. To work as advised by the Factory management.

  Child Labors Remediation Policy

DEFINITION:

Children labor is the under 15 year old employee.

Juvenile labor is the not yet enough 18 year old employee.

The discoverer is the related division or personnel inside or outside the company who discovers any case of children or juvenile labor.

Suitable work to children or juvenile is the work that doesn’t have any impact on their physical development, not dangerous and the total time of working and studying is no more than 10 hours a day or 42 hours a week.

The children ’s family representative: parents, grandparents, brothers or sisters, uncle and aunt or the conservator.

4. CONTENT:

The company forbids all the staffs to participate in or approve the use of children & juvenile labor in the company. If any case is found, do as the following procedure:

When discover the use of children & Juvenile labor, the Discoverer must report to the Administrative Department the name and department where the child is working in.

The Administrative Department has responsibility to cooperate with other related departments and employees to check the true age of the suspected. This check will base on methods such as direct interview with the employee, check the ID card or citizen record, birth certificate or even ask for help from the employee’s hometown. In addition, also check the education level, temporary place and the office where that employee is working in.

When find out about the true age, the Administrative Department informs the suspected and other people (if concern) and make a report to the board representative to carry out corrective actions as follows:

• Ø AS FOR CHILDREN LABOR:

– The Administrative Department discusses with the chief of the office where that employee is working in to assign him (her) a suitable job in the waiting-to-negotiate period. This period is normally no more than 3 weeks.

– The personnel manager will discuss with the child’s family representative about sending the child to school. The company will pay for the tuition, book….. The family representative must guarantee that he (or she) will go to school.

– Each quarter, the company will contact the family and school to update the inspecting sheet. As for health status, it will be updated every 6 months

– When the child is enough 18 years old, the company will invite the child to work in the company. If he (or she) doesn’t agree, then the relation between him and the company ends. The period that the child works for the company will be reserved for later regimes (such as social insurance, working seniority, compensation….) as regulated by the company.

Factory will also ensure that he/she will get his/her wages till 18 years.

• Ø AS FOR JUVENILE LABOR:

– The head of Administrative Department must discuss with the chief of the office where that employee is working in to assign him (or her) a suitable job.

– When the employee is enough 18 years old, the Administrative Department will remove the name of that employee out of the list of juvenile labor and inform the concerning parties, then update the inspecting sheet and make a record.

– The period that the juvenile employee work for the company will be reserved for later regimes (such as social insurance, working seniority, compensation….) as regulated by the company.

– The Administrative Department has responsibility to inspect that employee and update the inspecting sheet of juvenile labor (No : 0006)

DISCIPLINARY POLICY

We follow the Govt. labour law for taking any disciplinary action against any worker.

To discharge, dismiss or termination we follow the Labour Law of  – 2006 and  labour law -1965.

If a worker disobeying the factory law remaining absent willingly or become unruly alone or with other worker make any disturbance in the factory, disciplinary action will be taken against him/her.

If a worker himself or for giving job in the factory takes any bribe or any unlawful activity, disciplinary action will be taken against him/her.

Disciplinary action will be taken against a worker for his habitual regular absent without permission or if he remain absent without leave for more then 10 (ten) days.

For stealing company property, business property, un-true statement or for mis-conduct.

Habitual regular late attendance in work.

Habitual unlawful disobeying any law of the factory disciplinary action will be taken against a worker.

Any act like riot, disturbance or any kind of unlawful activity, disciplinary action will be taken.

Habitual unlawful negligence or cheating in work.

To instigate or instigating others for unlawful strike or go slow in work.

For destroying official documents, distort or adding falls statement.

Disciplinary action will be taken against a worker for disobeying lawful command of an officer or his superior. Before taking any disciplinary action against a worker we give time and chance to the worker to explain the incident. For giving punishment or to discharge we investigate the matter thoroughly and then we take action.

LEAVE POLICY

Leave procedure for all employees:

All kinds of leaves are granted as per Govt. labour law As per rules, annually a staff/worker will get the following leave with full pay.

Maternity Leave 16 weeks or 112 days with full pay.  For this a doctor’s certificate is required and she must have at-least six month services in the factory. She will get 8 (eight) weeks before delivery of child and 8 (eight) weeks after delivery of child. She must also produce a certificate from doctor that she has delivered a child.

1. For any kind of leave a worker must full fill the following terms and condition. Other wise leave will not be entertained.

2. A worker must complete one-year service in the factory if he wants earn leave which are mentioned in the Factory Law.  For maternity leave this period is six months only.

3.Casual and sick leave is under consideration of the factory management if a worker does not complete one-year service in the factory.

4.If any worker wants to go on leave, he/she must fill-up a leave application before two days and submit it to the factory management.  On special grounds this time is under consideration.

5. If the concerned officer approves the leave only then the worker will get the leave as per rules. Otherwise it will be treated as absent.

CERTIFICATION OF COMPLIANCE WITH ALL LEGAL OBLIGATIONS

Kohl’s Department Stores, Inc. (“Kohl’s”) is committed to full compliance with all laws, regulations, orders and rulings of all federal, state and local governments of all applicable countries, and all departments, boards, bureaus and commissions thereof (collectively “Laws”).  As a condition of entering into any purchase order, contract or other contracting or subcontracting agreement with Kohl’s, you and your contractors and subcontractors shall provide Kohl’s with a Written Assurance of full compliance with all laws and compliance with Kohl’s Terms of Engagement, receipt of which is hereby acknowledged.  Kohl’s will monitor your compliance with these Terms of Engagement at your expense.

Written Assurance

The undersigned Vendor warrants and certifies on behalf of itself and all of its contractors and subcontractors that all of the goods delivered to Kohl’s, pursuant to any purchase order, contract or agreement issued by Kohl’s, will be produced, manufactured, represented, described, labeled, advertised, sold, invoiced and shipped in full compliance with all existing laws, regulations, orders, and rulings of all federal, state, and local governments of all applicable countries and all departments, boards, bureaus and commissions thereof and in compliance with Kohl’s Terms of Engagement.  The undersigned Vendor acknowledges that Kohl’s will monitor Vendor’s compliance with Kohl’s Terms of Engagement at Vendor’s cost and expense.  Kohl’s reserves the right to deduct unpaid factory monitoring charges from your merchandise payments if our third party monitor does not receive your direct payment within 30 days of their invoice date.

The undersigned Vendor further warrants and certifies on behalf of itself and all of its contractors and subcontractors that the country of origin of all goods will be as listed on labels as required by laws, and that no convict, slave, child or indentured labor will be used by Vendor, its contractors or subcontractors.

In performing any activities on behalf of or related to Vendor, You will not, directly or indirectly, pay, offer, authorize or promise any monies or anything of value (such as gifts, contributions, travel, or entertainment) to any person or organization, including any employee of a customer, or any Government Official (which includes any employee or official of any governmental authority, government owned or controlled entity, public international organization, or political party or any candidate for political office) for the purpose of improperly influencing their acts or decisions or to improperly obtain a business benefit.  You will take appropriate actions to ensure that any person representing or acting under your instruction or control (“Your Business Representatives”) also will comply with this paragraph.  Neither You, nor to your knowledge Your Business Representatives, have violated any Anti-Corruption Laws in performing any activities on behalf of or related to Vendor. Vendor will not be required to take any action or make any payments that Vendor believes, in good faith, would cause it or its affiliated companies to be in violation of Anti-Corruption Laws.

The undersigned Vendor agrees to deliver to Kohl’s a complete and accurate Written Assurance within 24 hours of Kohl’s request with respect to any goods delivered, pursuant to a purchase order, contract or agreement issued by Kohl’s, that any allegation of a violation of law or contractor’s representations shall be a material breach by Vendor of any purchase order issued by Kohl’s and that Kohl’s may withhold and offset any amounts which may become payable to you by Kohl’s as a result of breach of Vendor’s Written Assurance.

Legal Operating Name of Vendor (Please Print)

Principal of Co. (Please Print)                                                                             Title

Principals Signature                                                                                            Date: