Suppliers Gp Implementation Guide English

8/21/2019 Suppliers Gp Implementation Guide English

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C O P Y R I G H T 2 0 1 1 T H E C O C A - C O L A C O M P A N Y

Global Workplace Rights

Workplace Rights Implementation Guide


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Introduction

The Coca-Cola Company is committed to upholding fundamental principles of international human andworkplace rights everywhere we do business and believe that the true measure of a well-managed businessis not just whether it is financially successful, but how it achieves that success. We seek to develop

relationships with bottlers and suppliers that share similar values and conduct business in an ethicalmanner.

Our commitment to respecting human rights is formalized in our Human Rights Statement and theworkplace right principles are encompassed in our Workplace Rights Policy, which covers company-owned operations and our Supplier Guiding Principles, which covers our supplier partners andindependent bottlers. TCCC introduced the Supplier Guiding Principles (SGP) in 2002 for direct suppliersto TCCC, authorized suppliers of the TCCC system, direct suppliers to bottlers and independent bottlers.

Our Workplace Rights Policy (WRP) and Supplier Guiding Principles (SGP) communicate our values andexpectations of suppliers/independent bottlers and emphasize the importance of responsible workplacepractices that respect human rights and comply, at a minimum, with applicable environmental and local

labor laws and core international conventions. These laws and regulations include, among others, thosethat address working hours, compensation, working conditions and the rights of employees to choose

whether to be represented by third parties and to bargain collectively.

Our customers and stakeholders expect that we demonstrate our commitment to human and workplacerights by implementing our Supplier Guiding Principles and Workplace Rights Policy across our business.

Accordingly, we request that our partners undergo a specialized SGP assessment and, once alignment withSGP is confirmed, undergo periodic re-assessments. The assessments are conducted by accredited,independent third party firms that specialize in social compliance.

This Implementation Guide describes SGP, the assessment process, and the proactive steps a supplier cantake to align with SGP. In addition, the Guide explains a supplier srole and responsibilities with regard toSGP. Suppliers to The Coca-Cola Company should review this Guide thoroughly.

TCCCsgoal is to work with facilities to address any performance gaps in order to achieve and maintain asupply chain that is fully aligned with SGP.

We ask that you:

Familiarize yourself with our Supplier Guiding Principles;

Work to align your facility with SGP by taking the steps described in this Guide;

Communicate TCCC requirements to your employees; and

Post the SGP brochure somewhere it can be easily seen and read by employees (if you are acurrent supplier to TCCC). To print brochures (available in in multiple languages), visit our

website at:www.thecocacolacompany.com/citizenship/suppliers.html

We look forward to working with you to support appropriate understanding of SGP. If you have anyquestions or would like to discuss SGP requirements in more detail, please email Workplace

Accountability at [email protected].
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W O R K P L A C E R I G H T S I M P L E M E N T A T I O N G U I D E


V E R S I O N V 3 R E V I E W F E B 1 2 0 1 23

Table of Contents

POLICIES (HRS/WRP/SGP) 4

STAKEHOLDER EXPECTATIONS 8

BENEFITS OF WORKPLACE ASSESSMENTS 8

MUTUAL RECOGNITION 9

ASSESSMENT PROCESS 10

POST ASSESSMENT FOLLOW-UP 14

EMPLOYEE INTERVIEWS 14

GRIEVANCE MECHANISMS 17

LAWS AND REGULATIONS 18

CHILD LABOR 20

FORCED LABOR 22

ABUSE OF LABOR 24

FREEDOM OF ASSOCIATION 26

DISCRIMINATION 28

WAGES AND BENEFITS 30

WORK HOURS AND OVERTIME 32

HEALTH AND SAFETY 34

ENVIRONMENT 37

BUSINESS INTEGRITY 39

DEMONSTRATION OF COMPLIANCE 41

GOOD PRACTICES 44

GLOSSARY 54


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Policies (HRS/WRP/SGP)

Our commitment to respecting human rights, as formalized in ourHuman Rights Statement,is groundedin the Universal Declaration of Human Rights, related covenants and the International LaborOrganization's Declaration on Fundamental Principles and Rights to Work. The workplace rights

principles are encompassed in ourWorkplace Rights Policy,which covers company-owned operations andourSupplier Guiding Principles,which covers our supplier partners and independent bottlers.

Human Rights Statement

We are committed to earning that trust with a set of values that represent the highest standards of quality,integrity and excellence. A serious commitment to human rights is fundamental to the way we conductour business. Our Human Rights Statement establishes a foundation for managing our business aroundthe world in accordance with these high standards.

Our Human Rights statement is guided by theUnited Nations Declaration of Human Rights and relatedinternational covenants. While governments are responsible for protecting human rights through legalframeworks, businesses have a corporate responsibility to respect all human rights. Our Human RightsStatement recognizes this commitment. In addition to our Human Rights Statement, TCCC has endorsedthe Guiding Principles on Business and Human Rights, a framework adopted by the United Nations.

The Coca-Cola Companys Human Rights Statement can be downloaded online: http://www.thecoca-colacompany.com/citizenship/human_rights_statement.html

Workplace Rights Policy

The success of our business depends on every employee in our global enterprise. We are committed tofostering open and inclusive workplaces that are based on recognized workplace human rights, where allemployees are valued and inspired to be the best they can be. Our Workplace Rights Policy reflects these

values and our commitment to uphold workplace rights globally.

The Coca-Cola Company's Workplace Rights Policy applies to all of the entities that it owns, holds amajority interest, has management responsibility or where a bottler has adopted the policy. The WRP canbe downloaded in multiple languages online:http://www.thecoca-colacompany.com/citizenship/workplace_rights_policy.html

Supplier Guiding Principles

Values and Commitments at The Coca-Cola CompanyThe reputation of The Coca-Cola Company is built on trust and respect. Our employees and those who dobusiness with us around the world know we are committed to earning their trust with a set of values thatrepresent the highest standards of quality, integrity, excellence, compliance with the law, and respect forhuman rights and the unique customs and cultures in communities where we operate.

Our Company has always endeavored to conduct business responsibly and ethically. We respectinternational human rights principles, including the United Nations Declaration of Human Rights and theInternational Labor Organizations Declaration on Fundamental Principles and Rights at Work. Weactively participate in the United Nations Global Compact. These corporate values are formalized in theCompanys Human Rights Statement and Workplace Rights Policy.Our acknowledgment of these international principles is consistent with our dedication to enriching the

workplace, respecting all human rights, preserving the environment and strengthening the communitieswhere we operate.
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The Supplier Guiding Principles Reflecting theCompanys Values

The Supplier Guiding Principles (SGP) are a vital pillar ofThe Coca-Cola Companys human rights and workplaceaccountability programs. These programs are driven by the

belief that good corporate citizenship is essential to ourlong term business success and must be reflected in ourrelationships and actions in our workplaces and the

workplaces of those who are authorized to directly supplyour business.Recognizing that there are differences in laws, customs, andeconomic conditions that affect business practices aroundthe world, we believe that shared values must serve as thefoundation for relationships between The Coca-ColaCompany and its suppliers, starting with the commitmentto respect all human rights. The Supplier Guiding Principlescommunicate our values and expectations and emphasizethe importance of responsible workplace policies andpractices that comply, at a minimum, with applicableenvironmental laws and with local labor laws andregulations. The principles outlined below reflect the values

we uphold in our own policies, and we expect our directsuppliers to follow the spirit and intent of these guidingprinciples to ensure respect for all human rights.

Freedom of Association and Collective BargainingRespect employees right to join, form, or not to join a laborunion without fear of reprisal, intimidation or harassment.

Where employees are represented by a legally recognizedunion, establish a constructive dialogue with their freely

chosen representatives and bargain in good faith with suchrepresentatives.

Prohibit Child LaborAdhere to minimum age provisions of applicable laws andregulations.

Prohibit Forced Labor and Abuse of LaborProhibit physical abuse of employees and prohibit the use of all forms of forced labor, including prisonlabor, indentured labor, bonded labor, military labor, slave labor or any form of human trafficking.

Eliminate DiscriminationMaintain workplaces that are free from discrimination or physical or verbal harassment. The basis forrecruitment, hiring, placement, training, compensation, and advancement should be qualifications,performance, skills and experience.

Work Hours and WagesCompensate employees relative to the industry and local labor market. Operate in full compliance withapplicable wage, work hours, overtime and benefits laws, and offer employees opportunities to developtheir skills and capabilities, and provide advancement opportunities where possible.


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Provide a Safe and Healthy WorkplaceProvide a secure, safe and healthy workplace. Maintain a productive workplace by minimizing the risk ofaccidents, injury, and exposure to health risks.

Protect the EnvironmentConduct business in ways which protect and preserve the environment. Meet applicable environmental

laws, rules, and regulations.

Business IntegrityConduct business with integrity, respecting relevant laws and avoiding bribes and fraudulent practices.

Grievance Procedure and RemedyProvide workers with a mechanism to express grievances without fear of reprisal and ensure concerns areappropriately addressed in a timely manner.

Management SystemsHave appropriate and effective systems in place to control actions ensuring lawful compliance and respectfor all human rights.

Compliance with Applicable Laws and Standards

We expect our suppliers to share our commitment to respect all human rights. Suppliers to The Coca-ColaCompany and suppliers authorized by The Coca-Cola Company are required to meet the followingstandards, at a minimum, with respect to their operations as a whole:

Laws and RegulationsSupplier will comply with all applicable local and national laws, rules, regulations and requirements in themanufacturing and distribution of our products and supplies and in the provision of services.

Child LaborSupplier will comply with all applicable local and national child labor laws.

Forced LaborSupplier will not use forced, bonded, prison, military or compulsory labor or any form of humantrafficking.

Abuse of LaborSupplier will comply with all applicable local and national laws on abuse of employees and will notphysically abuse employees.

Freedom of Association and Collective BargainingSupplier will comply with all applicable local and national laws on freedom of association and collectivebargaining.

DiscriminationSupplier will comply with all applicable local and national discrimination laws.

Wages and BenefitsSupplier will comply with all applicable local and national wages and benefits laws.

Work Hours & OvertimeSupplier will comply with all applicable local and national work hours and overtime laws.


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Health & SafetySupplier will comply with all applicable local and national health and safety laws.

EnvironmentSupplier will comply with all applicable local and national environmental laws.

Business IntegritySupplier will comply with all applicable local and national laws and will not use bribes or fraudulentpractices

Demonstration of ComplianceSupplier must be able to demonstrate compliance with the Supplier Guiding Principles at the request andsatisfaction of The Coca-Cola Company

If the eight Core Conventions of the International Labor Organization establish higher standards thanlocal law, the ILO standards need to be met by the supplier. These minimum requirements are a part of allagreements between The Coca-Cola Company and its direct and authorized suppliers. We expect oursuppliers to develop and implement appropriate internal business processes to ensure compliance with theSupplier Guiding Principles.

The Company routinely utilizes independent third-parties to assess suppliers compliance with the SGP.The assessments generally include confidential interviews with employees and on-site contract workers. Ifa supplier fails to uphold any aspect of the SGP requirements, the supplier is expected to implementcorrective actions. The Company reserves the right to terminate an agreement with any supplier thatcannot demonstrate that they are upholding the SGP requirements.


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Stakeholder ExpectationsThe Supplier Guiding Principles help The Coca-Cola Company align its supply chain with company values

while also demonstrating the Companys commitment to achieving a supply chain that meets stakeholderexpectations. Multiple stakeholders expect the entire Coca-Cola system to have workplace standards thatmeet or exceed the requirements of local law. These stakeholders include, but are not limited to:

Direct customers Consumers through customers Shareholders Non-governmental organizations Student activists Governments

TCCC is held accountable for anything occurring under the trademark, whether it occurs at anindependent bottler, a company-owned facility, a supplier of materials used in our products or productpackaging, a supplier of promotional merchandise, or any other type of supplier. This accountability isanother important reason that suppliers within the Coca-Cola system must operate in accordance with the

Supplier Guiding Principles.

Responsible workplace practices throughout the system are critical to protecting the value of ourtrademark and key to achieving our aspiration of being one of the most respected companies in the world.

Benefits of Workplace Assessments

Assessments can provide valuable insight into your operations and can help you:

Determine whether your facility operates in accordance with local laws and, if not, identify the

necessary corrective actions to avoid the risks associated with breaking the law. Identify and eliminate work hazards that could result in worker injuries, costly worker

compensation claims, and a damaged reputation. Improve operational efficiency and employee productivity by understanding how to create a better

work environment and implement recommended changes. See Hours of Work Guidance documentfor case studies on how reducing overtime improves operational efficiency.

Meet the reporting requirements of other customers in lieu of additional assessments in order tosave money and avoid additional work disruptions.

Align performance with The Coca-Cola Companys vision values for the supply chain, therebyincreasing the chance of becoming a preferred source.

Promote your responsible workplace practices as a competitive advantage when advertising,soliciting new business, or looking to attract prospective employees.

Receive professional guidance on remediation of any findings and on the effective implementationof best practices used by top-performing suppliers in your industry.

Finally, suppliers that undergo assessments and address findings can take pride that they are doing theright thing by striving to operating a safe and lawful facility that also is a good place to work.


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Mutual RecognitionWe recognize that many suppliers are asked by multiple customers to conduct social compliance audits todemonstrate compliance. By paying for the SGP assessment the supplier owns the results and is free toshare them with other companies. This can help reduce audit duplication and the costs associated withmultiple audits. Through a framework we call Mutual Recognition, TCCC agrees to review audit reportsto determine if internal criteria are met. Recognition of an audit report does not signify that anassessment is passed. Depending on audit results additional follow-up or a new assessment may berequired to demonstrate that issues are resolved.

Assessments should meet the following criteria to be considered under Mutual Recognition:1. Acceptable Auditor: Use of external auditors is preferred to provide an assurance of objectivity.

a. The auditor must be named and auditing affiliation disclosed to allow validationb. Preferred Audit firms have independent accreditations. TCCC frequently uses UL-STR, Intertek

and SGS but others may be acceptable as well.2. Acceptable Audit Coverage: Any submitted audit should be a social compliance assessment (not food

safety or quality) which verifies compliance to local law with regard to Labor and Wage, Health andSafety, Environment and Business Integrity.

3.

Audit Integrity: An acceptable audit report is complete and not redacted (except confidentialproduction information)

4. Acceptable Timeframe: Assessments within the last 12 months may be submitted for review5. Acceptable Process: The methodology used by an auditor to determine noncompliance is based on

visual inspection, documentation review and confidential employee interviews.

If the above criteria are met, the assessment will need to be converted into the TCCC ASR format todetermine rating. This can be accomplished in the following ways:

Preferred Method: The supplier may ask an approved service provider to put the results in theTCCC format for an agreed fee. The report is then submitted as a MR audit to Workplace

Accountability and the appropriate Business Unit and is treated with the same follow-up as anyother assessment.

If the above method is not feasible, the supplier may submit the original report to WorkplaceAccountability for conversion into ASR format.

Once an audit report is accepted under Mutual Recognition, it is tracked, reported and followed-up uponin the same manner as any other SGP assessment to ensure ongoing compliance is maintained. If thereport is more than 6 months old, the facility may have 1 month to demonstrate issues have been closed orto complete a follow-up assessment.


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V E R S I O N V 3 R E V I E W F E B 1 2 0 1 21 0

Assessment ProcessThe following is a general outline of SGP assessment process and procedures.

Preparation Instructions:

Read the Pre-Assessment Information Packet and sign/return relevant forms. In advance ofyour assessment, a third party service provider will send you an information packet that providesspecific information about scheduling and preparing for an assessment. This information packet

will contain an application form that must be filled out and returned to the service provider alongwith pre-payment and a signed report release form that allows the assessment results to be provided

to The Coca-Cola Company. The third party service provider will then work with you to schedulethe assessment.

Choose a Normal Operating Day. The facility must be operating on the assessment day in order foran assessment to occur, and is preferable that the facility is producing the type of product it suppliesto the Company. Mills, farms, and other suppliers working on a seasonal schedule should providethe service provider with dates when seasonal workers will be present and the facility is fullyoperating.

Re-read the Pre-Assessment Information Packet to prepare: It is extremely important that youread this document thoroughly and understand all of its contents to ensure all necessarypreparations are made. The Packet will provide you with a list of documentation to have available,sample communication for your employees and a checklist to help you prepare. Preparing properly

will make the assessment smoother and more efficient for everyone involved.

Ensure Someone from Senior Management is Available. This person needs to have fullknowledge of the facility operation, and the authority to comply with the assessment serviceproviders requests and respond accurately on behalf of the facility owners and management.

Ensure Production Manager and Personnel Manager Available.These individuals are necessaryto answer a series of questions regarding production capacity, machines, lead times, hiring practices,

and payroll records.

Ensure Union Representatives Available(if applicable), These representatives should be availablethroughout the assessment.

AssessmentScheduling

Assessment

Preparation

Assessment

Process

Assessment

Follow-up

Assessment

Scheduling

AssessmentPreparation

Assessment

Process

Assessment

Follow-up


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Notify Security in Advance. Assessors arrive at the facility and provide their business cards andidentification badges upon entry. Please be sure to notify your entry security guards in advance oftheir visit.

Assessments will take 1-4 person days. The assessment team will consist of fluent native speakers (often withmore than one dialect ability) and readers of the manufacturing countrys language. Assessors will hold an

opening meeting with the facilitys designated management person of authority, production and personnelmanagers, and any other managers you wish to have present. During this meeting, the assessors willdescribe the assessment format. No other unrelated parties shall be present during this assessment, exceptas approved in advance by Workplace Accountability.

Note that non-employee workers are included in the assessment, so you should notify any agencies thatprovide such workers as to the requirements provided in the supplier packet you receive prior to theassessment. It is expected that appropriate paperwork in on-site for Non-Employee Workers. Non-Employee Workers are defined as employees of a 3rd party company who provide ongoing labor services tothe facility (e.g. Seasonal workers, Production Workers, Security, Janitorial, Canteen) working full-time. IfNon-Employee Workers are employed at the facility, the service provider will request a 10% sample size, upto 25, from the total pool of non-employee workers, reflecting NEWs from each agency.

Assessment Components:Actual assessments may or may not follow this order. However, all steps as indicated below are completedduring the assessment in most cases. If further steps or documents are needed to support a completeunderstanding of the facility situation, the assessment service provider may request additional information

from the facility. Your full cooperation is appreciated to support a smooth and beneficial assessment.

Opening Meeting

Introduction of assessors and service provider SGP Overview Review of assessment procedures to be performed as well as inspection time frame

for each portion Coordination of management and facility personnel required for the assessment

Facility Tour

Review of floor plan of the entire facility to ensure every room is toured (i.e.,

kitchen and dormitories) Review of list of any potentially hazardous chemicals used/ stored at the facility Tour of the facility floor to evaluate health and safety conditions, production

capacity, use of outside subcontractors, waste water treatment, chemical andhazardous material containment, etc.

Tour of the dormitories and dining room facilities, if provided, to evaluate healthand safety conditions

Employee Interviews

Assessment

Scheduling

Assessment

Preparation

AssessmentProcess

Assessment

Follow-up


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Selection and interview of employees and Non-Employee Workers (10% of totalworkforce up to 25 workers plus 10% of in-scope NEWs up to 25)

Record Review

Review of facility policies or handbooks and licenses Review of employment contracts as required by the countrys labor laws

Review of age documentation / verification, labor contracts, medical certificates,

government registration. Review of payroll documentation, including but not limited to one year of the

most recent payroll records, time cards, production records, attendance records.(These documents are necessary in order to determine if the facility is in fullcompliance with the countrys national and regional labor laws on minimum

wage, overtime wage, overtime and holiday hours, etc.)- For facilities with 250 or fewer employees, records should reflect 10% of total

workforce / For facilities with more than 250 employees, records should beavailable for 25 employees maximum for the current month plus 5 from thepeak production period, 5 from a non-peak production period, and 5 fromthe balance of the year

- Non-Employee Worker payroll will also be reviewed Review of proof of insurance payment or tax payment, etc. Review of environmental permits, waste records, health/safety training records Review of official union agreement contract, where applicable Review of subcontractor info (name, address, contact information) Review of workers compensation insurance, I-9s and W-4s (USA only) Review of policies and procedures that demonstrate Good Practices (see section

below)

Closing Meeting

Review of Assessment Summary Report with facility management; the reportdetails findings and any corrective actions necessary to align with SGP

Discussion of assessment results with designated facility management personnel,

answering of any questions, and clarification of local labor and environmentallaws as necessary

Review of recommended corrective actions (if required) to make all requiredfuture improvements with the goal of 100% compliance within a timetable to bedetermined with The Coca-Cola Company

Verification that the facility manager understands the findings and has had theopportunity to make any comments if so desired. The facility manager andassessor then sign the Assessment Summary Report. A copy of the signed reportis left with the facility.

Appeals Process:

After an audit is complete findings should only be altered as a result of error detection in the qualityassurance process, an agreement between the service provider and facility or the below appeals process.Escalation Process for Appeals: If the dispute is in regards to legal interpretation the findings, as an initial step, should be reviewed

with the service providers external legal team to verify whether the auditor correctly interpreted locallaw (or SGP/WRP language) based on the evidence obtained during the assessment (within 5 businessdays).


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a. If determined to be valid and the supplier accepts the result, the supplier should resolve theissue by an agreed-upon deadline and undergo a follow-up assessment or desk review(depending on the type of finding).

If the service providers legal team determines the findings to be valid and the supplier does not

accept the result, or if the dispute is not of a legal nature, the facility representative has the right

to dispute findings by emailing the Workplace Accountability Director, copying the Coca-Colacontact who ordered the assessment. The email includes a full written explanation of the disputed

issue, including any evidence they used to support the decision to cite the finding, and the

law/regulation or SGP/WRP requirement on which the finding was based. Explanation needs to

be in English and therefore the facility may need to work with regional manager or service

provider.

a) If needed, TCCC legal review may be undertaken at the request of the WorkplaceAccountability Director

b) Workplace Accountability will engage audit firm and facility in determining appropriateactions.

c) Workplace Accountability sends a letter to the facility representative explaining the

determination. Upon receipt of this letter, the account manager sends the final ASR andfull report to the facility, copying all relevant recipients, with an assessment results letterand follow-up instructions.


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Post Assessment Follow-UpSuppliers and The Coca-Cola Company receive a detailed assessment report within 7-10 days. The supplieralso receives a results letter with instructions and any necessary forms to demonstrate completion ofcorrective action. The Assessment Summary Report (ASR) provides you with a score that is linked to acolor rating. A facilitys color rating determinesfollow-up requirements:

Assessment

Scheduling

Assessment

Preparation

AssessmentProcess

Assessment

Follow-up

No action required. Facility will be assessed in 1-3 years.

Fill out Facility Action Plan form and send to the service provider. Service Provider will notify you if the plan meets SGP requirements;

if not, they will provide any necessary guidance. Correct minor findings to achieve Green status. (Note: You will

receive a new summary report with a zero score and Green ratingafter completing a desk review).

Return letter to the service provider within the time frame specifiedin your assessment summary report along with any requiredevidence that corrective action has occurred.

Service provider completes desk review. Facility will be re-assessed in 1-3 years.


if not, they will provide any necessary guidance. Correct findings as outlined on the approved Facility Action Plan. Schedule a follow-up assessment to occur within 6 months of the

initial assessment. In certain instances a Desk Review Assessmentis acceptable in lieu of an in-person visit.

Process continues until the facility becomes Green.


if not, they will provide any necessary guidance. Correct findings as outlined on the approved Facility Action Plan. Schedule a follow-up assessment to occur within 6 months of the

initial assessment. Process continues until the facility becomes Green or is

deauthorized.


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Employee InterviewsAll third-party service providers thatconduct assessments of suppliers to The Coca-Cola Companyrequire their assessors to undergo extensive training with regard to employee interviews.

Assessors conduct employee interviews primarily to corroborate documentary evidence obtainedduring the assessment. They only will objective, non-leading questions.

Employee Selection Process Employees from various workstations will be selected during the walkthrough of the facility and

from a random sampling of personnel records. Employee participation in interviews is strictly voluntary and at the employees discretion. All interview notes are destroyed away from facility location. All interviews must be conducted in a private area with no management presence. If there is no Health and Safety risk for workers and the auditor, Interviews may be conducted at

workstations on the production floor if management is not visible to employees and if no one isable to hear the discussion

Categories of Questions Which May be Asked:

Child LaborQuestions will be asked to validate age and determine if children ever are present on site.

Forced LaborQuestions will be asked to determine how employees found their positions and whether overtime is

voluntary or communicated at hire if mandatory.

Abuse of LaborQuestions will be asked to determine if employees understand the disciplinary rules and regulations andto ensure there is no abuse.

Freedom of Association/ Collective BargainingObjective, non-leading questions will be asked to determine whether the plant working environmentis sufficiently open to allow discussion of issues generally, including the ability of employees to joinany legal organization in which they may have an interest both inside and outside work.

Working HoursQuestions will be asked to determine if working hours (meal times, breaks, etc) meet both state andfederal legal requirements.

Wages & BenefitsQuestions will be asked to determine if wages meet both state and federal legal requirements.

Health & Safety

Questions will be asked to determine if employees are aware of all state and federal legal requirements toensure a safe and healthy workplace.

Work EnvironmentQuestions will be asked to determine if a grievance mechanism is in place and if and how workersatisfaction is tracked.

DiscriminationObjective, non-leading questions will be asked to determine if there are any issues around discrimination.


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Business IntegrityQuestions will be asked to ensure there are no fraudulent business practices, in particular related topayroll and to determine awareness of a Code of Business Conduct.

Demonstration of Compliance

Questions will be asked to validate that the facility is able to effectively demonstrate alignment with SGP.

If there are issues of concern (SGP and/or legal violations) addressed through the interview process,e.g., employees report alleged discriminatory behavior by management or other employees, and theyare able produce information supporting the claim, management will be notified of issues withoutnaming employee(s) who reported them.

If there are issues that arise from the interviews that either cannot be validated or are not actualviolations, the assessors may also review with management without naming the employee(s) whoreported them during the process if the information will be valuable to management.


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Grievance MechanismsGrievance mechanisms help identify potential non-compliances or adverse human rights impacts andenable facilities to address and remediate issues early to prevent further escalation. Grievancemechanisms are an important part of TCCCs human rights due diligence. Auditors are asked toidentify the existence of grievance mechanisms and determine if the mechanism is beingimplemented.

Effective grievance mechanisms, as outlined in the Guiding Principles on Business and Human Rights,should be:

(a) Legitimate: enabling trust from the stakeholder groups for whose use they are intended, and beingaccountable for the fair conduct of grievance processes;

(b) Accessible: being known to all stakeholder groups for whose use they are intended, and providingadequate assistance for those who may face particular barriers to access;

(c) Predictable: providing a clear and known procedure with an indicative timeframe for each stage, andclarity on the types of process and outcome available and means of monitoring implementation;

(d) Equitable: seeking to ensure that aggrieved parties have reasonable access to sources of information,advice and expertise necessary to engage in a grievance process on fair, informed and respectful terms;

(e) Transparent: keeping parties to a grievance informed about its progress, and providing sufficientinformation about the mechanisms performance to build confidence in its effectiveness and meet anypublic interest at stake;

(f) Rights-compatible: ensuring that outcomes and remedies accord with internationally recognizedhuman rights;

(g) A source of continuous learning: drawing on relevant measures to identify lessons for improving themechanism and preventing future grievances and harms;

(h) Based on engagement and dialogue: consulting the stakeholder groups (e.g. workers) for whose use

they are intended on their design and performance, and focusing on dialogue as the means to addressand resolve grievances.

For employees of The Coca-Cola Company in addition to local, facility specific grievance procedures,employees outside the European Union can also report potential Human Rights Statement or

Workplace Rights Policy violations through the EthicsLine secured Internet website atwww.koethics.com or by calling the appropriate toll-free number for their location, which can befound on the www.koethics.com website. Local toll-free EthicsLine number(s) are available on theposters located in each facility outside of the European Union.
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Laws and RegulationsRequirement

Supplier will comply with all applicable local and national laws, rules, regulations and requirements in themanufacturing and distribution of our products and supplies and in the provision of services.

Key Requirements Copies of legal age documents are available for all employees, including photo ID. Hiring ages on employee contracts or applications represent legal age for employment. Documents are available for randomly selected employees on the work floor. Hours worked as shown on timecards or revealed by other means do not exceed legal restrictions. All deductions shown on pay journal are authorized by law, with the employees written consent. Hours worked and overtime are calculated and compensated correctly. Employees are aware of terms of either written or oral employment contracts. All mandated benefits are paid in a timely manner.

Indicators of Performance Gaps Facility does not operate with a legal business license, or license is expired. Labor contracts are missing for some or all of the employees. Facility does not comply with legal requirements regarding worker documentation. Insurance certificates are missing or expired. Wages and benefits policies are not communicated to employees. Workers bring work home

Laws and Regulations: Examples of Findings and Corrective Actions

Finding Corrective Action Recommended

Time Table

Confirmation

MethodLabor Contracts:Employees

who have been working at apackaging plant tell the auditorthey have not yet received laborcontracts as required by law.

Provide labor contracts toemployees.

60 days

Youth Workers:Youth workers have been hiredlegally, but are working morethan the number of hours thatlocal law allows.

Ensure a system is in place tomonitor the number of hours

worked by legal youth workersand keep the number of hours

worked within legal limits.

60 days

Probation Terms:A labor contract set forth aprobationary period of sixmonths while local law statesthat the probationary periodcannot exceed 90 days.

Modify new and existingcontracts with language thatsets the probationary periodat 90 days or less andcommunicate the change toemployees that may beaffected.

60 days

Laws and Regulations: Examples of Findings and Corrective Actions


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Finding Corrective Action RecommendedTime Table

Confirmation Method

Insurance:A facilitys insurancedocumentation expired twomonths ago. Facility

management states thatthey have applied for arenewal and receivedapproval from an insurancecompany, but have notreceived new insurancecertificates.

Ask the insurance companyto fax a copy of thecertificates to keep on fileuntil the actual certificates

arrive.

60 days


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Child LaborThe U.N. Global Compact The SGP Principle The Requirement

Effectively abolish childlabor.

Prohibit child labor andadhere to minimum ageprovisions of applicable lawsand regulations

Supplier will comply with all applicablelocal and national child labor laws or ILOcore convention (whichever is higher).

Key Requirements Procedures in place to verify age; Copies of legal proof of age documents available for all

employees, including photo ID. Hiring ages on employee contracts or applications represent legal age for employment. Documents are available for randomly selected employees on the work floor.

Indicators of Performance Gaps

Child labor is observed on the day of the assessment.

Child labor has been reported and corroborated by at least two sources. Workers currently of legal age were hired while under age.

Child Labor: Examples of Findings and Corrective Actions


ConfirmationMethod

Minimum Working Age:Anemployee is found to be belowthe minimum legal working ageof 15.

The factory mustimmediately remove theemployee from the

workfloor and work withthe childs guardian(s) to

ensure the child attendsschool in accordance withlocal law. Ensure a systemis in place to verify newand existing workers are atleast the minimum legal

working age.

Remove thechildimmediately andimplement anage verification

system within 60days.

Child Visitors:An employeebrings his 10 year old child to

work because the school is closedand there is no one to take careof her at home. During the day,the child occasionally helps hermother place bottles in front of abottle capping machine.

The child must beremoved from the

workfloor immediately.Alternative arrangementsfor the childscare shouldbe made by the employeeand the facility. Thefacility should establishand communicate a policythat prohibits the presenceof children in work areas.

Remove thechildimmediately andcommunicatethe policy within30 days.


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Child Labor: Examples of Findings and Corrective ActionsFinding Corrective Action Recommended

Time TableConfirmation

Method

Historical Child Labor:Anemployee who is 18 year old hasbeen working at a facility for the

last four years. Although she iscurrently 18, she was hired at theage of 14, which was below theminimum legal working age.

The factory must verifythat all current employeesare meet local minimum

working age requirementsand obtain validdocumentation for newhires to prevent the hiringof workers below the legalminimum working age.

Immediately

Minimum Working Age:Thefactory does not have a policy onminimum working age that isconsistent with legal minimumage requirements.

The facility shouldestablish andcommunicate a minimumage policy that complies

with local minimum age

laws and disallowschildren from workfloors.A system to verifycompliance with the policyshould be established.

60 days


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Forced LaborThe U.N. GlobalCompact

The SGP Principle The Requirement

Eliminate of all forms offorced or compulsorylabor.

Prohibit physical abuse of employees andprohibit the use of all forms of forcedlabor, including prison labor, indenturedlabor, bonded labor, military labor, slavelabor and any form of human trafficking

Supplier will not use forced,bonded, prison, or compulsorylabor or engage in humantrafficking

Key Requirements No forced, bonded, prison, military or compulsory labor. Ensure that there are no programs that may cause a forced labor situation, such as excessive

recruitment fees or loan repayment programs No human trafficking


Use of prison labor.

Evidence of slave or forced labor. Facility retains original worker documentation without worker permission. Employees are penalized for refusing overtime hours and were not informed at the time of hire that

overtime is mandatory. Employee mobility is restricted due to wage deposits, loan repayments, repayment of recruitment

fees

Forced Labor: Examples of Findings and Corrective Actions


ConfirmationMethod

Free Movement:When an

employee is hired, the HumanResources Manager takespossession of the employeespassport, birth certificate, or otherpersonal papers, which inhibits theemployees ability to leave orterminate employment.

Make copies of all

documentation and return theoriginals to the employee.

Immediately

Forced Labor: Employees aredenied permission to leave workbecause they are ill or need to carefor familymembers who are ill.

Allow employees to leave thefacility if the requests are

within reason. Create a policythat allows employees to leave

when a reasonable request ismade. Train employees andsupervisors to adhere to thepolicy.

Allow theemployee toleaveimmediately /develop a policy

within 30 days

Free Movement: Employees areonly allowed to use the toilet or toobtain drinking water once a day.

Workers always should beallowed access to the lavatoryand drinking water withoutneeding to ask permission.

Immediately


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Forced Labor: Examples of Findings and Corrective ActionsFinding Corrective Action Recommended


Method

Forced Labor: It takes 10 hours,with breaks, to produce 3,000handbags. An employee is told

that he cannot take a break until3,000 handbags are produced.

Allow the worker to takebreaks in accordance with legalrequirements.

Immediately

Prison Labor:A packagingsupplier uses workers from thelocal prison to make pallets usedto move product.

Discontinue the use of prisonlabor.

Immediately

Bonded Labor: A worker isindebted due to recruitment feesthat cannot be effectively paid off

Fees must be legal andcommensurate with salary.Good practice is that employerpays all recruitment fees.

Immediately


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Abuse of LaborThe SGP Principle The Requirement

Prohibit the use of all forms of forced labor,

including prison labor, indentured labor, bondedlabor, military labor or slave labor.

Supplier will comply with all applicable local and

national laws on abuse of employees and will notphysically abuse employees.

Key Requirements: No evidence of physical abuse of workers (reported or observed). No threats of physical abuse. No physical contact or comment that could be interpreted as sexual.

Indicators of Performance Gaps: Observed or reported physical abuse. Observed or reported verbal threats of physical abuse.

Abuse of Labor: Examples of Findings and Corrective Actions


ConfirmationMethod

Physical Abuse:Managers usephysical punishment as adisciplinary practice.

Immediately stop thepractice. Implement a policythat prohibits the use ofphysical punishment, set upa system to enforcecompliance with the policy,and conduct training ifnecessary.

Stop practiceimmediately.Communicate thepolicy to allmanagers and

workers / addpolicy language

within 60 days.

Sexual Harassment:A femaleemployee is made to feel she mustaccept unwanted sexual advancesfrom a manager in order to keepher job or to receive a better workassignment.

Immediately investigate anyclaim of sexual harassment,place the worker and theperson suspected ofharassment in separate workareas, and disciplineemployees responsible forthe harassment when there issufficient evidence. If anemployee does not respondto warnings and the evidenceindicates continued

harassment, the employeeshould be terminated.Ensure the facility has a

written policy prohibitingsexual harassment andcommunicate the policy tosupervisors and employees.

Immediatelycommunicate thepolicy to allmanagers and

workers / addpolicy language

within 60 days.


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Abuse of Labor: Examples of Findings and Corrective Actions


ConfirmationMethod

Verbal Threats / AbusiveLanguage:A floor manager at aproduction facility threatens

employees using profane, abusive,and demeaning language tomotivate them to work harder.

Immediately investigateclaims of verbal abuse anddiscipline any employee

found to be engaging inverbal abuse. Ensurelanguage prohibiting verbalabuse is included in thefacilitys policies and that thepolicy is communicated toemployees. Providesensitivity training asnecessary to supervisors.

Immediatelycommunicate thepolicy to all

managers andworkers / addpolicy language

within 60 days.

Discipline: An employee is firedbecause he failed to inform her

supervisor in advance that shewould not be at work. He has nevermissed work before.

Instruct employees andsupervisors on the proper

disciplinary practices andensure they are appliedconsistently. Verbal or

written warnings should begiven before a worker issuspended or terminated.

Immediatelydiscontinue the

practice and trainworkers andsupervisors

within 60 days.

Grievances: Employees feel theycannot complain about theirsupervisors abusive behaviorbecause they do not have anyone

with whom to register a complaint.

The facility should have asystem for employees tocommunicate theircomplaints confidentially tohigher-level managers orhuman resources staff.

Workers and supervisorsshould be made aware of thepolicy, which should beincorporated into writtenpolicies.

60 days


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Freedom of Association

The U.N. GlobalCompact

The SGP Principle The Requirement

Businesses should upholdthe freedom ofassociation and theeffective recognition ofthe right to collectivebargaining.

Respect employees right to join, form or not tojoin a labor union without fear of reprisal,intimidation, or harassment. Where employeesare represented by a legally recognized union,establish a constructive dialogue with theirfreely chosen representatives and bargain ingood faith with such representatives.

Supplier will comply withall applicable local andnational laws on freedomof association andcollective bargaining.

Key Requirements Employees are free to collectively bargain.

Facility complies with the terms of the collective bargaining contract.

Collective bargaining contract is available for review. Internal regulations are available for review. Minutes from meetings of the worker committee are available for review. Any grievances or complaints against management are available for review. Performance records of terminated workers are available for comparison with the performance of

others in the same line or producing at the same rate.

Indicators of Performance Gaps Records on cases of workers having been disciplined or terminated for supporting union activities

such as handing out union cards, wearing a union button or showing up at a union meeting. Evidence of management interfering with a workers ability to organize or participate legally in a

union. Management does not recognize or refuses to bargain with legally elected employee

representatives. Management does not comply with the terms of a collective bargaining agreement. Workers are refused hire because of their affiliations.

Freedom of Association & Collective Bargaining:Examples of Findings and Corrective Actions


ConfirmationMethod

Collective BargainingAgreements:Facilitymanagement refuses to adhere to

the terms of an approvedcollective bargaining agreement.

The facility should respect theterms of the agreement andengage in dialogue with union

representatives to resolve anyconflicts.

Immediately

Union Affiliation:A facilitypenalizes employees who supportthe creation of a union or engagein union activities.

Immediately discontinue thepractice. Adopt a neutralapproach to unions, respectemployees rights to freelyassociate, and engage in adialogue with workers.

Immediately


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Freedom of Association & Collective Bargaining:Examples of Findings and Corrective Actions


ConfirmationMethod

Union Affiliation:Management

promises better benefits, bonusesor a promotion if an employeedoes not vote to unionize.

Discontinue the practice.

Workers should not be treateddifferently based on theirdecision to engage or notengage in union activities.

Immediately

Collective BargainingAgreements:Management meetsand bargains with one union andthen imposes the terms of theresulting agreement on a secondunion without their consent or anynegotiation.

Discontinue the practice.Engage in a dialogue with allunion entities to develop anagreement that is acceptable toall parties.

Immediately


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DiscriminationThe U.N. Global Compact The SGP Principle The Requirement

Eliminate discrimination in

respect of employment andoccupation.

Maintain workplaces that are free from

discrimination or physical or verbalharassment. The basis for recruitment,hiring, placement, training,compensation, and advancement shouldbe qualifications, performance skills andexperience.

Supplier will comply with all

applicable local and nationaldiscrimination laws.

Key Requirements Facility does not discriminate on the basis of gender, race, religion, national origin, or other legally

protected class. Hiring practices, pay, and opportunities for advancement are based on occupational skills and

experience and not personal or physical qualities.

Indicators of Performance Gaps Employees are treated differently based on physical or personal qualities, religious beliefs or other

attributes not directly related to occupational skills and experience. Employees are required to undergo mandatory pregnancy or HIV testing prior to being hired as a

condition of employment. Men and women are not paid equally for equal work.

Discrimination: Examples of Findings and Corrective Actions


ConfirmationMethod

Gender Discrimination:

Women (pregnant or not),members of a particular religionor religious sect, individuals of aparticular racial or ethnicminority or any other protectedcategory are not being hired orare barred from applying becauseof these specific characteristics.

Remove all discriminatory

requirements from hiringcriteria. Establish a hiring policythat prohibits discriminationand communicate the policy tomanagement and humanresources personnel responsiblefor making hiring decisions.

Immediately

HIV Testing: Prospectiveemployees are required to take anHIV test prior to being hired.

Remove all discriminatoryrequirements from hiringcriteria. This is considered anImmediate Notification issue

and may jeopardize supplierauthorization status.

Immediately

Pregnancy Testing: Prospectivefemale employees are required totake a pregnancy test prior tobeing hired.

Remove all discriminatoryrequirements from hiringcriteria. This is considered anImmediate Notification issueand may jeopardize supplierauthorization status.

Immediately


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Discrimination: Examples of Findings and Corrective Actions


ConfirmationMethod

Discrimination: Severalemployees from a particularindigenous or ethnic group or of

a particular race state that theyare refused any assignmentsnecessary to become qualified fora promotion.

Set forth a policy that prohibitsdifferential treatment of workersbased on their physical

characteristics, gender, race,religion, social status, or anyother legally protected class.Immediately communicate thepolicy to workers andsupervisors.

Ensure a grievance system is inplace for workers to alertmanagement of potential

violations of the policy andinvestigate all complaints in atimely manner.

Immediatelycommunicatepolicy /

implementgrievance systemandinvestigationmechanism

within 60 days.

Gender Discrimination:Amanager passes over a femaleemployee (who would be thenormal choice) to make a salespresentation or distribute goodsto a potential client, using insteada male employee because themanager thinks or knows that theclient prefers to deal with men.

Discontinue the practiceimmediately.

Set forth a policy that prohibitsdifferential treatment of workersbased on their physicalcharacteristics, gender, race,religion, social status, or anyother legally protected class.Immediately communicate thepolicy to workers and

supervisors.

Immediately


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Wages and BenefitsThe SGP Principle The Requirement

Compensate employees relative to the industry

and local labor market. Operate in full compliancewith applicable wage, work hours, overtime andbenefits laws and offer employees opportunities todevelop their skills and capabilities, and provideadvancement opportunities where possible.


national wages and benefits laws.

Key Requirements Hours worked and overtime are calculated, compensated correctly, and paid in a timely manner. All mandated benefits should be paid / provided in a timely manner. All deductions shown on pay journal are authorized by law, with the employees written consent.


Employees are paid less than the required minimum wage. Wages or benefits are delayed or withheld. Workers are not compensated properly for overtime work. Mandated benefits are not provided. Workers attend meetings prior to normal work hours but are not compensated for the time.

Wages and Benefits: Examples of Findings and Corrective Actions


ConfirmationMethod

Minimum Wage:Newemployees receive less than themonthly minimum wage during

the first month following theirhire date.

Pay the monthly minimumwage from the time of hireand pay employees

retroactively who did notreceive the minimum wageduring the first month of

work.

Immediately adjustpay to meetminimum wage

requirements.

Issue back paywithin 30 days.

Overtime Payment:Legalrequirements specify thatpayment for work on legalholidays be paid at twice theregular hourly rate but thefacility is paying 1.5 times theregular wage.

Pay the holiday overtimerate in accordance with locallaw. Pay any employeesretroactively who receivedthe incorrect rate for workperformed on holidays.

Immediately adjustpay to meetminimum wagerequirements.

Issue back paywithin 30 days


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Wages and Benefits: Examples of Findings and Corrective Actions


ConfirmationMethod

Benefits:Workers are notprovided legally mandatedhealth insurance benefits

after their first 90 days.

Provide all legallyrequired benefits andensure the employees

are aware of the benefitsto which they areentitled. Ensure alllegally required postingsregarding benefits areposted in the mannerrequired by law.

Allowemployees toapply for

benefitsimmediately.

Communicatebenefits andpost all requiredpostings within60 days.

Social InsuranceDeductions:A facilitydeducts an amount from

employeespaychecks forsocial insurance but doesnot immediately transferthe money to theappropriate financialinstitution or thegovernment.

Transfer all deductedfunds promptly to thefinancial or government

institution responsiblefor the administration ofsocial insurance.

60 days totransfer delayedfunds. All funds

going forwardshould be keptcurrent.

Wage Discrimination:Employees are paiddifferently based on theirprotected group status,such as religion or gender.

(Note that this also violatesthe Discriminationcomponent of the SupplierGuiding Principles).

Discontinue practiceimmediately andcompensate employees

who received less pay forequal work so that the

total amount receivedequals then totalamount received by thehigher-paid worker.Ensure a policy is inplace prohibitingunequal pay for equal

work and ensure it iscommunicated tosupervisors and payrollpersonnel.

Immediatelydiscontinuepractice andcompensateemployees

within 30 days.


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Work Hours and OvertimeThe SGP Principle The Requirement

Compensate employees relative to the industry

and local labor market. Operate in full compliancewith applicable wage, work hours, overtime andbenefits laws and offer employees opportunities todevelop their skills and capabilities, and provideadvancement opportunities where possible.


national work hours and overtime laws.

Key Requirements Hours worked as shown on timecards or revealed by other means do not exceed legal restrictions. Hours worked and overtime are calculated and compensated correctly. Employees are aware of work hours terms of either written or oral employment contracts.


Workers work seven days or more without one day of rest. Workers work in excess of country overtime regulations. Break time is insufficient.

Work Hours and Overtime: Examples of Findings and Corrective Actions


ConfirmationMethod

Rest and Meal Breaks:Workers cannot take rest ormeal breaks as required bylocal law without staying lateto make up the time.

Allow workers to takerest and meal breaks asrequired by local law

without requiring make-up time.

Immediately

Rest Days:Workers aregenerally asked to work everyday of the week without a dayoff in violation of local law orthe provisions of a collectivebargaining agreement.

Discontinue the practiceand provide workers

with one day off perweek. Develop a workschedule that minimizesovertime and does notdrive workers to sacrificetheir rest days.

Immediately

Off-Clock Meetings:Workers are required attend

meetings before or after workwithout being compensatedfor the time.

Eliminate therequirement to attend

meetings off the clock orcompensate employeesat their regular hourlyrate for time spent at themeetings.

Immediately


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Work Hours and Overtime: Examples of Findings and Corrective Actions


ConfirmationMethod

Recordkeeping: The facilitydoes not use an establishedsystem for recording hours

worked.

Begin using anestablished system forrecording hours worked

that employees use torecord their own hoursfor regular and overtime

work.

60 days

Excessive Overtime:Workers are required to workhours in excess of legal limits

Ensure that workers donot exceed legal limitson hours worked per

week. Review publishedHours of Work Guidancefor ideas on how toreduce systemic

overtime

60 days


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Health and SafetyThe SGP Principle The Requirement

Provide a secure, safe and healthy workplace. Maintain a

productive workplace by minimizing the risk of accidents,injury and exposure to health risks.

Supplier will comply with all applicable local

and national health and safety laws.

Key Requirements Work area is well-lit, ventilated, free from debris, and aisles are clear. There is functioning fire control equipment. Facility maintains adequate on-site equipment and trained personnel to provide for basic first aid. Unlocked and accessible exit doors with multiple exits in each area.. Machine pulleys have guards, tagging needles are disposed of properly. There are a sufficient number of clean, functioning restrooms, running water and trash cans. Chemicals are used, stored, labeled, and disposed of in compliance with local regulations and do

not present an environmental risk or worker exposure risk.

Food preparation areas are maintained in a sanitary condition and refrigerators/freezers are usedfor perishable ad temperature-sensitive foods.

Employees are trained to respond to potential emergencies in accordance with local regulations.Facility is prepared for an emergency (cleared aisles, unlocked exit doors, first aid kits, fire drills,fire extinguishers, etc)

Potable drinking water, compliant with local requirements, is available to all workers.

Indicators of Performance Gaps Fire exits are blocked, locked or not marked properly. Employees work without appropriate protective equipment such as goggles, masks, helmets,

shields, gloves, boots, respirators or earplugs, although required or appropriate. Employees are not trained about how to maintain a safe and healthy workplace, including how to

wear and use safety gear and equipment when required or appropriate. First aid or emergency evacuation procedures or instructions are not visible or available. Spills of water, oil or other materials, including hazardous materials, are not promptly contained

and cleaned up, or other appropriate actions are not taken to prevent slipping, fires, or explosions. Emergency equipment such as fire extinguishers, eyewash stations, safety showers, is not provided

or not maintained. Gangways or aisles are obstructed by debris or otherwise blocked. Chemicals and other hazardous materials are not properly labeled, stored, secured, handled, and

disposed. Employees do not have access to the Companys up-to-date Occupational Safety & Health

Management System and Standards in easily accessible locations. Employees are not following lock-out/tag-out or engage in hot work or other dangerous work

procedures.

Trolleys, buggies, equipment and pallets are not returned to proper locations after use.


35/57




Health and Safety: Examples of Findings and Corrective Actions


ConfirmationMethod

First Aid Kits:A facilitymakes first aid kits available,but the kits are locked in the

main office and can only beopened by a custodial

worker who is currently onvacation.

Ensure the legallyrequired number of firstaid kits are accessible

without any restrictedaccess, contain therequired supplies, andthat the supplies have notexpired.

Immediately

Emergency Exits:A facilityhas experienced a series ofthefts from a warehouse

where 200 workers operate aproduction line. The floormanager locks most

emergency exits to deterintruders. One exit is leftunlocked. Signs are placedon the locked doorsdirecting workers to theunlocked door in case ofemergency. Local lawrequires one emergency exitfor every 50 workers.

Unlock at least three moreemergency exits andensure all work locationsare within reasonabledistance of an unlockedemergency exit in

accordance with local law.

Hire security personnel tomonitor the facility at alltimes to prevent futurethefts.

Immediatelyunlockemergencyexits. Addsecuritypersonnel as

needed.

Machine Safety Guards:Machines do not have thelegally required guards to

prevent injury to workers.

Install legally requiredguards on all machineslacking them.

60 days

Fire Alarms / EvacuationDrills: Some of the workrooms in a facility lack firealarms. The last evacuationdrill was one year ago whilethe law requires a drill everysix months.

Ensure all work spaceshave fire alarms and that asystem is in place forchecking alarmsperiodically to ensure theyare functioning properly.

Conduct evacuation drillsas frequently as requiredby local law.

Immediately

Personal ProtectiveEquipment:Workers are ona production floors wherefumes from paintapplication circulate due tothe operation of theproduction line. These

workers are not wearing any

Provide personalprotective equipment toall employees inaccordance with local lawand require employees to

wear it. Determinewhether ventilationsystem can be improved to

Immediatelyprovide PPE.Conduct

ventilationcheck within 60days


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protective masks to avoidinhalation of the fumes.

eliminate exposure tofumes.

Health and Safety: Examples of Findings and Corrective ActionsFinding Corrective Action Recommended


Method

Fire extinguishers:Employees have not receivedtraining on the use of fireextinguishers and someextinguishers do not havemaintenance labelsindicating when they werelast inspected. In addition,some extinguishers areblocked by crates. Some

work areas lackextinguishers altogether.

Ensure all fireextinguishers havemaintenance tags andhave been inspectedrecently. Confirm that anadequate number ofextinguishers are available,properly mounted andunblocked. Providetraining to employees fromeach work area.

Immediatelyunblock anyblockedextinguishersand purchaseextinguishersfor work areasthat do not havethem. Train

within 60 days.

Emergency Exits:Doorsopen inwards, potentiallypreventing employees fromleaving quickly during anevacuation.

Install doors that open inan outward direction onall emergency exits.

60 days

First Aid Training:No onehas been trained toadminister first aid in case ofemployee injury or illness.

Provide first aid trainingand establish writtenmedical procedures fortreating victims of injuryor illness. Verify thattraining and procedurescomply with local law.

Begin formaltraining within60 days.

Signs:There are no exitsigns over some of theemergency exits, noWarning signs inhazardous areas, and someunlabeled chemicals.

Label all hazardousequipment with Warningsigns, label all chemicals

with the appropriateMaterial Data SafetySheets, install exit signsover all exits, and providemaps showing evacuationroutes in all work areas.

60 days

Electrical Boxes: Electricalboxes do not have covers,

wiring is exposed, and someswitches lack labels..

Place covers over allelectrical boxes, make sure

no wiring is exposed, andlabel all switches.

60 days

Dormitory Safety:Employee living quarters isin the same building orattached to the samebuilding used for productionor warehousing.

Provide living quartersthat are physicallyseparated from productionareas and warehouses.Confirm that dormitoriescomply with local law with

90 days


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regard to emergency exits,signage, fire safety, toilets,climate, and cleanliness.

EnvironmentThe U.N. Global Compact The SGP Principle The Requirement

Support a precautionaryapproach to environmentalchallenges; undertake initiativesto promote greaterenvironmental responsibilityand encourage the developmentand diffusion of environmentallyfriendly technologies

Conduct business in wayswhich protect and preservethe environment. Meetapplicable environmentallaws, rules and regulations.

Supplier will comply with allapplicable local and nationalenvironmental laws.

Key Requirements Updated permissions and environmental licenses are available. Air emission permits and monitoring records are available. Wastewater discharge permits and monitoring reports are available. Records are available to confirm that generated wastes are disposed of in accordance with local

regulations and managed while on site to prevent environmental contamination or worker risk.

Indicators of Performance Gaps Factory waste is discharged to the environment without proper treatment . Hazardous waste is disposed of with regular waste. Chemicals are used that are outlawed globally or in the country of operation. Waste management is not properly documented.

Environment: Examples of Findings and Corrective Actions


ConfirmationMethod

Waste Disposal:Hazardous waste is mixedin with regular waste inreceptacles on theproduction floors.

Provide separatecontainers for hazardousand non-hazardous wasteat all waste disposal areasand clearly mark eachcontainers purpose.

60 days

Waste Disposal:A pipedrains liquid waste tainted

with solvents into a nearby

ditch on facility property.

Obtain an appropriatereceptacle to contain the

waste for subsequent

disposal in accordancewith local environmentalregulations. Takenecessary measures toclean waste that hasdrained to theenvironment and consult

with local environmentalauthorities to take

Immediately


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appropriate action.

Chemical Use:Facility useschemicals that are bannedlocally or nationally.

Immediately discontinuethe use of bannedchemicals.

Immediately

Environment: Examples of Findings and Corrective Actions


ConfirmationMethod

Flammable MaterialsStorage:Metal containersfull of flammable fuel arelocated alongside aproduction building on drygrass and in full sunlight.

Immediately relocate fuelcontainers to a paved areaaway from any fire risk.Store out of direct sunlightin space with adequateheat ventilation, preferablyin an unoccupied free-standing storage shed.

Immediately

Permits:A facility does nothave permits for disposal of

waste generated fromwastewater treatmentoperations. The facility hasnot asked the contractorresponsible for transportingthe waste to produce apermit.

Confirm that the facilityhas all necessary permitsfor storage and treatmentof waste. Obtain proof thatthe contractor has thenecessary transportpermits .

60 days

Permits: No permits are

available for equipment onsite (boilers, generators,etc.)

Check whether permits are

required for all equipmentused onsite and obtain thenecessary permits.

60 days

Waste Disposal: A facilitydoes not have anyinformation on the locationof the disposal site for itshazardous and non-hazardous waste. There isno process in place for

tracking wastemanagement.

Determine where non-hazardous and hazardous

waste are disposed andconfirm that the disposalfacility meets all legalrequirements. Develop aprocess for tracking and

documenting the deliveryof waste and trainappropriate employees onthe process.

60 days


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Business Integrity

The Coca-Cola Company expects all employees as well as suppliers to comply with the law and actethically in business matters. To support this TCCC has a Code of Business Conduct for Suppliers which

reviewsourcompanypolicyaboutconflictsofInterest,

Meals & Gifts, Business and Financial Records, Bribery and Protecting Information(http://www.thecocacolacompany.com/citizenship/pdf/COBC_Suppliers.pdf). Business Integrity extendsbeyond corruption, extortion and bribery to include fraudulent business practices. Below are acceptedexplanations of such practices:

Corruption: the abuse of entrusted power for private gain

Extortion: The solicitation of bribes is the act of asking or enticing another to commit bribery. Itbecomes extortion when this demand is accompanied by threats that endanger the personal integrity

or the life of the private actors involved

Bribery: An offer or receipt of any gift, loan, fee, reward or other advantage to or from any person as

an inducement to do something which is dishonest, illegal or a breach of trust, in the conduct of the

enterprise's business

Fraud: intentional deception often made for personal gain or to damage another individual

During the audit questions will be asked to validate facilitys knowledge and compliance with the code ofbusiness conduct and to ensure that no fraudulent practices, such as double books.

Key Requirements Awareness of relevant Business Integrity laws and regulations Awareness of TCCC Code of Business Conduct for Suppliers Accurate record keeping to reflect actual time worked and wages paid No facilitation payments paid or offered

Indicators of Performance Gaps No mechanism available for workers to file grievances related to business integrity. Inconsistent/incomplete documentation indicating potential falsification of records Evidence of facilitation payments to government officials

Business Integrity: Examples of Findings and Corrective ActionsFinding Corrective Action Recommended

Time Table

Confirmation

MethodBribery: Evidence ofbribery to serviceprovider orgovernment official

Cease any bribes; developpolicies and procedures toensure no ongoing facilitationpayments. Instances of suchnoncompliances will bereviewed on a case-by-casebasis

Immediately

The U.N. Global Compact SGP Principle The Requirement

Work against corruption in all itsforms, including extortion andbribery

Supplier conductsbusiness with integrity -

without bribes orfra

Suppliers Gp Implementation Guide English

Documents

Transcript of Suppliers Gp Implementation Guide English