Verite Corrective Action Report Rosita Knitwears

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Verité 44 Belchertown Road, Amherst, MA USA 01002 Tel: +413.253.9227 Fax: +413.256.8960 Email: [email protected] CORRECTIVE ACTION REPORT ROSITA KNITWEARS (PVT.), LTD. ISHWARDI EXPORT PROCESSING ZONE, PAKSEY, PABNA, BANGLADESH Facility Visit Dates: March 21-23, 2012 This Corrective Action Report (CAR) embodies the results of the workplace assessment. It is the intent of the Corrective Action Report (CAR) to help improve your factory and facilitate corrective action planning.

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Verite Corrective Action Report Rosita Knitwears

Transcript of Verite Corrective Action Report Rosita Knitwears

Page 1: Verite Corrective Action Report Rosita Knitwears

Verité 44 Belchertown Road, Amherst, MA USA 01002

Tel: +413.253.9227 Fax: +413.256.8960 Email: [email protected]

CORRECTIVE ACTION REPORT

ROSITA KNITWEARS (PVT.), LTD. ISHWARDI EXPORT PROCESSING ZONE, PAKSEY, PABNA, BANGLADESH

Facility Visit Dates: March 21-23, 2012

This Corrective Action Report (CAR) embodies the results of the workplace assessment. It is the intent of the Corrective Action Report (CAR) to help improve your factory and facilitate corrective action planning.

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Summary of Areas of Concern

Below is a summary of the compliance areas in which areas of concern were identified during the onsite phase of the assessment. Note that full details of findings, including recommendations, are found beginning on page 3, organized by category, sub-category, and benchmark.

I. EMPLOYMENT POLICIES

Compliance Category Area of Concern

No Issues Identified

Compliance Category Area of Concern

No Issues Identified

Worker Awareness x Contract Labor (Foreign

or Domestic)

Factory Records x Grievance Procedures x

Forced Labor Discipline and Termination x

Child and Juvenile Labor

Discrimination x

Harassment and Abuse x Pregnancy Issues Freedom of Association

x Freedom of Movement

II. COMPENSATION AND HOURS

Regular Wages x Regular Hours and

Overtime x

Overtime Wages Mandatory Overtime Benefits and Deductions x Production Quotas x

Pay Practices x

III. HEALTH AND SAFETY

Emergency Evacuation / Fire Safety

x Medical Care, Accidents,

and Injuries

Sanitation / Maintenance Working Conditions

Machine Safeguarding x Explosion Hazards

Chemical Safety x Personal Protection

Equipment x

Dormitories

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Findings Details and Action Planning

Below are the details, legal references (as applicable), and recommendations for corrective action for each area of concern detected during the

onsite Verité social compliance assessment. Only relevant standards are included, and assessment categories with no areas of concern are not presented. As a guide for determining the significance of standards (and findings in those areas), each standard is assigned a priority level

according to the significance of a given issue. Issues are categorized as “Zero Tolerance” (the highest priority issue), “Immediate Action,” and followed last by “Continuous Improvement.” These priority levels are based on CSR norms and Verité’s experience in social accountability

benchmarking, as well as brand Codes of Conduct and are offered as guidelines only.

Priority Shading: Zero Tolerance=Red Immediate Action=Orange Continuous Improvement: Yellow

Employment Policies

Verité Good Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

SUBCONTRACTING

All subcontractors must be audited.

Management reported that the facility subcontracts with the MEGATEX Knitwears (Pvt.), Ltd. factory located in the Ishwardi Export Processing Zone.

Audit all subcontractors.

WORKER AWARENESS

Relevant national and local labor laws should be prominently posted, written in a language workers understand, verbally communicated to illiterate workers, if applicable, and should cover, where applicable:

Minimum age of employment/ restrictions on juvenile employment;

Minimum wage;

Regular and overtime work hours;

Overtime pay rates;

Benefits (holidays, leaves);

Freedom of Association/ Collective Bargaining

Harassment and Abuse

The auditors reported that there are no labor laws posted in the factory. The auditors reported that the factory’s personnel policies were not posted at the time of the audit. The auditors reported that worker awareness of national and local labor laws and factory personnel policies was uniformly low. The auditors further noted that communication in the factory is not generally conducted in the languages spoken by the workforce. Although the posting of labor laws and personnel policies are not specifically required by law, the auditors recommend that this information be posted as a good practice and as another means to improve communication with employees. The auditors noted that the factory does provide

a. Prominently post relevant national and local labor laws and regulations (or a summary of these) that cover minimum age, minimum wage, benefits (including holidays and leave), work hours, overtime rates, freedom of association, and harassment and abuse. All posted laws must be written in the languages spoken by the workforce. b. Prominently post the

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Employment Policies

Verité Good Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

workers with a copy of the employee handbook, but workers do not carry the handbook with them at all times, and provision of the handbook is only one method to inform workers of employment-related policies and legal matters (interviews revealed that there are considerable communication gaps at the factory, with worker awareness quite low on matters related to their employment). The auditors also note that often, brand Codes of Conduct will specify the posting of this information.

factory’s personnel policies (or a summary of these), written in the languages of the workforce, in a place where workers will feel comfortable reading them. c. Conduct trainings, in the languages spoken by the workforce, to familiarize workers with national and local labor laws and factory personnel policies.

Employment / Personnel Policies and Procedures should be written in a language all workers understand, posted prominently, distributed to all workers, and verbally communicated to illiterate workers, if applicable. Policies and Procedures should include:

Pay practices;

Benefits and deductions;

Leave and vacations;

Regular and overtime hours;

Regular and overtime rates;

Discipline and termination

Grievance procedures

Harassment and abuse policies

Sick leave and personal leave. Discipline and termination policies should include an escalating series of verbal and written warnings prior to suspension or dismissal; grievance procedures should systematically address workers’ grievances, permit workers to lodge grievances against their supervisors without having to report the grievance to that supervisor, allow workers to address their grievances without penalty or reprisals of any kind, and provide for management follow-up; harassment and abuse policies should define harassment and abuse and include a list of penalties for violations.

Most workers must be aware of the contents of the factory’s personnel policies and procedures.

FACTORY RECORDS

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Employment Policies

Verité Good Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

An individual personnel file should be maintained for each worker that includes, at a minimum, a copy of age-verification document(s), emergency contact information, the worker’s employment agreement, and if applicable, disciplinary notices and accident reports.

The auditors reported that not all applicable personnel files included disciplinary notices and accident and injury reports.

Take measures to ensure that all personnel files include copies of disciplinary notices and accident and injury reports, as applicable.

Files of dismissed and resigned workers should be kept on-site for three years.

The auditors reported that files for dismissed/resigned employees are not generally kept by the facility, and that those that are kept do not include information about the reason for dismissal.

Keep records of all dismissed/resigned employees on file, on site for at least three years. Dismissal records must include the reason for dismissal.

Personnel files of dismissed employees should include an accurate and detailed reason for dismissal.

HARASSMENT AND ABUSE

All forms of harassment and abuse are unacceptable. Verbal Abuse: Chronic shouting and/ or use of insulting or offensive language. Verbal and Psychological Harassment: Chronic use of implied or direct threats. Humiliating or intimidating verbal or non-verbal behavior, including the throwing of objects. Sexual Harassment: (1) Unwelcome sexual advances; requests for sexual favors, and all other verbal or physical conduct of a sexual nature when submission to such conduct is made either explicitly or implicitly a term or a condition of an individual’s employment, when an employment decision is based on an individual’s submission to or rejection of such conduct, or when such conduct has the purpose or effect of unreasonably interfering with an

Workers interviewed reported that it is a common practice for factory supervisors and floor staff members to punish tardy and/or absent workers by forcing them to stand out of their production line for many hours without rest. Most of the workers interviewed reported that they are subjected to verbal abuse and similar humiliating punishment for committing minor offenses such as being late or being absent. Workers interviewed further reported that Bangladeshi managers use abusive language toward workers who are judged to be discontented. Workers approached BEPZA authorities approximately two weeks before the audit regarding harassment and abuse at the factory. Reportedly, an office order was subsequently issued that banned all types of unreasonable punishment and allowed workers to arrive a maximum of 15 minutes late without penalty. Workers interviewed also reported that they are psychologically harassed by management in the form of

Take measures to end all forms of physical and verbal/psychological harassment and abuse, and communicate to all supervisors and managers that harassment and abuse will not be tolerated.

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Employment Policies

Verité Good Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

individual’s work performance by creating an intimidating, hostile, or sexually offensive environment. (2) Offensive sexual comments, jokes, innuendoes, and other sexually oriented statements. Physical Abuse: Includes any physical contact with the intent to injure or intimated (including the throwing of objects) and disciplinary measures that cause physical discomfort.

excessive penalties and punishment including deducting the number of pieces recorded on production documents so that workers effectively receive pay reductions; firing workers for being absent even if there is a significant family emergency; requiring workers to sign resignation letters for offenses such as absenteeism; firing trainees without compensation and confiscating their ID cards; security guards forcibly removing workers from the factory premises; and beating workers involved in freedom of association or protest activities. The auditors noted that at the time of the audit, the situation surrounding worker protest actions in the Ishwardi EPZ was quite volatile. In late March and concurrent with the onsite visit, local police were involved in an escalating situation. Both the auditors and workers interviewed reported that problems in the factory are exacerbated by the fact that Bangladeshi supervisors, line leaders, and mid-level managers do not speak or understand Mandarin/Chinese which is the language spoken by upper management. Workers, therefore, do not have a ready means for filing a grievance regarding harassment and/or abusive behavior.

GRIEVANCE PROCEDURES

Most workers must be reasonably aware of the factory’s grievance procedures.

Workers interviewed reported that they are often subjected to physical, verbal, and psychological harassment and abuse, but do not have an effective means for filing a grievance for several reasons. For instance, both the auditors and workers interviewed reported that problems in the factory are exacerbated by the fact that Bangladeshi supervisors, line leaders, and mid-level managers do not speak or understand Mandarin/Chinese which is the language spoken by upper management. Management does not possess the verbal expertise to understand the basics of workers’ grievances, much less the nuances involved in a particular dispute. In addition, because workers are physically, verbally, and psychologically abused by managers in positions of power, they are afraid to bring grievances forward for fear of retaliation. The factory’s history of summarily and/or excessively fining and

a. Establish written grievance policies and procedures that systematically address workers’ grievances and permit workers to lodge grievances against their supervisors without having to report the grievance to that supervisor, allow workers to address their grievance without penalty or reprisals of any kind, and provide for management follow-up. b. Keep detailed documents

Procedures must be judged by the auditors and workers to be fair and effective.

Most workers who report using the procedures must judge the procedures to be effective.

Management response to worker grievance must be judged by the auditors and workers to be prompt and effective.

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Employment Policies

Verité Good Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

dismissing workers impedes workers’ ability to comfortably raise a grievance. Worker interviews revealed that workers have no faith in their ability to file a grievance with management regarding harassment and abuse, so they approached BEPZA authorities approximately two weeks prior to this audit regarding harassment and abuse at the factory. An office order was subsequently issued by BEPZA that banned all types of unreasonable punishment and allowed workers to arrive a maximum of 15 minutes late without penalty. Workers noted that they believe no such resolution would have been possible if they had approached management themselves. The auditors further noted that no grievance and dismissal files have been kept for many workers who were reportedly summarily terminated by the factory for various offenses, including exercising their right to freedom of association. Grievance records for all grievances filed should be kept on file, on site. The auditors also reported that although there are complaint boxes posted at work stations, management could provide no documentation proving that any of the grievances filed in the boxes have ever been addressed.

of all grievances filed, including details of procedures followed, and keep all related documents on file, on site. c. Establish a system for promptly responding to grievances filed using the complaint boxes at the work stations.

DISCIPLINE AND TERMINATION

Application of discipline and termination procedures must be standardized throughout the factory. “Standardized” means all supervisors and managers must employ the same reasonable disciplinary measures and most of the workers must report that the same disciplinary/ termination procedures are applied.

BEPZA Instructions specify a standardized discipline and termination process to be followed for disciplinary action against a worker, including dismissal / termination (BEPZA Guidelines for the enterprises of CEPZ pertaining labour matters, November 14, 1988, Sections 15-19). According to workers interviewed, factory disciplinary procedures are not standardized and do not follow the steps required. Workers reported that they are fired instantaneously and sometimes workers who work on a line suddenly discover that a worker is missing and has been fired without warning.

a. Establish standardized disciplinary procedures that include an escalating series of verbal and written warnings prior to suspension or termination, and do not include punitive deductions from workers’ pay. Immediately cease the practice of summarily firing workers and prohibiting them from providing defense for their actions.

Discipline and termination procedures must be judged by most (more than half) of the workers and/ or the auditors to be reasonable.

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Employment Policies

Verité Good Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

Workers stated that many have been fired without being able to defend themselves and no due process is observed. According to workers, during the work stoppage at the end of January 2012, management, with BEPZA’s mediation, closed down the factory for a few days and summarily disposed of involved workers. Also according to workers, police intervention and beatings were used to discipline and intimidate workers, further breaching the already strained relationship between workers and management. The auditors noted that at the time of the audit, the situation surrounding worker protest actions in the Ishwardi EPZ was quite volatile. In late March and concurrent with the onsite visit, local police were involved in an escalating situation. Workers also stated that new recruits who are working on a probationary period are sometimes fired without explanation and their ID cards are confiscated. If they attempt to resist, the new recruits are literally pushed out of the factory by security guards. Workers also noted that they are fired for being absent without permission even if there has been a family emergency. The workers noted that termination on such grounds usually happens during lean production seasons when workers are not needed as much. Workers interviewed reported that permanent workers who are dismissed receive an equivalent of three month’s salary, but are forced to sign resignation letters which follow a standardized format. They also reported that they receive a deduction equivalent to a full day’s pay if they are late to work more than three days per month. Additionally, it was reported that workers turned to BEPZA authorities to address their grievance against Bangladeshi managers who use abusive language toward workers as a means of disciplining them. Workers approached BEPZA authorities approximately two weeks before the audit regarding disciplinary harassment and abuse; and an office order was subsequently issued that banned all types of unreasonable disciplinary punishment and allowed workers to

b. Cease the practice of utilizing deductions for tardiness or time missed that exceed the wage equivalent of actual time missed. c. Cease the practice of forcing dismissed workers to sign letters of resignation. d. In any case of worker dismissal, follow the guidelines for disciplinary actions as prescribed in the Bangladesh Export Processing Zone (BEPZA) Instructions. Workers should not be terminated for any offense without following these standardized procedures. e. Cease the practice of allowing factory security guards to engage in disciplining workers.

The use of punitive deductions (fines) to workers’ pay is unacceptable.

Deductions for tardiness or time missed must not exceed the wage equivalent of the actual time missed.

Workers should not be prohibited from working if they are tardy.

Workers must never be forced or asked to sign a letter of resignation or a blank paper.

Factory security guards should not intimidate workers or be asked to enforce disciplinary measures.

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Employment Policies

Verité Good Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

arrive a maximum of 15 minutes late without penalty.

DISCRIMINATION

Discrimination is unacceptable in hiring, salary, benefits, advancement, discipline, termination, or retirement practices on the basis of gender, race, religion, age, disability, pregnancy, sexual orientation, nationality, union affiliation, political opinion, or social or ethnic origin.

According to workers, during the work stoppage at the end of January 2012, management, with BEPZA’s mediation, closed the factory for a few days and summarily disposed of workers, without allowing them to defend themselves. After January 31, 2012, several workers were dismissed after

a

bout of labor unrest. The factory was closed for 12 days, and on the day the factory resumed working, the names of several workers were hung at the front gate. These workers were not allowed to enter the factory and were asked to report to the BEPZA office. The auditors noted that information is conflicting on the number of workers that were dismissed, with interviewees and media reports citing differing figures. Interviewees noted that amongst the workers that were dismissed, those who had completed one year of service were dismissed with three months’ salary, but the trainees on the list were terminated with no compensation. A police case was also filed against several workers (again, the auditors note that sources differ on the number of workers), and many workers were reportedly arrested and beaten by the police. The auditors reported that the Worker Welfare Association is allowed by EPZ authorities in lieu of a trade union and that operation without interference from management is permissible. However, auditors noted that the Association is not allowed to operate freely, as workers fear retaliation if they should put the Association into practice.

Take measures such that workers are not discriminated against for freedom of association activities conducted within the requirements of BEPZA regulation, including involvement in the Worker Welfare Association.

FREEDOM OF ASSOCIATION

Management must not interfere with workers’ legal rights to associate freely or to form and join unions and workers must not be punished or dismissed or receive reprisals of any kind for doing so.

Workers interviewed reported that during the work stoppage at the end of January 2012, management, with BEPZA mediation, closed down the factory for a few days and summarily terminated workers, without allowing them to defend themselves. The factory was closed for 12 days, and on

a. Provide all workers with the right to freely associate within the requirements of local law and operate the Worker Welfare Association without

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Employment Policies

Verité Good Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

the day the factory resumed working, the names of several workers were hung at the front gate. These workers were not allowed to enter the factory and were asked to report to the BEPZA office. The auditors noted that information is conflicting on the number of workers that were dismissed, with various media reports and interviewees citing differing figures. Interviewees noted that amongst the workers that were dismissed, those who had completed one year of service were dismissed with three months’ salary, but the trainees on the list were terminated with no compensation. A police case was also filed against many of these workers (again, the auditors note that sources differ on the number of workers) , and many workers were reportedly arrested and beaten by the police. The auditors reported that the Worker Welfare Association is allowed by EPZ authorities in lieu of a trade union and that operation without interference from management is permissible. However, according to interviews the Association is not allowed to operate freely, as workers fear retaliation if they should put the Association into practice. Based on information gathered from the media and workers of a local NGO interviewed by the auditors, on January 20, 2012, when the elected representatives of the WWA wanted to negotiate with the personnel manager over earned leave encashment, the WWA asked for an explanation for deduction of 10 days earned leave (EL) from the EL encashment bill. Conversation between the two parties became heated and escalated into a conflict, whereby the elected workers were harassed and a large number of workers protested. This is when the worker agitation started and the factory was closed down for 12 days to sort out the disciplining of workers. Police cases were filed against most of the elected representatives and several workers were fired.

fear of reprisal or punishment of any kind. b. Cease the practice of interfering with the Worker Welfare Association and allow it to operate freely without intervention.

Most of the workers must be reasonably aware of their rights to associate freely and to form and join unions.

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COMPENSATION AND HOURS

Verité Best Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

REGULAR WAGES

Trainees must be upgraded to permanent status after three months, or earlier as per law.

Bangladesh labor law states that the probationary period should be for three months, after which a worker should be upgraded to permanent status, or the probation period may be extended for another three months after which the worker must to be upgraded or dismissed. According to BEPZA instruction no. 2 of 1989, which was amended in October 2010, an apprentice (trainee) worker shall be given a consolidated wage of USD 39 per month; the period of training should be for three months which may, however, be extended by another three months at the maximum. The auditors reported that trainees/probationary workers are not upgraded to permanent status after three months.

Ensure that the facility upgrades trainees / probationary workers according to local regulations.

Other findings. The auditors reported that factory documents indicated that the facility is compliant with minimum wage payments according to BEPZA law, however, minor discrepancies were noted, as certain pay scales had not been correctly adjusted for the exchange rate of the US dollar and BDT Taka. For instance, a discrepancy of $.43 was noted in the pay scale of trainees.

Take measures to ensure that the facility makes the correct adjustments in the exchange rate of USD to BDT Taka when calculating workers’ wages.

The auditors reported that minor discrepancies in the production sheet piece rate calculations were found, as some workers were slightly short changed (approximately $.40) and some workers were inadvertently paid more than they earned. These errors were judged to be likely calculation errors, rather than a systematized attempt to cheat workers out of wages.

Conduct regular payroll reviews to ensure that workers are earning the correct wage when they are paid.

BENEFITS AND DEDUCTIONS

All workers must be provided with the holidays and leave to which they are

Workers interviewed reported that applications for leave are jeeringly turned down by line leaders and personnel

Permit workers to avail themselves of the vacation

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COMPENSATION AND HOURS

Verité Best Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

legally entitled.

department staff members when workers submit them. The auditors reported that through review of sample payroll documentation, they found that during the month of February 2012, 82 workers used casual leave time and 18 workers used sick leave. However, the auditors noted that workers interviews revealed that workers are discouraged from asking for leave, and often face harsh treatment for the request or are marked as absent without leave.

and sick leave benefits to which they are entitled.

REGULAR HOURS AND OVERTIME

Regular and overtime hours must not exceed legal limits, Code of Conduct limits, or Verité Best Practice Standards, whichever is lower.

Bangladesh labor law limits overtime to two hours per day (Bangladesh Labour Code, 2006, Articles 100 and 108). Male workers interviewed reported that they sometimes work in excess of two overtime hours per night – sometimes working day and night shifts back-to-back – in violation of the law. Female workers reported that they are not required to work night shifts.

Ensure that overtime work hours are limited to two per day, as per law.

PRODUCTION QUOTAS Workers must not be penalized for failing to reach production quotas.

Most of the workers interviewed reported that they only sometimes meet their production quotas, and only three workers interviewed reported that they meet their quotas most of the time (out of 32 workers interviewed). Workers reported that if they fail to meet their production quotas on a regular basis, their employment is terminated and they are offered the option of being re-hired by the factory at the lowest work level.

a. Cease the practice of terminating and re-hiring workers for failing to meet their production quotas. b. Review the reasonableness of the factory’s quota system such that the majority of workers can meet their quota on a daily basis.

PAY PRACTICES At least 75 percent of the workers must understand how their wages are calculated.

The auditors reported that the payment structure utilized by the factory is quite complicated, and worker interviews indicated that workers uniformly do not have a clear understanding of how their production incentive is calculated

Conduct trainings to inform workers how their wages and pay slips are organized and calculated, and prominently

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COMPENSATION AND HOURS

Verité Best Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

for overtime. The auditors noted that for regular working hours, 60 percent of the gross pay is given as basic pay and the balance, 40 percent, is provided as a fixed production incentive target (a production quota). Every worker has to fulfill their quota in order to earn the additional incentive bonus. For instance, a trainee’s gross salary according to BEPZA is USD 39 times BDT 83.70 for a total of BDT 3,264. Sixty percent of this sum is provided as basic pay; 40 percent is calculated with a production incentive clause. Forty percent divided by the total working days according to the factory, multiplied by the total working days of the worker, is equal to a worker’s production incentive. If the worker can exceed their production target, they are given a production incentive; otherwise they only receive the 40 percent due. The overtime calculation is not based on piece rates, but on basic wages. Workers strongly suspect that they are being cheated of overtime wages because of this complicated process.

post instructions, explanations, and diagrams of pay slips and calculations throughout the factory for all workers to review. These documents should be written and labeled in the languages spoken by the workforce.

Other findings. The auditors reported that they were not provided with copies of workers’ pay slips for review, as requested. The auditors note that the circumstances surrounding the audit likely interfered in management’s ability to provide requested documents in a timely manner. During the audit, the factory’s personnel manager attempted to provide the auditors with as many documents as possible (and continued to provide scanned copies of documents to the team after the audit), but ultimately was not able to furnish some of the documents requested.

Ensure that copies of workers’ time cards are kept on file, on site.

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HEALTH AND SAFETY

Verité Best Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

Completion Date

EXITS- VISIBILITY

Exit signs must be clearly visible at 100 feet/ 30 meters.

The auditors reported that not all exit signs in the factory are clearly visible at 100 feet.

Take measures to ensure that all exit signs are clearly visible from 100 feet (30 meters).

WIRING/ ELECTRICAL

The factory must maintain maintenance and testing records for the electrical systems.

The auditors reported that they were not provided with maintenance and testing records for the factory’s electrical systems. The auditors note that the circumstances surrounding the audit likely interfered in management’s ability to provide requested documents in a timely manner.

Keep maintenance and testing records for the factory’s electrical systems on file, on site.

ALARMS/ EMERGENCY SYSTEMS

Other findings.

The auditors reported that the factory’s emergency alarm and lighting systems could not be tested at the time of the audit.

Ensure that the factory’s emergency alarm and lighting systems are regularly tested and maintained to ensure their functionality.

ELEVATORS

Elevator permits must be valid.

The auditors reported that at the time of the audit, the elevator in the main building was not in use, and factory management could not provide elevator permits for review.

In the event that the elevator in the main production building is put in use, obtain a valid permit prior to putting it into service.

CHEMICAL SAFETY

Areas where toxic chemicals are used must be posted with safety and warning signs. Signs should be in a language understood by the workers and include chemical composition, potential health hazards of exposure, instructions on safe use/ handling, and instructions for what

The auditors reported that there are no safety warnings signs posted that warn workers of potential health hazards of exposure.

Prominently post safety/warning signs in all areas where toxic chemicals are in use warning workers of potential health hazards of exposure.

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HEALTH AND SAFETY

Verité Best Practice Standards Findings (and Legal Reference, if applicable) Remediation/Action Plan Facility Response and Target

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to do if exposure exceeds safety levels.

Relevant MSDS must be posted or readily available and written in a language understood by workers.

The auditors reported that MSDS are written in English.

Provide MSDS that are written in the languages of the workforce.

Signs are posted that require workers to wash hands after handling, storing or disposing of chemicals in bathrooms, kitchens, and production areas.

The auditors reported that there were no hand washing reminders posted in the bathrooms and kitchen.

Prominently post signs in bathrooms and kitchen reminding workers to wash their hands after handling, storing, or disposing of chemicals.

Chemicals must be properly stored. Storage must be away from work areas, toilets, cafeterias, and open flames; in secure, sealed containers; labeled with the chemical’s name, use instruction, and exposure warnings in a language the workers understand; and storage areas must be ventilated.

The auditors reported that chemical containers are labeled only in English.

Label all chemical containers in the languages spoken by the workforce

PERSONAL PROTECTION EQUIPMENT

Posters should be posted in relevant work areas showing what PPE should be worn.

The auditors reported that posters are not posted in all work areas detailing which PPE should be worn.

Prominently post posters in all work areas detailing which PPE should be worn in each area.