Social Compliance Manual for CAMIO USA Knitwear Limited

Objective

The objective of the study was to prepare a complete Social Compliance Manual for the Company of CAMIO USA KNITWEAR Ltd. This manual provides the procedures to set up social compliance for any Garments Industry.

It will also help in making better environment. Ensure motivational activity in the organization. This will also help to maintain a good employee relationship and a sound working environment in the organization.

Methodology

Before preparing this assignment through survey was conducted among the employee of the organization CAMIO USA Knitwear ltd. . First I have to visited various department and talked to the Departmental heads & related employee. I tried to mark their views and opinion which would help me to prepare the manual for them.

For example, how will be the procedures for personal protective equipment & how to use it, Electrical Safety, Documents required etc. I collected all of data after go through all of department. Then I tried to match it with the existing Labour Laws of the country also important buyers’ code of conduct.

Thus I prepared the draft of the total Compliance Procedures & Policies for the organization. All these draft were first given to al departmental head of the company. With all of their inputs and valuable suggestion it was modified and corrected where necessary. Then it was again verified with the relevant Labour laws and standard of renowned buyer.

Finally, it was prepared, published & distributed to as many employees as possible. To communicated these Compliance policies & procedures in CAMIO USA KNITWEA Ltd . At last, HR personnel conducted various awareness programs with the help of Welfare Officer to all employees.

LIMITATIONS

During preparation of the assignment, I actually could not receive the view of almost all the employees. Production department personnel always give priority production only. Sometimes they do not care regarding issues of safe working environment.

Again to match with existing practice of some polices by the employee of CAMIO USA Knitwear Ltd, it is a little bit difficult to maintain with this standard.

However, ultimately we tried to synchronize those standards with existing practise as much as possible. And we tried to make this standard easier for the employee in their day in day out practices.

Executive Summary

The purpose of this report was to examine the implications on Social Compliance in an Apparel Sector in Bangladesh. Research for this report included a review of current Practice & Various audit report regarding Social Compliance issues…

The major finding indicates that while there is a need for some caution, awareness should be seen as a way of enriching the standard of social compliance.

While it is clear that company needs take necessary action to develop and implement its current practise of social compliance standard to make a safe & good working conditions.

History Background

Social Compliance is now an important factor for any export oriented Industry. It not only emphasis on comply with existing labour law of country & buyers code of conduct as well. It also makes a working environment safer & comfortable for workforce.

INTRODUCTION OF SOCIAL COMPLIANCE

Social Compliance / Social Accountability are an important parameter in international business today, and buyers from major markets global markets, are increasingly insisting on adherence to social compliance norms.

Social Accountability is the measure of an organization’s state of being mindful of the emerging social concerns of internal & external stakeholders (community, employees, governmental and nongovernmental organizations, management, and owners). It is reflected in the organization’s verifiable commitment to certain factors (which may or may not be tied directly to its processes) such as (1) willing compliance with employment, health and hygiene, safety, and environment laws, (2) respect for basic civil & human rights, and (3) betterment of community and surroundings.

Social Compliance is the result of conformance to the rules of social accountability by the extended organization including not only the organization’s own policies and practices but also those of its supply and distribution chains. It is a continuing process in which the involved parties keep on looking for better ways to protect the health, safety, and fundamental rights of their employees, and to protect and enhance the community and environment in which they operate. A social compliance program is usually based on adherence to rules of social accountability, established by certified conformance to international standards such as SA8000.

Importance of Social Compliance for Leather Products & Footwear – Leather Products like Garments, Accessories, Small Leather Goods, & Footwear are termed life-style consumer products. In recent years, through the efforts of Human Rights Organizations and media, consumers have become increasingly aware of suspected unethical labor practices throughout the world. This knowledge has put pressure on retailers and manufacturers to ensure that they supply ethically manufactured products.

Until recently, the assumption that the manufacturers complied with local legal requirements was assumed to be monitored by local authorities. But retailers and manufacturers are beginning to act independently to ensure that fair and ethical labor practices are employed in the manufacture of their products. Doing so helps these companies ensure that their reputation is not tarnished by forces previously assumed to be out of their control.

Bangladesh is a sourcing destination for many international brands for leather products and as sourcing by some large American and European Buyers increased, it necessitated the advent of social compliance programs in the leather goods factories. All compliance programs are aimed at ensuring legal compliance to laws of the country/ region and going beyond that for improving workers’ conditions in the export-oriented factories. This is a relatively new business challenge for our industry, although major disturbing issues like child labor, minimum wages and health & safety at the workplace have been tackled quite successfully.

Major international players (Footwear Retailers, Dept Stores, Chain Stores etc) who insist on Social Compliance/Audits, are well-known retailers Like Levis, Puma, Adidas, Decathlon, Artsana, Inditex, who have also developed their own policies/ Code of Conduct (CoC). Many retailers request third party organizations to audit their suppliers’ for compliance to the COC. Some clients like Marks and Spencer, Tesco, Debenhams follow Sedex (Supplier Ethical Data Exchange) Methodology, if the facility is already certified for SA 8000, WRAP etc they wave off the Sedex audits. Retailers like Esprit, Migros, Metro follow the Business Social Compliance Initiative (BSCI) audit methodology, and Carrefour, Siplec and some French clients follow ICS certification.

IMPORTANT SOCIAL COMPLIANCE PARAMETERS:

Compliance with all national laws and regulations – Organizations are required to abide by all applicable laws, regulations and standards applicable to its particular industry under the national laws of the countries where the organization is doing business. Should the legal requirements and the standards of the industry conflict, organizations must comply with the laws of the country in which the products are being manufactured. Organizations should, however, strive to meet industry standards whenever possible. If state or local legal requirements apply to the organisation’s manufacturing activities, they must comply with the state and local requirements.

Employment practices – Organizations are to respect its employees and to strive to improve conditions whenever possible but in all instances to be in compliance with the specific requirements relating to employment conditions.

Wages & Benefits – Organizations shall provide wages, overtime compensation and benefits at not less than the minimum levels required by applicable laws and regulations or which are consistent with the prevailing local industry levels, whichever is higher.

Working Hours – Organizations shall maintain employee work hours in compliance with local standards and applicable laws of the jurisdictions in which they are doing business. Unless the national law is different, the maximum standard working time is 48 hours per week or 60 hours per week including 12 hours of overtime work

Child Labor –Exploitation of child labor or any vulnerable group (illegal immigrants for example) is totally unacceptable. No person shall be employed at an age younger than the legal minimum age for working in any specific country and in no circumstance shall any worker be younger than 14 years of age. In general, all children under the age of 18 must not be employed in hazardous work; not work night shifts; and are entitled to more breaks than adults.

Forced Labor – The use of forced or involuntary labor is unacceptable. Organizations shall maintain employment on a voluntary basis. They are not to directly or indirectly use in any manner, forced labor or prison labor.

Nondiscrimination / Human Rights – Cultural differences exist and different practices apply in various jurisdictions. However, all terms and conditions of employment should be based on an individual’s ability to do the job, not on the basis of physical characteristics or beliefs. Employees must not be exposed to physical punishment, threats of violence or physical, sexual, psychological or verbal harassment or maltreatment.

Freedom of Association – Organizations must recognize their employees’ rights to choose whether or not to associate with or establish any organization including labor organizations.

Working Conditions – Organizations must provide adequate working conditions for employees and comply with all applicable worker safety laws and regulations.

Social Compliance an overview

Whether it is large or small manufacturer, a traditional retailer or a supplier/sub-contractor – social accountability is the order of the day. Increasingly, the public and more importantly your consumer has become sensitive to how ‘business houses’ demonstrate accountability for social compliance along their supply chain.

Different Social Compliance Audits
Mainly, there are three types of SA audits. They are: Certifying audits such as SA 8000, which are universal. One can get an SA 8000 certification similar to that of ISO 9001:2000, buyers audit & audit of different apparel associations. Buyers & apparel associations have there own codes of conduct. They may not exempt a factory from their own COC audits just because the factory has got SA 8000.

Buyers who want to ensure social compliance in a company.
Almost all buyers located in US & Europe are looking for social compliance because this again their local statutory and regulatory requirement. Walmart, K mart, Disney, JC Penny are some famous & big groups that want to ensure social compliance before placing any order. Companies from other part of glob like Zara Internatiuonal, IKEA have also started to ask for compliance.

Related Regulation For Social Compliance Audit:

International Legislation:

ILO Convention
The United Nations’ Universal Declaration of Human Rights,
The UN’s Conventions on children’s rights and the elimination of all forms of discrimination against women,
The UN Global Compact and the OECD Guidelines for Multinational Enterprises and other relevant internationally recognized agreements,

National Legislation:

Labor Law 2006
Rules of Factories 1979
Industrial Relation 1969
Fire Safety Act 2006 & Amended 2011
Environmental Conservation Act 1995
Environmental Conservation Rules 1997
Custom Law
Bangladesh National Building Code 2006

A factory Social Audit

What is Social Audit?

The Social Audit (CSA) should be performed to ensure that company comply with Country’s rules & regulations in which social rights are respected.

Area to check during a Social Audit?

Child labor,
Forced labor.
Health & Safety.
Freedom of association and right to bargain.
Discrimination.
Disciplinary practices.
Working hours and Environment.
Compensation.
Management Systems.

Following a social audit, a Corrective Action Plan, explaining the required improvements and corresponding timetable to the factory.

Why should take place a social audit?

Dealing with a vendor who is not complying with international basic laws is not the right choice. Starting a proactive sustainable procurement approach could be valuable for a company.

The Simple Factory Audit should be performed before the buyer places an order with a new vendor and only takes one day. The Simple Factory Audit is done at your manufacturer’s premises, anywhere in Bangladesh.

Business Social Compliance Initiative (BSCI)

Business Social Compliance Initiative (BSCI) was founded in 2003 for the purpose of developing the tools and procedures for the European Business Social Compliance Programs. Business Social Compliance Initiative (BSCI) is the common European platform of retailers, industry and importing companies for monitoring and improving social standards in supplier countries for all consumer goods. The BSCI is based on the labour standards of the International Labour Organization (ILO) and other important international regulations like the UN Charter for Human Rights, as well as on national regulations. The Business Social Compliance Initiative (BSCI) was officially launched on 30 November 2004. It represents a coordinated effort by the European retail industry to implement a harmonized code of conduct and improve working conditions in supplier countries on a voluntary basis. The driving force behind the BSCI is the Brussels -based Foreign Trade Association (FTA), which is the association for European commerce lobbying particularly on foreign trade issues.

What are the benefits of the BSCI?

The benefits of the BSCI as a broad and comprehensive monitoring system for social standards in the supply chain are numerous:

Synergy effects, reduction of multiple auditing thereby reducing costs are one characteristic. Factories/companies which are being audited can improve their competitiveness through improved social standards as better working conditions and an improved management system leads to better product quality, higher productivity, fewer work accidents, less sick leave producing more highly motivated workers and lower staff turnover. The result of this is an improvement ethically, but also economically for both involved employers as well as employees. The economic advantages in this respect – in parallel taking into account the objectives to reduce excessive overtime and raise salaries where necessary, have been shown in research studies in this field. Therefore, benefits of the individual company also have a positive effect on the broad public.

Does the BSCI provide a certification?

The BSCI is not a certification system and therefore does not issue a certificate. The BSCI provides a specific process with uniform management instruments for Members, suppliers, auditors and qualifiers. This approach ensures uniform audit procedures and evaluation and therefore comparability of the results. If I do not get a certificate what do I receive as proof of the audit? The cover page of the audit report outlining the results and the validity of the audit can be displayed in the factory premises and be used as proof of the audit.

Which products are covered by the BSCI?

Audits within the BSCI can be conducted in any production facility worldwide. The type of articles covered by the BSCI varies widely. There are quite a number of department stores as members, who sell all sorts of soft goods, clothing, home textiles, small appliances, toys, and accessories. There are also members that focus on one particular product group, for example clothing stores, shoe retailers, baby products, or sports goods. For the implementation of the BSCI in the food industry, the BSCI has developed a special module for the primary production .

BSCI Social Requirements

Management Practice.
Documentation.
Working Time
Remuneration.
Child labour/Young Labour
Forced Labour/Discrepancy Measures/Prison Labour.
Freedom of Association and Collective Bargain.
No Discrimination.
Working Conditions.
Health and Social Facilities.
Occupational Safety and Health.
Dormitories.
Environment.

BSCI Best Practices for Industry

The BSCI currently recognizes SA8000 as its best practice. Some points of crucial important are as follows

Policy Establishment.
Proper Planning and Implementation.
Management Review.
Control of Subcontractors/Suppliers/Sub-suppliers.
Control of Home workers.
Compensation.
Child Labour.
Evasion.
Outside Communications

Commitment of BSCI audited companies

At present, BSCI audited companies have to commit themselves to auditing and integrating 2/3 of their soft goods suppliers or 2/3 of their buying volume in defined risk countries into the compliance program. SA8000 Auditors must carry out this auditing and integrating within a timeframe of 3 ½ years after joining the BSCI. The Supervisory Council checks the fulfillment

Immediate requirements:

Social :

Work/labor rights

Conditions of work

Safety at work (ILO 184)

Safe work environment

No forced labor (ILO 29&105)

Child labor prohibited (ILO 182)

Condition of employment

Minimum age (ILO 138)

Equal remuneration (ILO 100)

Workers empowerment

Freedom of association (ILO 87)

Collective Bargaining (ILO 98)

No discrimination at work (ILO 111)

Short-term requirements:

Environment:

Chemicals

Equipment and training on chemical use

Storage/disposal/waste

Management of chemicals

Waste

Pollution management

Disposal of waste

Water

Disposal of grey waters and run off

Social:

Social/human rights

Housing and sanitary facilities in place

Gender issues

Cultural/religion rights (ILO 169)

Indigenous rights

Minority rights

Work/labor rights

Conditions of work

Safety at work (ILO 184)

Training on safety issues

Safety equipments and emergency kits

Safe handling chemicals

Healthy work conditions

Access to safe drinking water

Access to sanitary facilities at work

Access to medical assistance/ insurance

Training requirements on site

No use of physical violence

Condition of employment

Contract labour policies and practices

Transparency of employment practices

Leave days clearly specified

Timely payment of wages

Minimum wage requirements

Work/labor rights

Condition of employment

Living wages to cover basic human

Services /savings

Maximum number of working hours set

BSCI Evaluation Scheme Structure of Audit

Part A – Recording Master Data: Business and master data of Supplier Company.

Part B – BSCI Audit: Recording and evaluation of compliance with minimum social and environmental requirements. The implementations of corrective actions arising from Part B are compulsory.

Part C – Recording and Assessment of Best Practice for Industry: Part C audit is compulsory; implementation of corrective actions arising from Part C is voluntary.

Following an initial audit where serious issues have been found, corrective actions may be required before arranging for a re-audit to close these out.

SGS is an accredited audit company for the BSCI program and has experience of conducting thousands of audits against this program with a dedicated Product Manager ensuring consistency across all countries.

Our global network of auditors enables a quick and cost-effective response in most major manufacturing areas; while dedicated key account managers can support large programs where BSCI members are seeking to monitor supply chains against BSCI requirements

C-TPAT VALIDATION PROCESS GUIDELINES

I. Introduction

The Customs Service has developed a validation process to ensure that C-TPAT participants have implemented the security measures outlined in their Security Profile and in any supplemental information provided to Customs. The validation process will be conducted jointly by U.S. Customs personnel and a representative of the industry participant. The validation will focus on the material in the participant’s C-TPAT security profile and any related materials provided by the participant and will be conducted under the guiding partnership principles of C-TPAT.

II. Objective

The purpose of the validation is to ensure that the supply chain security measures contained in the C-TPAT participant’s security profile have been implemented and are being followed. In the context of the company’s operations and the C-TPAT security recommendations, the validation team will evaluate the status and effectiveness of key security measures in the participant’s profile and make recommendations where appropriate.

III. Validation Principles

The guiding principle of the C-TPAT program is partnership. The C-TPAT program is voluntary and designed to share information that will protect the supply chain from being compromised by terrorists and terrorist organizations.

The validation process will enable Customs and the C-TPAT participant to jointly review the participant’s C-TPAT security profile to ensure that security actions in the profile are being effectively executed. Throughout the process there will also be the opportunity to discuss security issues and to share “best practices” with the ultimate goal of securing the international supply chain.

C-TPAT validations are not audits. In addition, they will be focused, concise, and will last not longer than ten work days.

Based on the participant’s C-TPAT security profile and the recommendations of the validation team, Headquarters will also oversee the specific security elements to be validated.

IV. Conducting a Validation

A. Validation Selection Process

To ensure their accuracy, the security profiles of C-TPAT participants will be validated. The order in which a C-TPAT participant’s profile will be selected for validation will be based on risk management principles. Validations may be initiated based on import volume, security related anomalies, strategic threat posed by geographic regions, or other risk related information. Alternatively, a validation may be performed as a matter of routine program oversight. Customs Headquarters will schedule a company’s first validation within approximately three years of the company becoming a C-TPAT certified participant. Customs field offices will not initiate validations and unannounced validations will not be conducted. C-TPAT participants will be given thirty days advance written notice along with a request for any supporting documentation that is needed.

B. Partnership Validation Teams

A Partnership Validation Team (PVT), consisting of Customs Office of Field Operations personnel and a representative of the C-TPAT participant, will conduct the on-site C-TPAT validation.

Customs representatives on a PVT will be officers knowledgeable in supply chain security matters. Customs PVT members will receive supply chain security training to assist them in working with industry representatives to promote effective corporate supply chain security programs. Customs Headquarters will determine the Customs representatives for each PVT. All Customs PVT representatives will be personnel from the Office of Field Operations.

The Customs Partnership Validation Team Leader (assigned by Customs Headquarters) will be responsible for the team’s reviewing the company’s security profile, other security information provided by the company, and data and information retrievable from other sources to determine the focus of the validation. This will help ensure that the validation is effective and limited in duration.

C. Validation Venue

A validation is an on-site review of the participant’s C-TPAT supply chain security profile. The actual site of the validation may vary depending on the aspect(s) of the participant’s profile that the “C-TPAT Validation Team” will review.

Under normal circumstances the validation will begin with a briefing of company officials at the domestic corporate office or facility of the C-TPAT participant. If additional data or information is required to validate a portion of a C-TPAT participant’s supply chain domestically or overseas, the PVT leader will request approval of travel through the Director, C-TPAT, at Customs Headquarters.

D. Validation Procedures

Upon receiving direction from Headquarters, Customs PVT leader will provide the company with a written notification of the scheduled validation. The notice will be issued at least thirty days prior to the start of the validation and will include a request for supporting documentation or materials, if any. The PVT leader will also contact the C-TPAT participant to establish a single point of contact at the corporate level.

Each validation will be customized for the participant involved and focused on the company’s C-TPAT security profile. Prior to the on-site validation, the Customs representatives on the PVT will review the participant’s C-TPAT security profile, any supplemental information received from the company, and any Customs Headquarters instructions, to determine the extent and focus of the validation.

In preparation for the on-site validation, the validation team may also consider pertinent C-TPAT security recommendations. A complete set of recommendations is included as Attachment A below. These security recommendations are a reference tool for considering the sufficiency of specific aspects of a participant’s C-TPAT security profile. It is understood that the recommendations are not mandatory and are not all-inclusive with respect to effective security practices.

As noted earlier, to begin the validation, the PVT will meet with company officials to discuss the process. Upon completion of the validation, the PVT will again convene with company officers to discuss validation findings. Although not a part of the PVT, the company’s Customs account manager will normally attend the company briefings that initiate and complete the validation process.

E. Validation Report

Validation findings will be documented, included in the team’s final report, and forwarded to the Director of C-TPAT for final editing and sharing with the C-TPAT participant. Ideally the report will affirm or increase the level of benefits provided to the participant. However, depending on the findings, some or all of the participant’s C-TPAT benefits may be deferred until corrective action is taken to address identified vulnerabilities. With respect to actions resulting from a validation, Customs authority will rest with the Executive Director, Border Security and Facilitation.

Guidelines

PREFACE

The following outlines the C-TPAT Security Recommendations that may be used by the C-TPAT Validation Team in the planning phase of an on-site validation. The recommendations are not mandatory for C-TPAT participation, but they may be helpful in the pre-validation review of key aspects of a participant’s C-TPAT security profile. Therefore, prior to conducting an on-site validation, the validation team may review and discuss appropriate security recommendations contained in these attachments in the context of the participant’s C-TPAT security profile. This will assist the team in limiting the scope of the validation and in customizing the validation to the C-TPAT participant involved.

IMPORTERS

Develop and implement a sound plan to enhance security procedures throughout your supply chain. Where an importer does not control a facility, conveyance or process subject to these recommendations, the importer agrees to make every reasonable effort to secure compliance by the responsible party. The following are general recommendations that should be followed on a case-by-case basis depending on the company’s size and structure and may not be applicable to all.

Procedural Security: Procedures should be in place to protect against unmanifested material being introduced into the supply chain. Security controls should include the supervised introduction/removal of cargo, the proper marking, weighing, counting and documenting of cargo/cargo equipment verified against manifest documents, the detecting/reporting of shortages/overages, and procedures for verifying seals on containers, trailers, and railcars. The movement of incoming/outgoing goods should be monitored. Random, unannounced security assessments of areas in your company’s control within the supply chain should be conducted. Procedures for notifying Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected, or suspected, by the company should also be in place.

Physical Security: All buildings and rail yards should be constructed of materials, which resist unlawful entry and protect against outside intrusion. Physical security should include perimeter fences, locking devices on external and internal doors, windows, gates and fences, adequate lighting inside and outside the facility, and the segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by a safe, caged or otherwise fenced-in area.

Access Controls: Unauthorized access to facilities and conveyances should be prohibited. Controls should include positive identification all employees, visitors, and vendors. Procedures should also include challenging unauthorized/unidentified persons.

Personnel Security: Companies should conduct employment screening and interviewing of prospective employees to include periodic background checks and application verifications.

Education and Training Awareness: A security awareness program should be provided to employees including the recognition of internal conspiracies, maintaining cargo integrity, and determining and addressing unauthorized access. These programs should offer incentives for active employee participation in security controls.

Manifest Procedures: Companies should ensure that manifests are complete, legible, accurate, and submitted in a timely manner to Customs.

Conveyance Security: Conveyance integrity should be maintained to protect against the introduction of unauthorized personnel and material. Security should include the physical search of all readily accessible areas, the securing of internal/external compartments and panels, and procedures for reporting cases in which unauthorized personnel, unmanifested materials, or signs of tampering, are discovered.

BROKERS

Develop and implement a sound plan to enhance security procedures. These are general recommendations that should be followed on a case-by-case basis depending on the company’s size and structure and may not be applicable to all.

Procedural Security: Companies should notify Customs and other law enforcement agencies whenever anomalies or illegal activities related to security issues are detected or suspected.

AIR CARRIERS

Conveyance Security: Aircraft integrity should be maintained to protect against the introduction of unauthorized personnel and material. Conveyance security procedures should include the physical search of all readily accessible areas, securing all internal/external compartments and panels, and reporting cases in which unmanifested materials, or signs of tampering, are discovered.

Access Controls: Unauthorized access to the aircraft should be prohibited. Controls should include the positive identification of all employees, visitors and vendors as well as procedures for challenging unauthorized/unidentified persons.

Procedural Security: Procedures should be in place to protect against unmanifested material being introduced aboard the aircraft. Security controls should include complete, accurate and advanced lists of international passengers, crews, and cargo, as well as a positive baggage match identification system providing for the constant security of all baggage. All cargo/cargo equipment should be properly marked, weighed, counted, and documented under the supervision of a designated security officer. There should be procedures for recording, reporting, and/or investigating shortages and overages, and procedures to notify Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected or suspected by the carrier.

Manifest Procedures: Companies should ensure that manifests are complete, legible, accurate, and submitted in a timely manner to Customs.

Personnel Security: Employment screening, application verifications, the interviewing of prospective employees and periodic background checks should be conducted.

Education and Training Awareness: A security awareness program should be provided to employees including recognizing internal conspiracies, maintaining cargo integrity, and determining and addressing unauthorized access. These programs should encourage active employee participation in security controls.

Physical Security: Carrier’s buildings, warehouses, and on & off ramp facilities should be constructed of materials which resist unlawful entry and protect against outside intrusion. Physical security should include adequate locking devices for external and internal doors, windows, gates and fences. Perimeter fencing should also be provided, as well as adequate lighting inside and outside the facility; including parking areas. There should also be segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by means of a safe, cage, or otherwise fenced-in area.

SEA CARRIERS

Conveyance Security: Vessel integrity should be maintained to protect against the introduction of unauthorized personnel and material. Conveyance security should include the physical search of all readily accessible areas, the securing all internal/external compartments and panels as appropriate, and procedures for reporting cases in which unmanifested materials, or signs of tampering, are discovered.

Access Controls: Unauthorized access to the vessel should be prohibited. Controls should include the positive identification of all employees, visitors, and vendors. Procedures for challenging unauthorized/unidentified persons should be in place.

Procedural Security: Procedures should be in place to protect against unmanifested material being introduced aboard the vessel. Security procedures should provide for complete, accurate and advanced lists of crews and passengers. Cargo should be loaded and discharged in a secure manner under supervision of a designated security representative and shortages/overages should be reported appropriately. There should also be procedures for notifying Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected, or suspected, by the company.

Manifest Procedures: Manifests should be complete, legible, accurate and submitted in a timely manner pursuant to Customs regulations.

Personnel Security: Employment screening, application verifications, the interviewing of prospective employees and periodic background checks should be conducted.

Physical Security: Carrier’s buildings should be constructed of materials, which resist unlawful entry and protect against outside intrusion. Physical security should include adequate perimeter fencing, lighting inside and outside the facility, and locking devices on external and internal doors, windows, gates, and fences.

LAND CARRIERS

Conveyance Security: Integrity should be maintained to protect against the introduction of unauthorized personnel and material. Conveyance security procedures should include the physical search of all readily accessible areas, securing all internal/external compartments and panels, and procedures for reporting cases in which unmanifested materials, or signs of tampering, are discovered.

Physical Security: All carrier buildings and rail yards should be constructed of materials, which resist unlawful entry and protect against outside intrusion. Physical security should include adequate locking devices on external and internal doors, windows, gates and fences. Perimeter fencing should be addressed, as well as adequate lighting inside and outside the facility, to include the parking areas. There should be segregation and marking of international, domestic, high-value, and dangerous goods cargo within the warehouse by a safe, caged or otherwise fenced-in area.

Access Controls: Unauthorized access to facilities and conveyances should be prohibited. Controls should include the positive identification of all employees, visitors, and vendors as well as procedures for challenging unauthorized/unidentified persons.

Procedural Security: Procedures should be in place to protect against unmanifested material being introduced aboard the conveyance. Security controls should include the proper marking, weighing, counting, and documenting of cargo/cargo equipment under the supervision of a designated security representative. Procedures should be in place for verifying seals on containers, trailers, and railcars, and a system for detecting and reporting shortages and overages. The timely movement of incoming and outgoing goods should be tracked and there should be procedures for notifying Customs and other law enforcement agencies in cases where anomalies or illegal activities are detected or suspected by the company.

Manifest Procedures: Companies should ensure that manifests are complete, legible, accurate, and submitted in a timely manner to Customs.

Personnel Security: Companies should conduct employment screening and interviewing of prospective employees to include periodic background checks and application verifications.

AIR FREIGHT CONSOLIDATORS/OCEAN TRANSPORTATION INTERMEDIARIES, AND NVOCCS

Procedural Security: Companies should notify Customs and other law enforcement agencies whenever anomalies or illegal activities related to security issues are detected or suspected.

Documentation Processing: Consolidators should make their best efforts to ensure that all information provided by the importer/exporter, freight forwarder, etc., and used in the clearing of merchandise/cargo, is legible and protected against the exchange, loss or introduction of erroneous information. Documentation controls should include, where applicable, procedures for:

Maintaining the accuracy of information received, including the shipper and consignee name and address, first and second notify parties, description, weight, quantity, and unit of measure (i.e. boxes, cartons, etc.) of the cargo being cleared.

Recording, reporting, and/or investigating shortages and overages of merchandise/cargo.
Tracking the movement of incoming and outgoing cargo.

Safeguarding computer access and information.

Companies should participate in the Automated Manifested System (AMS) and all data submissions should be complete, legible, accurate and submitted in a timely manner pursuant to Customs regulations.

Personnel Security: Consistent with federal, state, and local regulations and statutes, companies should establish an internal process to screen prospective employees, and verify applications. Such an internal process could include background checks and other tests depending on the particular employee function involved.

WORLDWIDE RESPONSIBLE ACCREDITED PRODUCTION (WRAP)

The Background of WRAP

Worldwide Responsible Accredited Production (WRAP) is an independent, non-profit corporation dedicated to the promotion and certification of lawful, humane, and ethical manufacturing throughout the world. The WRAP Principles have received the public endorsement of the American Apparel Manufacturers Association (AAMA) Board of Directors in 1998. More recently, the Principles have been endorsed by groups representing apparel manufacturers from 18 countries. The principles cover basic standards that address labor practices, factory conditions, and environmental and customs compliance.

WRAP Principles Consist of Twelve Elements

Compliance with Laws and Workplace Regulations
Prohibition of Forced Labor
Prohibition of Child Labor
Prohibition of Harassment or Abuse
Compensation and Benefits
Hours of Work
Freedom of Association and
Collective Bargaining
Health and Safety
Prohibition of Discrimination
Environment
Customs Compliance
Security

WRAP Certification Process

Step 1: Application: Manufacturer first contacts WRAP for an audit request and sends back the completed application form and fee to initiate the certification process.

Step 2 : Self-Assessment: The facility must adopt procedures described in the WRAP Handbook and provide evidence they have been implemented for at least 45 days (not less than 90 days for new applicants).

Step 3 : Monitoring: The facility then chooses and contacts a WRAP certified auditing firm to get audited. The report and recommendations are sent to both the facility and WRAP.

Step 4 : Evaluation: WRAP Staff may notify the facility that it needs to correct certain procedures and have the monitor make an additional inspection and report or may recommend to the Certification Board that the factory be certified.

Step 5 : Certification: The Certification Board studies the recommendation of the staff, including the monitor’s report, and votes to award or withhold certification.

Certification may be granted for six months or one to two years, depending on the final audit results and the length of time that the facility has held certification successfully.

SGS

SGS has WRAP approved auditors in most major sourcing countries and is able to provide consistent monitoring and reporting to support certification recommendations. With over 10 years’ experience of undertaking WRAP audits SGS is able to guide companies through the process while ensuring that professional audit standards are maintained.

SGS Basic Code of Conduct program Consist of Nine Elements

Child and Young Labor
Forced Labor
Health and Safety
Freedom of Association
Discrimination
Disciplinary Practices
Working Hours
Compensation
Environment

SGS Basic Quality System Audit Program Consist of Eight Elements

Purchase Control
Incoming Material Control
Process Control
Calibration of Measurement Equipment
Inspection of Finished Product
Random Product Inspection
Continuous Improvement
Quality Assurance Records

SGS Basic Security Audit Program Consist of Eight Elements

Physical Security
Warehouse/Conveyance Security
Access Control
Electronic and Security Staff Investments
Procedural Security
Personnel Security
Education and Awareness Training
Service Provider Security

Integrated Approach

Code of Conduct Audit Solutions are often combined with other programs such as Quality, Environment or Security, as well as audits against Counterfeit Products, to provide a cost and time-effective mechanism thus ensuring conformance to local law and regulatory, and other industry requirements such as ISO 9001, ISO 14001, or SA 8000 requirements.

SGS can offer a “one stop” and complete vendor evaluation program to include “capability and capacity” audits and Corporate Social Responsibility monitoring requirements, including Human Rights and the Environment. This offers increased efficiency and business opportunities to meet the multiple criteria demanded by diverse buyers and a source of competitive advantage where larger buyers seek to rationalize their supply chains.

ETI (Ethical trade Initiative)

ETI is a UK-based alliance of companies, trade unions and NGOs dedicated to improving the lives of workers and their families in global supply chains. It focuses on companies producing, supplying and selling goods for consumer markets. The organisation identifies and promotes responsible corporate practices that observe national and international labour laws. Recognised by almost all UK retailers, ETI has established an international reputation for combining a practical focus with a critical but balanced view of labour rights issues. ETI members must adhere to a code of labour practices based on key conventions of the International Labour Organisation and accompanied by a set of general principles.

Code of Conduct audits

In addition to operating within the highest standards of business ethics in accordance with applicable local laws, many businesses choose to go a step further. They expect their vendors to maintain these same high standards

Technical Audit and Factory Evaluation

To ensure your vendors and suppliers are able to undertake a specific order as per your requirements, we carry out technical audits at their business premise. This process establishes a manufacturer’s ability to design and produce according to your legal or normative requirements. Audits are conducted to any checklist specified. Alternatively, our experienced auditors can compile a checklist to match your requirements.

Code of Conduct

Compliance with Laws

Suppliers and their designated manufacturing facilities (“Suppliers”) must fully comply with all applicable national and/or local laws and regulations, including but not limited to those related to labor, immigration, health and safety, and the environment.

Voluntary Labor

All labor must be voluntary. Child, forced, bonded, prison, or indentured labor will not be tolerated. Workers must be allowed to maintain control over their identity documents. Suppliers must provide workers with rest days and must ensure the working hours are consistent with local regulations and not excessive.

Hiring and Employment Practices

Suppliers must implement hiring practices that accurately verify workers’ legal right to work in the country and age prior to employment. All terms and conditions of employment including, but not limited to, hiring, pay, promotion, termination, and retirement must be based on an individual’s ability and willingness to do the job.

Compensation

Suppliers must compensate all workers with wages, overtime premiums, and benefits that meet or exceed local legal standards, local industry standards, or collective agreements, whichever are higher. Suppliers are encouraged to provide wages and benefits that are sufficient to meet workers’ basic needs and provide some discretionary income for workers and their families.

Freedom of Association and Collective Bargaining

Suppliers must respect the right of workers to choose whether to lawfully and peacefully form or join trade unions of their choosing and to bargain collectively.

Health and Safety

Suppliers must provide workers with a safe and healthy work environment and, where applicable, safe and healthy residential facilities. Suppliers must take proactive measures to prevent workplace hazards

Environment

Suppliers must ensure every manufacturing facility complies with national and local environmental laws, including all laws related to air emissions, water discharges, toxic substances and hazardous waste disposal. Suppliers must validate that all input materials and components were obtained from permissible harvests consistent with international treaties and protocols in addition to local laws and regulations.

Gifts and Entertainment

Suppliers must not offer gifts or entertainment to Comapys associates.

Conflicts of Interest

Suppliers must not enter into transactions with company’s associates that create a conflict of interest.

Anti-Corruption

Suppliers must not tolerate, permit, or engage in bribery, corruption, or unethical practices whether in dealings with public officials or individuals in the private sector.

Financial Integrity Suppliers must keep accurate records of all matters related to their business w in accordance with standard accounting practices .

Disciplinary Practices

Vendors shall not use corporal punishment or any other form of physical or psychological coercion or intimidation against workers.

Wages and Benefits

Vendors shall provide wages and benefits that comply with all applicable laws and regulations or match the prevailing local manufacturing or industry rates, whichever is higher. Overtime pay shall be calculated at the legally required rate, regardless of whether workers are compensated hourly or by piece rate.

Working Hours

Vendors shall not require workers to work, including overtime, more than 60 hours per week or more than any maximum number of hours per week established by applicable laws and regulations, whichever is less. Vendors shall guarantee that workers receive at least one day off during each seven-day period.

Contractors and Suppliers

Vendors shall ensure that their contractors and suppliers adhere to this Code of Conduct.

Monitoring of Compliance

Vendors principals to conduct scheduled and unscheduled inspections of Vendors’ facilities for the purpose of ensuring compliance with this Code of Conduct. During these inspections, its principals shall have the right to review all employee-related books and records maintained by Vendors and to interview workers.

Familiarization and Display of This Code of Conduct

Vendors shall familiarize workers with this Code of Conduct and display this Code of Conduct, translated in the local language, at each of their facilities in a place readily visible and accessible to worker.

Social Codes of Conduct in the RMG Industry

Voluntary Codes of Conduct

Social codes of conduct are rules and guidelines imposed by buyers upon themselves and along their supply chains, both in response to consumer pressure and as part of comprehensive marketing strategies aimed at improving their image.
Social and environmental standards as outlined in the Bangladesh Labor Law and Environmental Act set out minimum standards to which manufacturers in Bangladesh must adhere. In contrast, compliance with general codes of conducts, which usually contain standards slightly higher than those defined by the Bangladesh laws, is voluntary.
The social compliance status of the Bangladesh RMG industry refers to the extent to which the industry meets the requirements of the labor law and/or any other buyer-specific code of conductor voluntary certification scheme.
The current social compliance status of the industry is not satisfactory; there is an urgent need to improve the situation.

The voluntary codes of conduct most widely used by the RMG sector include those of:

Social Accountability International (SAI) – SA8000
Ethical Trading Initiative (ETI)
Fair Labor Association (FLA)
Fair Wear Foundation (FWF)
Business Social Compliance Initiative (BSCI)
Worldwide Responsible Apparel Production
(WRAP).

Only WRAP and SAI have certifications for factories, whereas FLA certifies brands, not factories. The other above-mentioned codes of conduct do not have any certification options.

Generally, adherence by a particular manufacturer to a given standard or code of conduct is verified through periodic audits/ inspections. These inspections are carried out by buyers and/or thirdparty auditors nominated by the buyers.

Bangladesh Labor Law 2006 (BLL 2006) Implementation of the BLL 2006 is monitored primarily by Ministry of Labor and Employment (MoLE) factory inspectors and BGMEA and BKMEA social compliance monitors. Besides inspecting and monitoring the status of the factories, BGMEA and BKMEA monitors provide advisory support to factory personnel so that they are able to implement the required, correct measures as stated in BLL 2006.

General codes of conduct (CoCs) are usually voluntary and developed using a multi stakeholder approach. SA8000, ETI, WRAP, BSCI, FWF and FLA are some of the prevailing general CoCs.

Corrective Actio

When violations are found, Company and the Vendor will determine a corrective action plan to eliminate the problem in a timely manner. If it is identified that the Vendor is knowingly and/or repeatedly in violation of this Code of Conduct, Company and its principals shall take necessary action which may include cancellation of orders and/or termination of business with the Vendor in question.

Standard Code of Conduct

Compliance with Laws

Standard requires, at a minimum, that its suppliers are in compliance with all laws and regulations in the communities and countries where the suppliers and their designated factories operate. This standard is also applicable to all sub-contractors producing merchandise for sale by Walmart. In addition to laws and regulations pertaining to labor, immigration, health and safety, and the environment, compliance with laws and regulations extends to other matters such as intellectual property rights, labeling, documentation and certifications.

Voluntary Labor

All labor must be voluntary. Child, underage, forced, bonded, prison, or indentured labor will not be tolerated. Workers must be allowed to maintain control over their identity documents. Suppliers must provide workers with rest days and must ensure that the working hours are consistent with the regulation and not excessive.

Employment must be on a voluntary basis and thus workers must be able to terminate the employment relationship at any time with reasonable notice. Workers must be able to freely leave the locale (municipality, country, etc.) and therefore it is essential the workers maintain control over their identity documents. Forced, prison, and child labor are prohibited and those factories that are found to have violated this provision will cease to produce merchandise for standard and all merchandise produced will be subject to destruction.

Suppliers and factories found to have used child labor will be asked to remediate the situation by implementing a satisfactory solution that places the best interest of the child first.

Suppliers and factory management must ensure working hours are not only consistent with local laws and regulations but also are not excessive. In the absence of regulations regarding working hours and rest days, employers must provide workers with rest days.

Specifically:

Child Labor, Underage workers and juvenile (minor) workers

o Child Labor: Factories are prohibited from employing any workers under the age of 14 regardless of local and national regulations.

o Under age workers: Factories are prohibited from employing workers below the minimum working age as defined by local and national regulations. All workers must be at or above the legal minimum age at time of employment.

o Juvenile (minor) workers: Where a national law specifies juvenile (minor) employment restrictions or requirements, the factory must demonstrate their compliance with the local legal requirements.

o Factories must have age-verification procedures that are effectively implemented. The personnel (personal) file of each worker must contain copies of identification documents (such as birth certificates, national ID cards or school certificates) submitted by the worker as proof of age and education (where applicable).

Forced Labor

o All forms of prison or forced labor are prohibited as well as any subcontracting arrangement with prisons is prohibited.

o Any restrictions for workers to voluntarily end their employment, such as, excessive notice periods or substantial fines for terminating their employment contracts, are prohibited.

o Factories must grant employees permission to leave the factory under reasonable circumstances, such as personal or family emergencies, without disciplinary penalty. Factories must never physically prevent or delay workers from leaving the facility or its grounds.

o Factories must not require or allow employment agents to require any monetary deposits or keep any original identification documents. The

practice of deposits (money/original identification) may prevent workers from freely ending their employment (within the legal context).

Working Hours

o Overtime must be strictly voluntary. Any form of pressure to perform overtime is prohibited.

o Factories must comply with local and national regulations regarding limitations on overtime hours. If local and/nor national regulations regarding the number of maximum overtime hours that may be worked by individual workers do not exist, then the working hours should not exceed 60 hours per week consisting of a maximum of 48 hours of regular hours and 12 hours of overtime.

o Factories must meet the requirements for working hours as stipulated by the local and national regulations.

o Schedules implemented by factories must be in compliance with national and local regulations where the regular workday, workweek, rest days and/or holidays are defined.

o Where regulations do not specify rest days, workers should have a minimum of one day off in seven; workers may work on their rest day but no more than once in every two weeks. Factories should ensure that workers do not consistently work on their rest day by monitoring and limiting the practice of working on a rest day. Workers ability to work on a rest day should be limited to twice per month and only two months consecutively in one calendar year. For example, a worker may only be allowed in a one year period to have two consecutive months where 2 days of rest were taken. Generally, workers must have 4 days of rest in every month.

o Time records for all workers must be available for review. Employees must maintain their own time records, i.e. punch in and out themselves.

o Factories must record all employee working hours completely and accurately.

o Factories should have a working time clock that employees use to record their hours, both regular and overtime.

Hiring and Employment Practices

Suppliers must implement hiring practices that accurately verify workers’ legal right to work in the country and age prior to employment. All terms and conditions of employment including, but not limited to, hiring, pay, training, promotion, termination, and retirement must be based on an individual’s ability and willingness to do the job.

Suppliers as well as factory management must implement internal controls to validate the legal right of foreign workers to work in the country, that is, each worker has a valid work permit and are in the country lawfully. Additionally, suppliers and factory management must validate the age of their workers prior to employment. Work permits as well as copies of government issued identification documents must be maintained in the personnel files of all workers.

Employment practices of suppliers and factory management must be based on equal opportunity for all workers. Employment practices include, but are not limited to, recruiting, hiring, training, job assignments, pay, benefits, promotions, discipline, termination or retirement. Suppliers and factory management must not engage in any discrimination based on gender, age, religion, marital status, race, social background, diseases, disability, pregnancy, ethnic and national origin, nationality, membership in worker organizations or any other personal characteristic.

Specifically:

The process used by factories for hiring, compensation, promotion, termination and retirement practices and access to training should be based on a person’s ability to perform the job effectively, and not on a person’s individual characteristics. Practices that use religion, sex, ethnicity or nation origin, disability, political affiliation, social status, sexual orientation, actual or perceived HIV status or legal migrant worker status as a basis for the above is prohibited. Discrimination in any form is prohibited.

Factories must not require female applicants, contract workers or employees to be tested for pregnancy unless the factory is required by law to conduct such tests. Pregnancy testing should be voluntary not mandatory. Mandatory pregnancy testing (if not a legal requirement) is prohibited.

It is prohibited for factories to ask female applicants about their pregnancy status and must not discriminate in their hiring, salary, benefits, advancement, discipline, termination or retirement practices.

Restricting or limiting reproductive rights is prohibited.

Factories must meet any legal conditions on working environment for women and pregnant, post-partum and lactating women.

Women returning from maternity leave must be given an equivalent position and equal pay as required by local laws and regulations

Factories must make reasonable accommodations in job conditions for pregnant women (such as job reassignments to non-hazardous or lighter work, provision of seating, extended breaks, etc.).

Compensation

Suppliers must compensate all workers with wages, overtime premiums, and benefits that meet or exceed legal standards, local industry standards, or collective agreements, whichever are higher. Suppliers are encouraged to provide wages and benefits that are sufficient to meet workers’ basic needs and provide some discretionary income for workers and their families.

Suppliers and factory management must compensate all workers in accordance with local regulations and where applicable with contractual agreements. Workers must be provided with written and understandable details regarding their employment and compensation. Deductions from wages must not be made without the express permission of workers and must not be made as a disciplinary measure.

Specifically:

Factories must be in compliance with respect to all workers, including employees on piece rate.

Where the industry wage is greater than the minimum wage, the industry wage should be paid.

Factories must provide all benefits and bonuses in accordance with the law.

Workers should be aware of their benefits and understand how their wages are calculated. Workers should be provided with pay slips in a language the workers understand and that show regular and overtime hours worked, regular and overtime rates and wages, bonuses and deductions.

Factories must only deduct from wages what is legally permitted; factories must not deduct for tardiness exceeding the actual hour(s) lost and recruitment agency fees.

Freedom of Association and Collective Bargaining

Suppliers must respect the right of workers to choose whether to lawfully and peacefully form or join trade unions of their choosing and to bargain collectively.

Workers must be able to join or form trade unions consistent with laws and regulations. Suppliers and factory management must not prevent workers from exercising their rights and must not discriminate against worker representatives and union members due to their membership or affiliation with a trade union. In accordance with local regulations, suppliers and factory management must give worker representatives access to the workplace in order to carry out their representative functions.

Specifically:

o Factories must respect employee rights to freedom of association; they must not impose any punitive actions against workers in supporting a union such as threatening, fining, suspending or firing workers exercising those rights. Any action that suppresses freedom of association is prohibited, and may be an act deemed illegal in some countries’ labor codes.

o Where the right to freedom of association and collective bargaining is restricted under law, the supplier should not hinder the development of lawful parallel means for independent free association and bargaining.

o Managers and supervisors should be trained in freedom of association compliance when possible, and workers should receive instruction on their rights under national law and company standards.

Collective Bargaining

o Factories must honor the right of workers to bargain collectively.

o Employees should be able to raise issues regarding any collective bargaining agreement compliance by the employer/factory without retaliation.

o In situations where a Trade Union is not recognized as the bargaining agent of some or all of the workers in a factory, the Trade Union should have the means for defending the occupational interests of its members.

Health and Safety

Suppliers must provide workers with a safe and healthy work environment and where applicable, safe and healthy residential facilities. Suppliers must take proactive measures to prevent workplace hazards.

The work environment and, where applicable, residential facilities must be safe and clean to ensure the health and safety of all workers. Supplier and factory management must implement procedures and safeguards with the spirit of preventing accidents and injuries to workers; procedures and safeguards include, but are not limited to, inspection of buildings (residential and factories), machinery, and fire extinguishers. Workers must be provided with periodic health and safety training related to the handling and disposal of hazardous materials. Additionally, personal protective equipment and clothing must be provided to all workers handling hazardous materials.

Specifically

Fire Safety – Suppliers must ensure:

o Aisles and exits are kept clear and unblocked at all times

o Exits are unlocked at all times during working hours and are clearly marked

o Factories conduct regular fire drills per local laws, but not less than once yearly

o Factories have functional and sufficient fire fighting equipment

Electrical Safety – Suppliers must ensure:

o Factories maintain appropriate electrical wiring and circuit box conditions

PPE/Chemical Safety – Suppliers must ensure:

o Factories establish appropriate spill response programs

o MSDS sheet information is available for utilized chemicals in local language

o Factories provide appropriate PPE (Personal Protective Equipment) and training for workers

o Factory workers properly utilize PPE

o Factories appropriately store chemicals (proximity of incompatible chemicals, away from ignition sources, etc)

o Eye wash stations are appropriately located and maintained

Sanitation – Suppliers must ensure:

o Accessibility of drinking water for their workers

Restrooms, canteens, food preparation areas, dormitories, etc. are maintained in a safe and clean condition

o Factories possess appropriate hygiene certificates for their canteen and its workers per local laws

Accident/First Aid – Suppliers must ensure:

o Factories maintain detailed accident/incident logs

o Factories maintain an appropriate First Aid program with locally mandated and trained responders/clinics/hospitals per local requirements/laws

o Factories maintain sufficient First Aid boxes (1 per 100 employees) which are consistently monitored/refilled

Environment

Suppliers must ensure every manufacturing facility complies with national and local environmental laws, including all laws related to waste disposal, air emissions, discharges, toxic substances and hazardous waste disposal. Suppliers must validate that all input materials and components were obtained from permissible harvests consistent with international treaties and protocols in addition to local laws and regulations.

In addition to meeting specific laws and regulations such as acquiring the necessary permits and approvals relating to waste disposal, air emissions, wastewater discharge, water use, energy conservation, Greenhouse Gases, hazardous substances, environmental impact assessment, land use, and noise pollution, Walmart expects its suppliers to implement measures for reducing air and water pollutants, energy and water usage, and waste.

Specifically:

Waste Management – Suppliers must ensure factories:

o Obtain appropriate permits for on site waste disposal as required by local and national regulations

o Deliver hazardous waste for offsite treatment and disposal only to contractors licensed by appropriate competent authority (if any)

o Handle and store hazardous waste in a safe and environmentally sound manner to control any risks of environmental contamination

o Maintain waste containers and labels in an appropriate condition

Maintain waste inventory and tracking records

Wastewater & Effluents Management – Suppliers must ensure factories:

o Obtain appropriate permits for wastewater/effluents treatment and discharge as required by local and national regulations

o Conduct regular wastewater monitoring (sampling & testing) as required by local and national regulations

o Strictly comply with wastewater/effluents discharge limits as required by local and national regulations

o Take immediate corrective actions in the event discharge limits are exceeded

o Have a drainage system in place to convey wastewater to treatment plant and/or final discharge points. Drainage layout must be made available upon request. Drains must be regularly cleaned and maintained

o Maintain wastewater treatment plant in safe operating conditions to avoid any risks to environment and/or human health

Air Emissions Management – Suppliers must ensure factories:

o Obtain appropriate permits for air emissions as required by local and national regulations

o Conduct regular air emissions monitoring (sampling & testing) as required by local and national regulations

o Strictly comply with air emissions limits as required by local and national regulations

o Take immediate corrective actions in the event emission limits are exceeded

o Maintain on a regular basis air emission control equipment

o Establish an inventory of sources related to air emission points

o Expand the inventory of ODS (ozone depleting substances) containment equipment

Inspect and maintain ODS (ozone depleting substances) containment equipment to prevent the accidental release of substances

Water Management – Suppliers must ensure factories:

o Obtain appropriate permits for water use / extraction as required by local and national regulations

o Maintain data regarding water use consumption (e.g. water consumption data from water bills and meter readings)

Energy use and GHG (greenhouse gases) management – Suppliers must ensure factories:

o Meet applicable legal requirements in terms of energy use and GHGs emissions

o Set up energy use inventory (e.g. energy consumption data from energy bills and meter readings, fuel bills, gas bills)

o Maintain Greenhouse Gas Emissions (direct and indirect) inventory

Land Use and Biodiversity– Suppliers must ensure factories:

o Conduct Environmental Impact Assessment and submit the results to competent authority for review and approval as required by local and national regulations

o Obtain appropriate permits for land use and facilities construction as required by local and national regulations

o Meet applicable local and national regulations regarding protected land

Environmental Management System – Suppliers must ensure factories:

o Adopt environmental policy

o Have a mechanism in place to monitor environmental laws and regulations changes to achieve compliance

Appoint a member of management team for the coordination of environmental management activities and ensure he/she is properly trained

o Develop an emergency protocol to deal with environmental incidents. The emergency protocol should include emergency plan, trained emergency team and regular drills

o Provide regular environmental training to impacted employees

Hazardous Substances Management / Soil & Ground water Pollution Prevention – Suppliers must ensure factories:

o Do not utilize banned chemicals as required by local and national regulations

o Obtain appropriate permits for hazardous substances handling & storage as required by local and national regulations

o Take appropriate measures to prevent & control any risks of environmental pollution from hazardous substances release

o Verify the existence of sensitive receptors (e.g. rivers, underground water, etc.) close to production facilities and implement special measures to prevent contamination where needed

Noise Pollution – Suppliers must ensure factories:

o Obtain appropriate permit for noise pollution as required by local and national regulations

o Perform noise pollution assessments as required by local and national regulations

o Conduct regular noise pollution monitoring as required by local and national regulations

o Strictly comply with noise pollution limits as required by local and national regulations

o Take immediate corrective actions in the event the noise pollution limits are exceeded

Permissible harvests and origin of raw (input) materials:

Suppliers and factories should maintain inventory records and production records to demonstrate origin of incoming materials and place of production

o Factories must demonstrate through Chain of Custody documents (certifications) that raw materials (cotton, wood, etc.) were obtained from legal harvests consistent with international treaties and protocols in addition to local laws and regulations even if national regulations do not regulate harvests.

Gifts and Entertainment

Company’s policy of not permitting any gifts and entertainment stems from our goal to maintain Every Day Low Costs. Suppliers offering gifts, favors or entertainment to associates put our associates into difficult positions, where they must decline and report the incident.

Specifically:

Suppliers must ensure factories do not offer gifts or entertainment to company’s associates .Gifts include but are not limited to:

o Meals

o Travel expenses

o Money or the equivalent

o Free goods

o Tickets or access to events

o Personal favors

Conflicts of Interest

Suppliers must not enter into transactions with Companies that create a conflict of interest.

A conflict of interest may exist when personal interests interfere or appear to interfere with business interests.

Anti-Corruption

Suppliers must not tolerate, permit, or engage in bribery, corruption, or unethical practices whether in dealings with public officials or individuals in the private sector.

Suppliers and factories may not promise, offer, or pay anything of value to a government official or political party to obtain or retain business or secure an improper advantage on behalf of vendor.

Suppliers and factories may not promise, offer, or pay anything of value to any business or any individual in the private sector to obtain or retain business or secure an improper advantage on behalf of vendor.

Financial Integrity

Suppliers must keep accurate records of all matters related to their business with vendor. in accordance with standard accounting practices such as Generally Accepted Accounting Principles (GAAP) or International Financial Reporting Standards (IFRS).

Suppliers and factories must keep only one set of financial records, and should accurately record all legitimate financial transactions within those records using standard accounting practices. Financial records must be made available for both pre-arranged and unannounced audits by vendor or third party representatives.

Job Description of Compliance Professional:

Implementing law-2006, & various compliance related issues, COC of different reputed buyers and implementation of those in the factory.
Handle workers compensation, disability claims, evaluate employees.
Conduct vendor compliance audits in factories and follow up compliance issues.
Improve factories’ social compliance and quality performances by following up on Corrective Action Plans with frequent factory visits, training and support appropriate measures.
Good knowledge in social compliance programs (e.g. BSCI, SA8000) and quality a (e.g. ISO9000, ISO14000)
Do all paper work related to keeping office and factory ready to face audits
Help prepare reports and mails for correspondence with buyers and various compliance monitoring agencies as needed.
Interact with factory floor personnel to prepare them for compliance audits and make them aware on maintaining better compliance standards
Prepare regular compliance reports
Support HR and Welfare and other departments as the case may be, in successfully implementing compliance related initiatives
Looks after various Compliance Issues in the Factory.
Complying the Buyer’s COC and applicable Labor Law- 2006 in every area.
Looks after and ensure Health and Safety issue under the individual Buyer’s requirement.
Maintain good relation with workers and management.
Should be responsible to maintain all issues related to compliance and provide the summaries feedback.
Procure regulatory documents relating to labor ordinance, health & safety and others.
Train concerned/staffs on compliance standards and requirements.
To follow up the progress of internal factory audit.
Ensure facility’s Compliance requirements as per local-international legal standards,

To implement the buyers COC/ institution, factory acts and compliance in all the factories as per buyer desire.
To pre-evaluate the factories before buyers evaluation and make ready the factories as per buyer desire.
To conduct constant and regular visit to all the factories in search of new points of compliance and put suggestions to the factory management to remedy as soon as possible time.
To make good and peaceful relationship between the employees and employer.
To maintain the chemical compliance per buyer’s desire.
To maintain and monitor the compliance.
To keep the security system update under the security policy .
Maintain relation and discipline in the factory for all staffs and workers
Deal Recruitment Process Leave Management, Attendance monitoring, Salary Administration, Performance Appraisal. Handling Disciplinary & Grievance issues.
Look after employees Health, Safety & Welfare.
Look after social security of employees. Organizational Development. Maintain Buyers CoC.
Look after the Compliance & HR issues of the factory
Complying the EU/USA buyers requirement
Maintaining the standard in social and technical compliance issues
Updating the essential legal matter i,e Fire certificate, environmental certificate and all statutory permissions
Providing reports to the queries of buyer and meet their requirement in connection with compliance issue
Supervise the health and safety issues and ensure the readiness for Emergency
Conducting Training Program in different level
Efficient at all HR Issues (Increment, Disciplinary action, File management, Payroll, training & development etc)Looks after all Compliance Issues in the Factory.
Complying the deference Buyer’s COC and applicable Labour Law- 2006.
Maintain Register Separately for Leave Employee Insurance. Maternity Cases and Disciplinary procedure and prepare update leave statement, Yearly Increment, Salary Adjustment and individual Salary Statement.
Looks after and ensure that Health and Safety issue under the individual Buyer’s requirement.
Maintains the good relationship with workers and management.
Responsible to deal with labor Law and Law related occupational Safety.
Should be responsible to manage all issues related to compliance and provide the summaries feed back. Look after social security of employees.
Organizational Development.
Maintain requirement of SA 8000, ISO, WRAP, SEDEX, BSCI, FLO-Fare trade, GOTS etc.

Important Component of Social Compliance

Labor Welfare

Labour welfare activities in an industrialized society has far reaching impact not only on the work force but also all the facets of human resources. Labour welfare includes all such activities, which not only secures existential necessities but also ensures improvement in spiritual and emotional quotient. It comprises of short term and long terms goal toward building a humane society.

PRINCIPLES FOR SUCCESSFUL IMPLEMENTATION OF WELFARE ACTIVITIES
The success of welfare activities depends on the approach which has been taken into account in providing such activities to the employees. Welfare policy should be guided by idealistic morale and human value. Every effort should be made to give workers/ employees some voice in the choice of welfare activities so long as it does not amount to dictation from workers.

There are employers who consider all labour welfare activities as distasteful legal liability. There are workers who look upon welfare activities in terms of their inherent right. Both parties have to accept welfare as activities of mutual concern. Constructive and lasting Progress in the matter of social justice can be achieved only if welfare activities are accepted as essential factors in the progress of the business organization

Labour welfare is dependent on certain basic principles. The following are the principles on which successful implementation of welfare programmes depends :

Adequacy of Wages: Labour welfare measures cannot be a substitute for wages. Workers have a right to adequate wages. But high wage rates alone cannot create healthy atmosphere, nor bring about a sense of commitment on the part of workers. A combination of social welfare, emotional welfare and economic welfare together would achieve good results.
Social Liability of Industry: Industry, according to this principle, has an obligation or duty towards its employees to look after their welfare. The constitution of India also emphasizes this aspect of labour welfare.
Impact on Efficiency: This plays an important role in welfare services, and is based on the relationship between welfare and efficiency, though it is difficult to measure this relationship. Programmes for housing, education and training, the provision of balanced diet and family planning measures are some of the important programmes of labour welfare which increases the efficiency of the workers, especially in underdeveloped or developing countries.
Increase in Personality: The development of the human personality is given here as the goal of industrial welfare which, according to this principle, should counteract the baneful effects of the industrial system. Therefore, it is necessary to implement labour welfare services. Both inside and outside the factory, that is, provide intra-mural and extra-mural labour welfare services.
Totality of Welfare: This emphasizes that the concept of labour welfare must spread throughout the hierarchy of an organization. Employees at all levels must accept this total concept of labour welfare programme will never really get off the ground.
Co-ordination or Integration: This plays an important role in the success of welfare services. From this angle, a co-ordinated approach will promote a healthy development of the worker in his work, home and community. This is essential for the sake of harmony and continuity in labour welfare services.
Democratic Values: The co-operation of the worker is the basis of this principle. Consultation with, and the agreement of workers in, the formulation and implementation of labour welfare services are very necessary for their success. This principle is based on the assumption that the worker is “a mature and rational individual.” Industrial democracy is the driving force here. Workers also develop a sense of pride when they are made to feel that labour welfare programmes are created by them and for them.
Responsibility: This recognizes the fact that both employers and workers are responsible for labour welfare. Trade unions, too, are involved in these programmes in healthy manner, for basically labour welfare belongs to the domain of trade union activity. Further, when responsibility is shared by different groups, labour welfare work becomes simpler and easier.
Accountability: This may also be called the Principle of Evaluation. Here, one responsible person gives an assessment or evaluation of existing welfare services on a periodical basis to a higher authority. This is very necessary, for then one can judge and analyze the success of labour welfare programmes.
Timely: The timeliness of any service helps in its success. To identify the labour problem and to discover what kind of help is necessary to solve it and when to provide this help are all very necessary in planning labour welfare programmes. Timely action in the proper direction is essential in any kind of social wor

Last, but not the least is the fact that labour welfare must aim at helping workers to help themselves in the long run. This helps them to become more responsible and more efficient.

STATUTORY WELFARE SCHEMES

The statutory welfare schemes include the following provisions:

Drinking Water: At all the working places safe hygienic drinking water should be provided.
Facilities for sitting: In every organization, especially factories, suitable seating arrangements are to be provided.
First aid appliances: First aid appliances are to be provided and should be readily assessable so that in case of any minor accident initial medication can be provided to the needed employee.
Latrines and Urinals: A sufficient number of latrines and urinals are to be provided in the office and factory premises and are also to be maintained in a neat and clean condition.
Canteen facilities: Cafeteria or canteens are to be provided by the employer so as to provide hygienic and nutritious food to the employees.
Spittoons: In every work place, such as ware houses, store places, in the dock area and office premises spittoons are to be provided in convenient places and same are to be maintained in a hygienic condition.
Lighting: Proper and sufficient lights are to be provided for employees so that they can work safely during the night shifts.
Washing places: Adequate washing places such as bathrooms, wash basins with tap and tap on the stand pipe are provided in the port area in the vicinity of the work places.
Changing rooms: Adequate changing rooms are to be provided for workers to change their cloth in the factory area and office premises. Adequate lockers are also provided to the workers to keep their clothes and belongings.
Rest rooms: Adequate numbers of restrooms are provided to the workers with provisions of water supply, wash basins, toilets, bathrooms, etc.

NON STATUTORY SCHEMES

Many non statutory welfare schemes may include the following schemes:

Personal Health Care (Regular medical check-ups): Some of the companies provide the facility for extensive health check-up
Flexi-time: The main objective of the flextime policy is to provide opportunity to employees to work with flexible working schedules. Flexible work schedules are initiated by employees and approved by management to meet business commitments while supporting employee personal life needs
Employee Assistance Programs: Various assistant programs are arranged like external counseling service so that employees or members of their immediate family can get counseling on various matters.
Harassment Policy: To protect an employee from harassments of any kind, guidelines are provided for proper action and also for protecting the aggrieved employee.
Maternity & Adoption Leave – Employees can avail maternity or adoption leaves. Paternity leave policies have also been introduced by various companies.
Medi-claim Insurance Scheme: This insurance scheme provides adequate insurance coverage of employees for expenses related to hospitalization due to illness, disease or injury or pregnancy.
Employee Referral Scheme: In several companies employee referral scheme is implemented to encourage employees to refer friends and relatives for employment in the organization.

Machine guards: requirements and types

There are a number of general requirements for all machine guards if they are to protect workers against mechanical hazards. Guards must:

Prevent contact – The guard must prevent hands, arms, or any other part of a worker’s body from coming in contact with dangerous moving parts. A good guard eliminates the possibility of the operator placing their hands near dangerous moving parts.
Be secure – The guards should be firmly fixed to the machine (or preferably an integral part of the machine) and not easily removed. Remember that if a guard can be removed easily, it is no safeguard at all! Guards should be made of durable materials that can withstand workplace conditions over the lifetime of the machine.
Protect from falling objects – The guard should ensure that no objects (such as a tool) can fall into moving parts.
Create no new hazards – A guard defeats its own purpose if it creates another hazard such as its own shear point or a jagged or sharp edge, which can cause cuts.
Create no interference with work – Any guard which impedes a worker from performing his/her job efficiently and in comfort is likely to be removed or overridden. It should be pointed out that proper guards on machines can actually improve productivity, as workers then have confidence that they will not be injured.
Allow safe lubrication – If possible, the operator or maintenance worker should be able to lubricate the machine safely without removing the guard or having to reach inside the machine and into any hazardous area.

There are various types of guards that can be used to prevent injury in the workplace, including:

Fixed guards – These are the most common type of guard found in garment factories and basically prevent any contact between hands, arms, or other body parts and any moving machine parts. They should not easily be removed. In the best cases they provide the maximum amount of protection and require the minimum amount of maintenance. In some cases these guards can interfere with visibility.
Interlocking guards – When this type of guard is opened or removed, the tripping mechanism and/or power automatically shuts off or disengages. The machine cannot start until the guard is back in place.
Adjustable guards – These guards are useful because, as the name implies, they allow flexibility in accommodating various sizes (thickness, width, height, etc.) of stock. The best examples in a garment factory are the band knives in the cutting section where the guards are adjustable and can deal with varying thickness of material blocks.
Self-adjusting guards – The openings of these barriers are determined by the movement of the stock. As the operator moves the stock into the danger area, the guard is pushed away, providing an opening which is only large enough to admit the stock. After the stock is removed, the guard returns to the rest position. In some cases, these guards can interfere with visibility.

There are also a number of other techniques that can be used, including restraints, two-hand controls, safety trips, pullback mechanisms, and automatic feeds. Their name describes the mode of action but all work on a principle of disabling the machine as soon as a part of the body gets near a dangerous, moving component.

Guard-related problems in garment factories

The most common accidents in the garment industry tend to be:

Cut fingers, for machine operators in the cutting section
A needle in the finger, for sewers
Burns from irons, in the ironing section

(Note: A close analysis of the factory’s accident record book can help to identify priority areas that need to be addressed as a matter of urgency.)

As with all machinery, the machines in the garment industry are potentially dangerous. The most obvious are probably the band knives in the cutting section. In a walk-through survey of a garment factory, one of the most common observations is the number of machines that have missing or inadequate guards. As has been discussed, it is important to purchase so-called safe machines with fixed guards as an integral part – guards that cannot be removed, that allow for safe maintenance, and that provide clear visibility.

Accidents and unguarded machines

Tragically, accidents occur in all workplaces and the garment industry is no different. Accidents are costly to the employer in terms of loss of productivity; to the worker in terms of injury, loss of wages, etc.; and to society as a whole. The three factors that contribute to accidents are:

faulty technical equipment
the working environment
the worker

In the analysis of workplace accidents, it is clear that they are always the result of either unguarded machines, unsafe conditions in the workplace, and/or unsafe acts.

In companies with poor industrial relations, there tends to be a “culture of blame”. In apportioning blame:

Many employers tend to blame the worker for unsafe acts
Many workers tend to blame the employer for faulty equipment and unsafe environments

Personal Protective Equipment

Personal protective equipment (PPE) is special gear used to protect the wearer from specific hazards of a hazardous substance. It is a last resort protection system, to be used when substitution or engineering controls are not feasible. PPE does not reduce or eliminate the hazard, protects only the wearer, and does not protect anyone else.

Conclusion

Everything starting from planning, it seeing to be the most important step to start this industry report. In this industry report I have learned a lot of things, for instance communication, how to solve the problem, what are the recommendation, and what are the suggestion that given.

In this training establishment I have gained a lot of knowledge, the main thing that I can give is communication. Communication is the most important in hospitality studies. The communication between me, staffs and guests was the important part. In this case I have improved my language and communication skills as far as good. A part from that, the duties that given to me in eight hours, I know how to finish as fast as I can.

I would like to conclude that completion of the assignment has been both benefit and important to us. The industry report is really helpful for us towards the understanding of training establishment. We have learned a lot from the industry report and it is something that we will remember forever. We think we have learned to be better person now after do this industry report as it has helped us to improve knowledge in Performance appraisal. It is a great experience and we think that tasks are effective was to improve us members in any way and to be more productive.