Eicc Confidential - Eicc Gap Analysiss Only: Important Notice

EICC CONFIDENTIAL - EICC Gap Analysiss ONLY
The EICC information below is strictly confidential and subject to Agreement on Exchange of Confidential Informa (AECI).
The EICC VA Protocol can only be used by EICC Qualified Audit Firms and EICC VAP auditors.
IMPORTANT NOTICE: The EICC VA Protocol is strictly internal to EICC and cannot be used by any organization for any purpose other than EICC recognized Audit Program.
Auditee Information
Auditee/Facility Name TPV Electronics (Fujian) Co., Ltd.
Address Rongqiao Economic and Technological Development Zone, Fuqing City, Fujian Province, P.R. China
Country China
Facility Manager (Name & Title) Mr. Youzhu CHEN (General Manager)
Main Contact(s) for Audit (Name
& Title) Mr. Lock HUANG (vice manager of ISO office)
email lock.huang@tpv-tech.com
Telephone 86-591-85285555-7373
name email Phone

Auditee contact for
Person who is authorized to Mr. Lock HUNAG (vice manager of ISO office) lock.huang@tpv-tech.com 86-591-85285555-7373
approve and release the audit
Mr. HUI ZHAO (HR supervisor) felix.zhao@tpv-tech.com 86-591-85285555-8317
Labor:
Environmental: Health and Ms. Rui WANG (EHS supervisor) zara.wang@tpv-tech.com 86-591-85285555-8719
Safety:
Issued by/service date of issue/start valid until/end date

provided: date
NA NA NA NA
Labor
NA NA NA NA
Ethics
Certifications ISO14001:2004 No.CN97/31001 SGS 22/12/2015 15/09/2018
(include certificate number) Environment
OHSAS18001:2007 No. CN15/31518 SGS 23/12/2015 22/12/2018
Health & Safety
ISO9001:2008 No. CN93/2546 SGS 05/04/2015 04/04/2018
Others QC080000 No. IECQ-H SGSCN 09.0316 SGS 17/08/2015 16/09/2018
NA NA NA NA
Labor
NA NA NA NA
Ethics
NA NA NA NA
Environment
Supporting services used in last NA NA NA NA
3 years Health & Safety
(describe services) NA NA NA NA
Labor agent/contractor
NA NA NA NA
School/Academic insitution
(for student workers only)
NA NA NA NA
Others
Audit Information
Start date of the Audit: 06/06/2016
Close date of the Audit: 08/06/2016
Audit Type: Initial audit
Bureau Veritas
Audit Firm Certification
Audit Team:
name email Phone
Lead: Linda FU linda.fu@cn.bureauveritas.com 18017501362
Labor Linda FU linda.fu@cn.bureauveritas.com 18017501362
Ethics Linda FU linda.fu@cn.bureauveritas.com 18017501362
Health and Safety Lian WANG lian.wang@cn.bureauveritas.com 18017501279
Environment Lian WANG lian.wang@cn.bureauveritas.com 18017501279
Management System Lian WANG lian.wang@cn.bureauveritas.com 18017501279
Executive Summary
Legal Nonconformance Risks

A 1.5 Major It was defined in the item 4.4.3 of the labor service contract which signed with BONA labor source service company that the 30 days prior notice to
the company are required from employees for resignation. However, it do not meet requirement of the prior notice for probation.
A 3.1 Minor It was shown in the work time record of (Jun. 2015-low, Nov. 2015-peak, May. 2016- average) that 16.7% workers worked overtime more than 36 hours per month
as local laws requirements.
A3.3 Minor The work time record of Jun. 2015-low, Nov. 2015-peak, May. 2016- averageand found the sampled workers work time were not meet the EICCs
requirement. It was showed that the overtime should be controlled more effective.
B4.2 Minor Workshop. High voltage test employees has no insulant shoe, and the regular test record of insulant gloves has not been provided on assembling workshop
Executive summary
TPV Electronics (Fujian) Co., Ltd. is one subsidiary of TPV Group and its main scope of the facility is design and manufacturing of monitor and TV. The company is located
at Rongqiang Economic and Technological Development Zone, Fuqing City, Fujian Province, P.R. China. The company had obtained the certification of ISO9001, ISO14001,
OHSAS18001 and QC080000 management systems.
There are totally 4479 employees in the company.
The audit is conducted as an Non-VAP audit. Totally 5 mandays on site. It is performed to evaluate the facility's labor, ethics, occupational health and safety and
environmental practices and supporting management systems against the EICC Audit Criteria and applicable laws and regulations. No exception management or integrity issues
were encountered during the Audit.
Totally, 1 major findings, 3 minor finding raised during the audit:

Major Nonconformances:
A 1.5 Major It was defined in the item 4.4.3 of the labor service contract which signed with BONA labor source service company that the 30 days prior notice to
the company are required from employees for resignation. However, it do not meet requirement of the prior notice for probation.
Minor Nonconformances:
A 3.1 Minor It was shown in the work time record of (Jun. 2015-low, Nov. 2015-peak, May. 2016- average) that 16.7% workers worked overtime more than 36 hours per month
as local laws requirements.
A3.3 Minor The work time record of Jun. 2015-low, Nov. 2015-peak, May. 2016- averageand found the sampled workers work time were not meet the EICCs
requirement. It was showed that the overtime should be controlled more effective.
B4.2 Minor Workshop. High voltage test employees has no insulant shoe, and the regular test record of insulant gloves has not been provided on assembling workshop
Management attitude
The management has attended the opening meeting and closing meeting. The management is cooperative during the audit. The management promises to take corrective actions
for the nonconformances found.
Worker attitude
All workers attended interviews were freely selected by the auditors. Interviews were conducted either in group or individual in a confidential manner. Some interviews
with individual worker were conducted in a separate room, whereas others were conducted either in production lines or on spot. The Interviewed workers' attitude is open
to the audit. They can talk the condition in the company freely. Most of them gave positive comments to the company.
Process Integrity
The audit covered all EICC requirements: labor, ethics, environment, health & safety, management.The documents and records were analyzed. Individual workers and group
workers were interviewed. The offices, workshops, warehouses, dormitory were visited.
Closing meeting
LABOR/EHS Senior Manager and other managers attend the closing meeting. The audit findings were communicated to the management. The NC had been agreed by the management
and the top they promised to take corrective actions.
Exception management
None
Governance and acceptance

Audit Serial number: NA
Auditee Agreement Section

Agreement Date: 8-Jun-16
Auditee Management Response
OK
APM integrity changes made: NA
Significance
Absolute Conformance
Overall Audit Score Result
(worst individual finding)
187 Major
AUDIT SCORE DETAIL

M
o
s
Major Risk of non Minor
Weighted Conformance Score Priority Not Reviewed Not Applicable Conformance t
Nonconformance conformance Nonconformance
S
e
r
M
Overall 187 0 1 0 3 0 0 89 a
j
M
Labor 177 0 1 0 2 0 0 29 a
j
M
Health & Safety 191 0 0 0 1 0 0 22 a
j
M
Environment 200 0 0 0 0 0 0 12 a
j
C
Ethics 200 0 0 0 0 0 0 10 o
n
M
Management System 200 0 0 0 0 0 0 16 a
j
Audit Findings
General code and legal compliance
Tool reference Question Significance Description Supporting evidence

Labor
A1 Freely Chosen Employment

Forced, bonded (including debt bondage) or indentured labor; involuntary prison labor; slavery or trafficking of persons shall not to be used. This includes transporting, harboring, recruiting, transferring or receiving vulnerable persons by means of threat, force, coercion, abduction
or fraud for the purpose of exploitation. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment. Workers must not be required to surrender any government-issued identification, passports, or work permits as a condition of
employment. Excessive fees are unacceptable and all fees charged to workers must be disclosed.
Data point 1: Site observation: The workers moved freely in the factory without restriction.
Data point 2: Document Review; The detailed policy was defined in the <TPV employee manual>, 15 version, release on April 2014,Labor and <Ethics Manual>, TPVFQ-LEM-01,08
Any type of forced, Version, It stated that any type of force labor was forbidden in the company.
involuntary prison,
All employees joined the company
indentured, bonded Data point 3: Management Interview; Mr. Hui Zhao/HR supervisor stated that no withdraw of ID, no deposit was taken for worker employment, and no forced prison or bonded
A1.1 Conformance voluntarily. All of them had signed labor
(including debt bondage, worker was used.
contracts with the company.
trafficked or slave) labor
is not used Data point 4: 67 workers interviewed, they all said that no any type of forced, prison, indentured or bonded labor used.
Legal references:---
Supporting evidence reference(s):---
Data point 1: Document Review:
The detailed policy of freely choosen employment was defined in the <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-01,08
Version.
Adequate and effective
policy and procedures are Data point 2: Management Interview: Mr. Hui Zhao/HR supervisor, stated that the ID card and personnel information should be checked in the recruitment process. No forced
The company prohibit using any type of
established ensuring that labour is used in the company.
forced, involuntary prison, indentured,
A1.2 any form of forced, bonded, Conformance
bonded (including debt bondage, trafficked
involuntary prison, Data point 3: Worker interview
or slave) labor.
trafficked or slave labor 67 workers were interviewed.They all stated that they joined the company volunteer and they signed the labor contact themselves. No any type of forced, prison, indentured
is not used. or bonded labor used.
Legal references: --
Supporting evidence reference(s):--
Data point 1: Document review

Workers are informed in The detailed policy on freely choosen employment policy was defined in the <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-
writing and in their own 01,08 Version.
language prior to
employment (in case of Data point 2: Management review
migrant workers, before The workers had signed labor contracts Mr. Hui Zhao/HR supervisor stated that employee terms and conditions are included in TPV employee manual and labor and Ethics Manual, contract, which is in Chinese and is
A1.3 they leave their home Conformance with the company. The contracts were in communicated to workers before they take over the job.
country/region) of the key compliance with the legal requirements.
employment terms and Data point 3: worker interview
conditions via employment 67 workers were interviewed, they state that they had signed labour contracts with the company.
letter/agreement/contract
as required by law Legal references: NA
Supporting evidence reference(s): NA
Data point 1: Document review:

The detailed policy on freely choosen employment policy was defined in the <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-
Upon hiring, the workers
01,08 Version. It declared that the company should no hold the government issued identification.
government issued
identification and personal
Data point 2: Management interview:
documentation originals are The copy of ID card, was collected by the
Mr. Hui Zhao/HR supervisor stated that the copy of ID card will be collected by HR Dept. No government identification is held by the facility.
A1.4 not withheld by Conformance company. No ID card, other governmental
employer/labor document was withheld by the company.
Data point 3: Worker interview:
agent/contractor (if
67 interviewed workers stated that they joined the facility voluntarily.No deposit, or government identification is held by the facility.
applicable) without formal
consent.
Legal references: NA

The policy was defined in the employees' <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-01,08 Version , states that workers are able to resign 30 days after notice,
manual. It stated that 30 days for and the resignation notice time is 3 days for workers in probation. Resignation application form received in 2015 reviewed show that the workers can leave company within 30
employees, only 3 days for employees in days after submission.
probation. However, one NCR was rasied during this audit, detailed as,'It was defined in the item 4.4.3 of the labor service contract which signed with BONA labor source service
company that the 30 days prior notice to the company are required from employees for resignation. However, it do not meet requirement of the prior notice for probation.
Workers are free to leave However, one NCR was rasied during this '.
their employment upon audit, detailed as,'It was defined in the
A1.5 Major
giving reasonable notice, item 4.4.3 of the labor service contract Data point 2: Management interview:
with no penalty which signed with BONA labor source Mr. Hui Zhao/HR supervisor stated the policy which is stated in the worker handbook.
service company that the 30 days prior
notice to the company are required from Data point 3: Workers interview:
employees for resignation. However, it do 67 interviewed workers state that they had trained about the resign process requirement.
not meet requirement of the prior notice
for probation. '. Legal references: China labour contract law
The policy on freely choosen employment policy was defined in the <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-01,08
Version. It declared that no payment fees, deposits required or debt repayment for employment.
The company recuit the employees/workers
Workers are not required to Data point 2: Management interview:
directly. And workers joined the company
pay fees, deposits or debt Hui Zhao/HR supervisor stated the company's policy about no deposit, debt repayment for employment.
A1.6 Conformance voluntarily.
repayments for their
employment Data point 3: Workers interview:
67 interviewed workers state that they do not have to pay deposit when they join the facility.
Data point 1: Site observation:

On-site observation shows that workers have basic liberties. There is no restriction for toilet passes, talking with others.

The detailed basic liberties policy was stated in the <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-01,08 Version. There is
There are no unreasonable no restriction policy for workers moving in the company.
restrictions on the
Workers had basic liberties in the
A1.7 movement of workers and Conformance Data point 3: Management interview:
company.
their access to basic Mr. Hui Zhao/HR supervisor stated the policy on basic liberties. They states no any restriction for toilet passes, talking with others.
liberties
67 interviewed workers state that there is no restriction for toilet passes, talking with others.
A2) Child Labor Avoidance

Child labor is not to be used in any stage of manufacturing. The term child refers to any person under the age of 15 (or 14 where the law of the country permits), or under the age for completing compulsory education, or under the minimum age for employment in the country, whichever
is greatest. The use of legitimate workplace apprenticeship programs, which comply with all laws and regulations, is supported. Workers under the age of 18 shall not perform work that is likely to jeopardize the health or safety of young workers.

No visible child worker worked in the company.

The forbidden child labor policy was defined in the <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-01,08 Version.
The roster showed that the youngest worker was born on Nov. 19, 1999.
Workers are not below the
A2.1 Conformance No worker was found below the minimum age. Data point 3: management interview:
minimum age
Mr. Hui Zhao/HR supervisor stated that ID card is checked at the recruitment process. All the employees who join the facility should be over 16 years old.
Data point 4: Workers interview:

67 interviewed workers state they were adult.
No visible child labour is found in the company.
Data point2: Document review:

An adequate and effective
No child labour policy is stated in <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-01,08 Version. It showed that ID card
policy and process is
will be checked in the recruitment process and re-checked the ID card used at the HR Dept. Namelist checked indicates that no child labor is found.
established to ensure that
The ID card will be checked at the
workers below the legal
A2.2 Conformance recruitment process. No worker was found Data point 3: Management interview:
minimum working age are not
the age was below 16 years old. Mr. Hui Zhao/HR supervisor can explain the policy. He can explain the ID card check method in the recruitment process.
hired either directly or
via labor agencies /
contractors
67 interviewed workers state that they have been trained on prohibition of child labour which is stated in the employee handbook.

On-site observation showed that no young workers work at the hazard positions.

Workers under the age of 18 The young worker protection policy is stated in <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-01,08 Version.
are not allowed to perform As the sample result of onsite observdaton
work that is likely to and document review, the young workers Data point 3: Management interview:
A2.3 Conformance
jeopardize the health or worked in the safety condiction in the Mr. Hui Zhao, HR supervisor, can explain the young worker policy and no young workers work at the hazard positions.
safety of these young company
workers Data point 4: Worker interview:
67 interviewed workers, 3 interviewed young workers, states that they do not work overtime.
Data points: 1, Document review:

The facility has established Student worker management method, which released on 24/10/2013. The labor contract with the student workers were available.
Data points: 2, Management interview:

Apprentice/intern/student Mr. Hui Zhao, HR supervisor, stated that some student workers are employed in the company. They plan to reduce the student workers number in the future.
No apprentice/intern/student worker was
A2.4 worker employment policies Conformance
found in the company.
and practices are in place Data points 3: Worker interview:
67 interviewed workers, included 2 students workers stated that they signed labour agreements with the company,
A3) Working Hours

Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Workweeks are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in
emergency or unusual situations. Workers shall be allowed at least one day off per seven-day week.
It was shown in the work time record of (Jun. 2015-low, Nov. 2015-peak, May. 2016- average) that 16.7% workers worked overtime more than 36 hours per month as local laws
requirements.
One NCR was raised during this audit,
Average hours worked in a detailed as:
Data point 2: Management interview
workweek over the last 12 It was shown in the work time record of
Mr. Hui Zhao, HR supervisor, they had control the work time from 2015 and the overtime time had reduced, however, parts of the workers's overtime exceed 36 hours per month.
A3.1 months does not exceed 60 Minor (Jun. 2015-low, Nov. 2015-peak, May. 2016-
hours or the legal limit average) that 16.7% workers worked
Dtat point 3: Worker interview
(whichever is stricter). overtime more than 36 hours per month as
67 interviewed workers state that they worked overtime only in case of urgent work order.
local laws requirements.

Jun. 2015(Low), Nov. 2015(Peak) and May. 2016(Average/Current) are sampled. The consecutive days are not more than 6 days. .
Data point 2: Management Interview

Workers receive at least Mr. Hui Zhao, HR supervisor, stated that the company one day off in each 7 days were control by the company.
Workers received at least on day off
A3.2 one (1) day off per seven Conformance
during 7 days.
(7) days Data ponint 3: worker interview
67 interviewed workers interviewed state that they had one day off in week at least.

Working and rest time policy are stated in TPV employee manual: 15 version, release on April 2014,Labor and Ethics Manual, TPVFQ-LEM-01,08 Version. The sampled workers'
worktime record were provided by the company's head office in the Xiamen and shared the data in the company's HR share folders.One minor NCR was raised in the A3.1.
policy and
Data point 2: Management Interview:
system/procedures are
Mr. Hui Zhao, HR supervisor reported that each employee was required to slip the electronic card when the enter/lefe the workplace. The work time records were stored in the
established to determine, One NCR was rasied during this audit
attendance database. The database was managed by the head office in the Xiamen, mostly due to the IT dept had moved to xiamen from 2015. The wage were calculate by the
communicate, record, manage 16.7% workers' monthly overtime were
headoffice. If any staff/workers wanted to check the attendance record, the HR staff will connect with the HQ staff to share the raw data to the company's HR share folder.
A3.3 and control working hours Minor exceed 36 hour as local law's requirement,
He also stated that overtime control have been controlled strictly from 2015, the actual overtime had been dicreased.
including overtime, it means that the overtime should be
including reliable and controlled more effective.
detailed records of workers
67 interviewed workers state that they slip the electronic card when they entre/left the company. The overtime hours were shown in the payslip. The overtime need be applied
regular and overtime
in advance.
working hours

The holiday, vacation policy in stated in <TPV employee manual>, 15 version, release on April 2014. The policy is in compliance with legal requirements.
Workers are allowed legally
mandated breaks, holidays
Mr. Hui Zhao, HR supervisor, can explain the policy and states that holiday and vacations are in compliance with legal requirements.
and vacation days to which Workers are allowed legal mandated breaks,
A3.4 Conformance
they are legally entitled, holidays and vacation days in the company.
Data point 3: worker interview:
including time off when ill
67 interviewed workers report that they were trained about the holiday and vacations. They can apply the annual leave freely.
or for maternity leave
Legal references:
Supporting evidence reference(s):
A4) Wages and Benefits
Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates.
Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being paid is to be provided in a timely manner via pay stub or similar documentation.
Data point 1: Documental Review: The payment policy is stated clear in <TPV employee manual>, 15 version, release on April 2014. <Salary management process>, A00, issued on
Jan. 12, 2016.

Legal wages for regular and Mr. Hui Zhao, HR supervisor stated that the wage were auto calculate by the headoffice in Xiamen. The payslip was delivery to each worker monthly, the workers can checked,
The wages and overtime wage were
overtime hours are if any problem, HR staff will help the workers to check with the headoffice. The wage was paid to all staff before 5th of next month.
A4.1 Conformance calculated correctly and paid to the
correctly calculated and
workers on time.
paid to all workers Data point 3: Worker interview:
67 interviewed workers state that the wage are calculated correctly and paid to them on time.
Data point 1: Documental Review:

Payment records in June 2015, Nov. 2015 and May 2016 are reviewed. The payment information are described in the payslips.

Wage calculations are Mr. Hui Zhao, HR supervisor stated that workers are provided payslips monthly. The payment information are described in the payslips.
The pay stub was communicated to the
clearly communicated to
A4.2 Conformance employees. And the payment items were
workers using pay stub or Data point 2: Worker interview:
indicated clearly in the pay stub.
similar documentation 67 interviewed workers state that payslips are distributed to them every month, they understand the pay slip.

Social insurance invoices from Feb. 2016 to April 2016 are checked. The auditor also sample checked the employees randomly.

Social insurance scheme and Mr. Hui Zhao, HR supervisor stated that the company has provided social insurance in compiamnce witht the legal requirements.
other benefits as required The social insurance and benefits was
A4.3 Conformance
by local law is provided to provided to employees. Data point 3: Worker interview:
all workers 67 interviewed workers stated that they are provided social insurance.
5 resignation records are reviewed. The payments for the resignation workers are checked. The wages were paid with 3 days.

Payments to workers are not Mr. Hui Zhao, HR supervisor stated that that workers are paid before 05th per month. The wage will be paid in 3 days if workers resign.
delayed or withheld and Payments to workers are not delayed or
A4.4 Conformance
proof of wage payments to withheld Data point 3: Worker interview:
workers is maintained 67 interviewed workers state that they are paid before 05th per month. They also know that the wage will be paid within 3 days if they resign the company.

Disciplinary notice forms from Jan. to May 2016 are checked. No wage deduction for disciplinary reason is found.

Mr. Hui Zhao, HR supervisor stated that the Organization does not practice deductions on payroll for disciplinary reasons.
Wages are not deducted or
A4.5 reduced for disciplinary Conformance No wages deducted or reduced was found.
reasons
67 interviewed workers state that they have heard the wage is not been deducted for the disciplinary reasons.
legal references: NA

The payment records in June 2015, Nov. 2015 and May 2016 are reviewed. Social charges and taxes are calculated correctively.
Deductions or withholdings
are calculated correctly
and submitted to the The social insurance fee was deducted from
Mr. Hui Zhao, HR supervisor stated that the deduction of social insurance are in comliance with legal requirements.
A4.6 appropriate government Conformance the wage. The fee was handed in the local
agency within the time insurance bureau.
frame specified in the
67 interviewed workers state that they know the deductions on the payroll, including social insurance charges.
applicable local labor law
A5) Humane Treatment

There is to be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these
requirements shall be clearly defined and communicated to workers.
Data point 1: Site observation
Site observation shows that no sexual harassment or abuse, corporal punishment, mental or physical coercion, verbal abuse or intimidation is found.

Complaint records show that no sexual harassment or abuse, corporal punishment, mental or physical coercion, verbal abuse or intimidation happened in the company.
No evidence of sexual
harassment or abuse, No sexual harassment or abuse, corporal
corporal punishment, mental punishment, mental or physical coercion,
A5.1 Conformance Mr. Hui Zhao, HR supervisor, states that sexual harassment or abuse, corporal punishment, mental or physical coercion, verbal abuse or intimidation is prohibited in the
or physical coercion, verbal abuse or intimidation exists was
company.
verbal abuse or found in the company.
intimidation exists
67 interviewed workers state that no sexual harassment or abuse, corporal punishment, mental or physical coercion, verbal abuse or intimidation is found in the company.

The discipline policy is stated in the <TPV employee manual>, 15 version, release on April 2014,<Labor and Ethics Manual>, TPVFQ-LEM-01,08 Version. Minor fault, major
fault, dismissal, and awared and discipline action control procedure indicates that discipline procedure is defined, and the complaint channel is identified as: suggestion
box, hotline, report to managers, or contact with work representatives in the company.
policies and procedures on
The discipline policy and complaint Data point 2: Management interview:
decent/humane working
channel is established in the company. And Mr. Hui Zhao, HR supervisor, states that the discipline policy is stated in the employee handbook. The complaint channel is identified as: suggestion box, report with
A5.2 conditions and fair Conformance
the policy has been communicated to all manager, or contact with work representatives.
treatment of workers are
employees.
established and
communicated to all workers
67 interviewed workers state that they know the complaint channel and the discipline policy and practices.

The discipline records from Jan. 2016 to May. 2016 were reviewed. The description of the cases, discipline level, the signature of HR Manager is available and are in
compliance with the discipline policy.
Disciplinary actions are The discipline actions were recorded and Data point 2: Management interview:
recorded, consistent with signed by the employee himself/herself. Mr. Hui Zhao, HR supervisor, states that the discipline actions are in compliance with the discipline policy.
A5.3 Conformance
the procedures and reviewed And the discipline actions were reviewed
by management by the HR Dept. Data point 3: Worker interview:
67 interviewed workers state that they know the discipline policy and no discipline action has been implemented for them.
A6) Non-Discrimination
Participants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination based on race, color, age, gender, sexual orientation, ethnicity, disability, pregnancy, religion, political affiliation, union membership or
marital status in hiring and employment practices such as promotions, rewards, and access to training. In addition, workers or potential workers should not be subjected to medical tests that could be used in a discriminatory way.
No case of discrimination is found.
No evidence of
discrimination based on
No discrimination policy is stated in TPV employee manual: 15 version, release on April 2014,Labor and Ethics Manual, TPVFQ-LEM-01,08 Version. TPV internal website, www.
grounds of race, color,
baidu.com were checked.
age, gender, sexual
orientation, ethnicity, No any kinds of discrimination was found
A6.1 Conformance Data point 3: Management interview:
disability, pregnancy, during this audit
Mr. Hui Zhao, HR HR supervisor, stated that there is anti-discrimination policy. He states that discrimination is prohibited in the company.
religion, political
affiliation, union
membership or marital
67 interviewed workers state that no discrimination is found in the company.
status exists.

No discrimination policy is stated in TPV employee manual: 15 version, release on April 2014,Labor and Ethics Manual, TPVFQ-LEM-01,08 Version.

Mr. Hui Zhao, HR supervisor, states that there is an anti-discrimination policy. She states that discrimination is prohibited in the company.
policies that ban A written discrimination and harassment
A6.2 Conformance
discrimination and ban policy is established in the company.
harassment are in place
67 interviewed workers state that no discrimination is found in the company.
A7) Freedom of Association

Open communication and direct engagement between workers and management are the most effective ways to resolve workplace and compensation issues. The rights of workers to associate freely, join or not join labor unions, seek representation, and join workers councils in accordance with
local laws shall be respected. Workers shall be able to openly communicate and share grievances with management regarding working conditions and management practices without fear of reprisal, intimidation or harassment.

The right of freedom association is stated in <TPV employee manual>, 15 version, release on April 2014,Labor and <Ethics Manual>, TPVFQ-LEM-01,08 Version,

Legal rights of workers for Mr. Hui Zhao, HR supervisor, stated that workers have the right to elect worker representative, and the facility respects the worker's right.
There was a organization in the company.
A7.1 free association are Conformance
respected Data point 3: Worker Interview:
67 interviewed workers state that they know the right of freedom association.
Freedom association policy is stated in <TPV employee manual>, 15 version, release on April 2014,Labor and <Ethics Manual>, TPVFQ-LEM-01,08 Version. The policy has
communicated to workers.
There was TU organization in the company.
Adequate and effective About 7% employees joined the company.
communication/training to
Mr. Hui Zhao, HR supervisor, stated that the freedom of association policy has been communicated to the workers when they join the facility.
A7.2 workers on their legal Conformance
rights related to freedom .
Data point 3: Worker Interview;
of association is provided
67 interviewed workers stated that the freedom of association policy has been communicated to them.

No evidence of Association "boycotting"

Freedom association policy is stated in <TPV employee manual>, 15 version, release on April 2014,Labor and <Ethics Manual>, TPVFQ-LEM-01,08 Version.
No evidence of unequal
treatment between unionized
No evidence of unequal treatment between Data point 3: Management interview:
A7.3 or worker representatives Conformance
worker representatives and other workers Mr. Hui Zhao, HR supervisor, stated that no discrimination on freedom of association is raised for worker representatives.
and non-unionized workers
exists
67 interviewed workers state that no discrimination on freedom of association is raised for worker representatives.

No evidence of control or Data point 2: Management interview:

attempt to control of labor Mr. Hui Zhao, HR supervisor, stated that no labor organization is established at the company.
The company did not attempt to control any
A7.4 organizations by any means Conformance
forms of labor organizations.
(incentives or Data point 3: Worker interview:
intimidation) exists. 67 interviewed workers state no labor organization is in the company.

Freedom association policy is stated in <TPV employee manual>, 15 version, release on April 2014,Labor and <Ethics Manual>, TPVFQ-LEM-01,08 Version. .
Workers are informed when Data point 2: Management interview:

being employed if they are Mr. Hui Zhao, HR supervisor, stated that there are 18 worker representatives elected by workers, and no other worker representative form and union existed.
The employees do not automatically enroll
A7.5 automatically enrolled in Conformance
in any forms of employee organizations.
union or other forms of Data point 3: Worker interview:
worker representation 67 interviewed workers state that they know the right of freedom association.
Data point 2: Management review

Mr. Hui Zhao, HR supervisor, stated that 18 worker representatives are democratically elected by workers.
Worker representatives are There was no worker representative in the
A7.6 Conformance
democratically elected company.
67 interviewed workers stated that worker representatives are democratically elected.
Health & Safety
B1) Occupational Safety

Worker exposure to potential safety hazards (e.g., electrical and other energy sources, fire, vehicles, and fall hazards) are to be controlled through proper design, engineering and administrative controls, preventative maintenance and safe work procedures (including lockout/tag out),
and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are to be provided with appropriate, well maintained, personal protective equipment. Workers shall not be disciplined for raising safety concerns.
Data point 1:
List of special equipment indicate that the use certificates, expiry dates of permits of all special equipment were tracked to ensure permits and licenses are up to date
at all times.
Periodical inspection reports for 36 elevators (last on 28/04/2016), 42 safety valve (last on 17/11/2015), 27 pressure valve(last on 18/02/2016) 63 forlifts (last
There are special equipment were
All required permits, inspection on 14/03/2016) and 18 air tanks (last on 29/09/2015) were available, uasage registration qualification for air tanks, elevators and weights were available.
elevators, forklift and Pressure tank at
licenses and test reports inspection report for safety performance of lightning protection system:DQ0020160100100017, DQ0020160100100015,issue date: Jan 26, 2016
the facility. The facility has obtained
for occupational safety are drink water inspection report: SZ201605070, issue date: May 16, ,2016,including two dormitory and production area.
all required permits, licenses and test
B1.1 in place and a process is Conformance
reports for occupational safety. The
implemented to ensure Data point 2: Management Interview:
facility has established and implemented a
permits and licenses are up Management interview: Ms. Rui WANG / EHS supervisor, state that special equipment list was available, and expired date was showed in the list, and special equipment will
process to ensure that all the permits are
to date at all times be re-inspected.
up to date.
Legal references: N/A
Supporting evidence reference(s): Nil
Data point 1: Onsite observation:

Workers operate machines safely. Chemical warehouses are air conditioned, installed gas alarm, auto dry foam spraying system and separated from main buildings. Electrical
generators and electricity distribution station are in separate rooms.
Worker exposure to
potential safety hazards The facility has established one procedure
Hazard identification and risk identification form checked to show that safety hazards were identified and control actions were available. Operation qualifications for 96
(e.g. electrical and other to identify, evaluate and control worker
forklift workers, 6 chemical worker and 3 elevtor worker are checked.
energy sources, fire, exposure to safety hazards for each
B1.2 vehicles, and fall hazards) Conformance workshop and each action in the facility,
are controlled through and all the identified hazards are
Ms. Rui WANG / EHS supervisor, states that the risk of energy hazards were identified in the risk identification and evaluation sheet. The control method is determined.
proper design, engineering suitably controlled to prevent worker
and administrative controls exposure from these safety hazards.
and safe work procedures
67 out of 67 workers interviewed state that the safety guidance had been trained to them.

Workers wear PPE correctly where it is required, such as safety cap for forklift workers and safety shoes etc. PPE signs are posted at relevant position. Relevant workers
wear PPE well.
The document of "Personal Protective Data point 2: Document Review:

Appropriate Personal Equipment Management Instruction" is Personal Protective Equipment Control Procedure (TPVFQ-SHEP-08, version:01, issue date:Jul 17, 2009) is available. The document of "Personal Protective Equipment Management
Protective Equipment (PPE) established to suitably define personal Instruction" is established to suitably define personal protective equipment for every position.
is consistently and protective equipment for every position,
B1.3 Conformance
correctly used where and workers wear personal protective Data point 3: Management Interview:
required to control safety equipment (PPE) correctly where it is Ms. Rui WANG / EHS supervisor, states that PPE was provided according to the relevant occupational health hazard and was defined in relevant instruction.
hazards and worker exposure required to control safety hazards and
workers exposure. Data point 4: Worker Interview:
67 out of 67 interviewed workers are required to wear PPEs state that they are provided earplugs. They have been trained how to use PPE during orientation training.

B2) Emergency Preparedness

Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire
detection and suppression equipment, adequate exit facilities and recovery plans.

All required permits,
Construction engineering fire verification comments (2009-0205 for production building), (2014-0007 for new warehouse),(350000WYS120003889 for dormitory),
licenses and
(350000WYS110016748 for canteen) by Fuqing Fire Brigrade were available.
inspection/testing reports All required permits, licenses and test
for fire safety and reports for emergency preparedness are in
B2.1 emergency preparedness are Conformance place.
Ms. Rui WANG / EHS supervisor, states that he is responsible for maintaining the permit and he has a process of tracking new building constructions to ensure permits and
in place and a process is
licenses are available, and he knows that this is one legal requirements of China Fire Law.
implemented to ensure
permits and licenses are up
to date at all times
Data point 1: Site observation: Automatic sprinklers are installed at the workshops. The alarm system are available in the company. The fire extinguishers were montly
inspected by the company.
Data point 2: Document Review: Construction engineering fire verification comments (2009-0205 for production building), (2014-0007 for new warehouse),(350000WYS120003889
for dormitory), (350000WYS110016748 for canteen) by Fuqing Fire Brigrade were available. Fire system checking forms (monthly) to show that fire system was monthly
Adequate and effective fire maintained by professional company (Zhejiang Yongan Fire Co., Ltd. FuJian branch).
The fire detection, alarm and supperssion
detection, alarm and
B2.2 Conformance systems are adequate, and monthly
suppression systems are in Data point 3: Management Interview: Ms. Rui WANG / EHS supervisor, states that the fire facilities were checked monthly by the company and by one professional company.
maintained to ensure its effectiveness.
place
Data point 4: Worker interview: 67 workers out 67 interviewed can state where the fire extinguishers and fire hydrants are in place.

Data point 1: Document Review: Emergency preparedness and Response Procedure (TPVFQ-SHEP-18/06) indicates that the facility has identified all potential emergencies, such
as fire, injury, earthquake, flood, posioning, trafic incident, etc. Corresponding response programs are established.
All potential emergencies
Data point 2: Site Observation: The fire escape maps are posted in the workshops. The emergency exits are indicated and emergency lights are available.
that could affect the site
The emergencies which could affect the
are identified and
site are identified and assessed, and Data point 3: Document Review: Fire Drill Records and photos shows that it is implemented in production area on 1/07/2016(lightday), 13/07/2016(night) and in dormitory area
assessed, and adequate and
B2.3 Conformance adequate emergency preparedness and on 17/12/2015(night).
effective emergency
response programs are established.
preparedness and response
Data point 4: Management interview: Ms. Rui WANG / EHS supervisor, states that the facility would conduct emergency drill for production area once per year.
programs (plans/procedures)
are established
Data point 1: Observation: All emergency exit, aisles and stairways were adequate, readily accessible and properly maintained.
Data point 2: Document review: Construction engineering fire verification comments (2009-0205 for production building), (2014-0007 for new warehouse),(350000WYS120003889
Effective emergency exit
for dormitory), (350000WYS110016748 for canteen) by Fuqing Fire Brigrade were available. Fire system checking forms (monthly) to show that fire system was monthly
access, exits, and exit
All emergency exit, aisles and stairways maintained by professional company (Zhejiang Yongan Fire Co., Ltd. FuJian branch).
discharge are adequate in
B2.4 Conformance were adequate, readily accessible and
number and location,
properly maintained. Data point 3: Management interview: Ms. Rui WANG / EHS supervisor, states that emergency exit, aisle and stairways passed the verification of loca fire bureau, and suitbaly
readily accessible, and
maintained.
properly maintained
Data point 1: Document review: Education training attendance forms (periodical training for workers, last on 24/12/2015) and training contents for new workers were
All employees are provided availabele.
with appropriate All workers are trained on fire and other
training/communication on emergencies as well as the corresponding Data point 2: Management interview: Ms. Rui WANG / EHS supervisor, states that the fire safety training had implemented to all employees, and fire dirll training was
fire and other emergencies, preparedness and response plans/procedures conducted to all workers at least once a year.
B2.5 Conformance
as well as the during orientation training and are re-
corresponding preparedness trained according to annual training plan. Data point 3: Worker interview: 67 out of 67 interviewed workers state that the training had implemented.
and response All workers attended fire drill.
plans/procedures Legal references: N/A

Fire Drill Records and photos show that it is implemented in production area on 1/07/2016(lightday), 13/07/2016(night).
Chemical spill drill record (last on Apr 20, 2016).
Adequate and effective fire Data point 2: Management interview:

and other emergency Ms. Rui WANG / EHS supervisor. , states that fire drill is annually provided to every workers and the last fire drill was implemented on Jul 13, 2016. She states that the
The fire drill were implemented in
evacuation and response problem had improved in the last drill, such as emergency evacuation time improving.
B2.6 Conformance Production area and Dormitory area on Jun
drills are conducted with
25, 2015. And the records were maintained.
all employees, and records Data point 3: Worker interview:
are maintained 67 out of 67 workers interviewed workers state that they attended the fire drill.

Data point 1: Document review: Emergency reponse organization chart for internal emergency response personned was available. total: 78 first-Aider.
Data point 2: Management interview: Ms. Rui WANG / EHS supervisor, states that the internal emergency response team was established and relevant PPE was available, and all
the persons were trained by local fire brigade.
Designated emergency
response personnel are Designated emergency response personnel
Data point 3: Worker interview: 2 of 67 workers was emergency respnse personnel states that the training had been implemented.
B2.7 provided adequate and Conformance are provided adequate PPE and periodic
effective PPE and training training.
Data point 4: Site observation: Adequate PPE for emergency repsonse personnel were placed at fire department, such as fire-prevetion clothes, respirators, light, etc.
on a regular basis
B3) Occupational Injury and Illness

Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions to: a) encourage worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and
implement corrective actions to eliminate their causes; and e) facilitate return of workers to work.
Data point 1: Document review: Occupational illness inspection summary report (on 11/04/2016) were available, and total 478 workers (related to noise, dust and chemical)
Occupational illness test is provided to
All required permits, were inspected on occupational illness body check,
workers at occupational-health-relevant
licenses and testing
positions, and the process to ensure
reports for occupational Data point 2: Management interview: Ms. Rui WANG / EHS supervisor, states that occupational inspection was needed for workers related to dust, noise and chemical, and was
permits and license to be up to date is
injury and illness are in conducted annually and before in-position.
B3.1 Conformance established in Occupational Health
place and a process is
Checking Implementation Instruction" and
implemented to ensure Data point 3: Worker interview: 2 of 67 workers was on occupational illess postion personnel states that the occupational illness body check had been implemented.
effectively implemented.
permits and licenses are up
to date at all times Legal references: N/A
Data point 1: Document review: Work-related injury insurrance control method (A01) ws established to define the requirements of investigations to determine root cause(s)
and implement corrective/preventive actions. Work-related injury list to show that 2 work-related injury was happened in 2012, 8 in 2013, 3 in 2014, 0 in 2015 and 1 in 2016
Investigations to determine till now. Incident investigation report (06/1/2016 sampled) showed that root cause investigation and corrective action was taken.
root cause(s) and implement The process for root cause investigation
corrective/preventive and corrective action taken for work- Data point 2: Management inteview: Ms. Rui WANG / EHS supervisor, can explain the process of work-related injury, and root cause and corrective action for work-related
B3.2 actions for work-related Conformance related injury was established, and no injury was needed.
injuries/illness in the work-related injury happened from the
past three years are establishment of the company. Data point 3: Worker interview: 67 out of 67 workers state that they had been provided injury insurance and they will be treated in compliance witht the legal requirement.
performed and documented
Data point 1: Document review: The first aiders list (total 78) was maintained. The training records for 78 first aiders are available. Medical facility operation license
(350181032711) was available for the infirmary, qualification for 1 nurses was available.
Data point 2: Management interview: Ms. Rui WANG / EHS supervisor, states that first aiders are arranged in differant dept., and one infirmary was available for all
A effective process and Trained first aiders are in place to workers.
adequate first aiders to provide medical treatment for injured or
B3.3 provide medical treatment Conformance ill workers, and one infirmary was placed Data point 3: Worker interview: 67 out of 67 interviewed workers know the first aider in the Dept. and the infirmary.
for injured or ill workers at dormitory area, and the doctors and
is in place nurses were qualified. Data point 4: One infirmary was placed at Productions area, and one first aid was available for every department.


The first aid boxs are available in each workshop and dormitory area.

Medical supplies recipients control instruction (Number: TPVXM-ADM-57, version: A01, issue date: Mar 29, 2012) indicates that the first aid kit control method is
determined. The medicine list is available in the boxes. The medicines in first aid kits are inspected weekly.
Adequate first aid kits to
provide medical treatment Adequate first aid kits are in place at Data point 3: Management interview:
B3.4 Conformance
for injured or ill workers the workshops of the company. Ms. Rui WANG, EHS supervisor, states that total 78 first aiders are trained at the facility. she also states that one local hospital is located 1-kilometer away from the
are in place facility for the workers who are in severe condition after checked by the infirmary.

67 out of 67 workers interviewed state where the first aid box in the workshop and know the procedure when they get sick.

B4) Industrial Hygiene

Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled. Engineering or administrative controls must be used to control overexposures. When hazards cannot be adequately controlled by such means, worker health is to be protected by
appropriate personal protective equipment programs.

Air quality including noise report in 2016 are reviewed and indicate all sites concerning occupational disease meet the limitation of workshop hazards, latest air quality
including dust,XRF, VOC and noise (report No.: 2016-4, issued date: Apr 28,2016) by fujian Center for Health inspection and testing.and all the results comply with legal
All required permits, requirements.
licenses and testing Test on indoor air quality and indoors
reports for Industrial noise was conducted once a year and these Data point 2: Management interview:
B4.1 hygiene are in place and a Conformance requirements are defined in one document Ms. Rui WANG / EHS supervisor, states that indoors air quality and noise test was annually conducted for the company.
process is implemented to of monitoring and measurement control
ensure permits and licenses procedure and effectively implemented.
are up to date at all times Legal references: N/A
Data point 1: Onsite observation: Onsite observation shows that workers who exposures to chemical are provide ordour-prevention mask, and who expoures to nosie are provided
The risks related to worker exposure to
to earplug.
chemical, biological and physical agents
Some welding employees have no mask on MI Workshop. High voltage test employees has no insulant shoe, and the regular test record of insulant gloves has not been provided
are identified, and appropriate controls
on assembling workshop
for worker exposure to hazards related to
chemical, biological and physical agents
Appropriate controls for Data point 2: Management interview: Ms. Rui WANG / EHS supervisor, states that who exposures to chemical are provide ordour-prevention mask, and who expoures to nosie are
are effectively implemented by
worker exposures to provided to earplug..
safeguarding equipment installation and
B4.2 chemical, biological and Minor
PPE wearing.
physical agents are Data point 3: Worker interview: 6 of 67 interviewed workers, who worked at tin-oven position and pluging position, state that earplug and ordour-prevention mask had been
implemented provided to them by the company.
Some welding employees have no mask on MI
Workshop. High voltage test employees has
no insulant shoe, and the regular test
record of insulant gloves has not been
provided on assembling workshop
B5) Physically Demanding Work

Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled

All raw materials and finished products are moved by manual forklift or automatic forklift, the goods moving in the production process are counted on automatic machines, no
heavy work is found by the workers during on site visit.

The physically reminding works are identified at the hazard identification and risk identification form. The control methods are determined.
Worker exposure to the hazard of
Worker exposure to the physically demanding work is identified,
hazards of physically assessed and no any work is required high
Mr. Weihan HU EHS MR, states that the physically demining works are identified. And he could explain the control methods.
B5.1 demanding work is Conformance physically demanding in the facility.
identified, assessed and
controlled effectively
67 out of 67 interviewed workers state that they are trained on machine safety and they all know the important of machine safeguarding to their safety and how/when to use
emergency stop buttons.

B6) Machine Safeguarding

Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly maintained where machinery presents an injury hazard to workers.
Data point 1: Document review: Production machine list is available to show that no machine required license is available. EDX-702 exemption notice (2008-291) by Shanghai
All required permits, environment protection bureau on 28/07/2008 to show that the 3 X-ray equipments were not required license.
licenses and testing
reports for machinery are The facility doesn't use any machines that Data point 2: Management review: Ms. Rui WANG / EHS supervisor and Mr. Lock HUANG / vice manager of ISO office, could show that no production machine is reqired license,
B6.1 in place and a process is Conformance need permits, licenses and testing and the 3 X-ray test machines are not required license.
implemented to ensure reports.
permits and licenses are up Legal references: NA.
to date at all times Supporting evidence reference(s): Nil
Data point 1: Document review: Machine operation working instructions (for SMT machines, doard-cutting machine, packing machines, etc.) were available. Training recording
forms (last on 15/12/2015) to show that training on safety machine operation was suitably conducted.
Workers operate machinery safely. They can
Workers operate machinery Data point 2: Site observation:Workers safely operated machiens, and safeguarding equipment was suitbaly available.
proper use of machine safeguards and
safely, including proper
B6.2 Conformance emergency stop switches.
use of machine safeguards Data point 3: Worker interview: 10 of 67 interiviewed workers who use the machine state that they are trained for the safety guidance.
and emergency stop switches
Data point 1: Document review: Machine operation working instructions and Machine Maintenance Recording Form (for SMT machines, doard-cutting machine, packing machines,
etc.) were available.
The facility has established the machine
safeguarding program, and the machine Data point 2: Management interview: Ms. Rui WANG / EHS supervisor, can explain the operation safety guidances and maintenance period, and safeguarding equipment was covered
safeguard program is effectively in maintenance content.
B6.3 machine-safeguarding Conformance
implemented. All safeguarding equipment
program is implemented
are periodically maintained together with Data point 3: Worker interview: 10 of 67 interiviwed workers who use the machine state that they are trained for the safety guidance.
periodical maintenance of machines.
B7) Food, sanitation and housing

Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities. Worker dormitories provided by the Participant or a labor agent are to be maintained clean and safe, and provided with appropriate
emergency egress, hot water for bathing and showering, and adequate heat and ventilation and reasonable personal space along with reasonable entry and exit privileges.
All required health & Data point 1: Document review:

safety licenses, permits, Health certificates of the 102 food service workers (sample, certificate number: (2015)1301-06587, issue date: Oct 26, 2015, expiry date: Oct 25, 2016) indicate that the
registrations and operators at the canteens comply with the legal requirements. The canteen hygiene permit (2002350181203928) for the canteen was available. The expiration date is Jun 30,
certificates related to There is one canteen at the facility. 2016
food, sanitation and Required license for the canteen is
B7.1 Conformance
housing are in place and an available and up to date. All food workers Data point 2: Management interview:
adequate and effective are certified on health body check. Ms. Rui WANG / EHS supervisor, states that the all permits had obtained and up-to-date, explains that they are trained by local hygience bureau.
process is established to
ensure permits and licenses Legal references:N/A
are up-to-date at all times Supporting evidence reference(s):Nil
Dormitory are visited. They are clean, safe and well maintained in compliance with legal requirements. Hot water is provided to workers.

Dormitory checking forms (daily) indicate that the condition of dormitory areas is daily checked. Fire equipment checking sheets for fire equipment including fire alarm,
Dormitories are maintained well, clean and suppression show that the fire alarm and suppression system are checked monthly to ensure they are effective.
Dormitories are clean, safe
safe. Hot drinking water is provided for
and well maintained and
B7.2 Conformance workers. Dormitory is checked daily to Data point 3: Management interview:
meet international housing
ensure compliance with the legal Ms. Rui WANG / EHS supervisor, states that the dormitories are clean daily, and the dormitories were provided for workers, and the safety guard patrols dormitory daily.
standards
requirements.
58 of 67 interviewed workers who live in the dormitories state that the dormitories are clean and safety.

Data point 1:Site observation:

The canteens is clean and tidy, every canteen divides into dishes washing area, food preparation area, cooking area and delivering food area, the food is stored on shelves,
food kept covered , the required mask and cap is worn by the workers in the canteen.

Food sample work instruction indicate that every food shall maintain sample for 48 hours in special appliance and refrigerators, canteen attention of Employee manual
indicates the employee shall put the food appliance in proper place, no smoke and not into the food making place and make clean and tidy dining room. The canteen hygiene
permit (2002350181203928) for the canteen was available. The expiration date is Jun 30, 2016
Canteens (cafeterias) are Canteens are clean, safe and well
clean, well maintained, and maintained in compliance with legal
B7.3 Conformance Data point 3: Management interview:
managed in compliance with requirements.
Ms. Rui WANG / EHS supervisor, states that all raw materials are inspected before inputting the warehouse, food sample was retained, and canteen is clean, safe and well
local health regulations
maintained in compliance with legal requirements.

2 canteen workers confirm that the food sample was retained. 58 out of 58 interviewed workers state that the canteen is clean, safe and well maintained in compliance with
legal requirements.

Environment
C1) Environmental Permits and Reporting

All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and their operational and reporting requirements are to be followed.

Environmental construction project completion verification approval (number: 2014-51, Feb 17, 2014) indicate that the factory has obtained all legal required permits,
approvals, licenses and registrations.
The facility has obtained all the legally
The facility has obtained
required environment impact reports and
all the legally required Data point 2: Management interview:
approvals and discharge permits from local
C1.1 environmental permits, Conformance Ms. Rui WANG / EHS supervisor, states that the facility has obtained all legal required environmental permits, approvals including environmental impact report and approval,
governmental bureau, and all the legally
approvals, licenses and and he knows it's the requirements of China Environment Protection Law.
required environmental permits are
registrations
effective.
Supporting evidence reference(s): pollutant discharging license(2015-121, valid date: Aug 17, 2016)
Industrial Enterprise Waste Discharge Application Registration Records (Jan 14, 2015) indicate that the facility reports the status about waste water, hazardous waste and
noise to local environmental protection bureau.
The facility has reported the status of
Reporting to environmental Data point 2: Management interview
wastewater, air emission, hazardous waste
C1.2 authorities as required by Conformance Ms. Rui WANG / EHS supervisor, states that the facility reports the waste water and hazardous waste status once year, and the reporting is controlled by local environments.
and noise to local environmental
law is performed timely When the facility receives the reporting notice from local environment protection bureau, it submits a timely report. And he claims that no other reports to government
protection bureau once per year.
agents on environmental issues.

C2) Pollution Prevention and Resource Reduction

Waste of all types, including water and energy, are to be reduced or eliminated at the source or by practices such as modifying production, maintenance and facility processes, materials substitution, conservation, recycling and re-using materials.
Data point 1: Site observation

Environmental objectives are posted at the bulletins, and control actions for water usage, electricity usage and paper usage are available.

Established adequate and "2016 environmental objective and achievement management sheet (no document number, issued date: May 17, 2016. The objectives are tracked monthly to ensure that objectives
effective programs, are met.
including targets, to: a) The facility has established a program to
eliminate, reduce or control environmental objectives, which Data point 3: Management interview
C2.1 control pollution Conformance included the requirements to control Ms. Rui WANG / EHS supervisor, states that the facility implements updating environmental objectives, tracks monthly the status of the objectives' achievement, and the
(emissions, discharges, pollution and conserves resources. The environmental objectives will be revised if the process is off tracked during monthly tracking, and reports the status of environmental objective to top management once per
wastes) and b) conserve program is effectively implemented. year.
resources (energy, water,
materials) in place Data point 4: Worker interview
67 out of 67 interviewed workers state they know environmental objectives of water saving and electricity usage.

C3) Hazardous Substances

Chemical and other materials posing a hazard if released to the environment are to be identified and managed to ensure their safe handling, movement, storage, use, recycling or reuse and disposal.
Data point 1: On-site observation:

Chemical warehouse is separate room. MSDS is available and different chemicals are placed separately. Dangerous waste is collected in special dangerous-waste collection bin
and stored at dangerous waste rooms.

Hazard waste is transfered to Fujian Luzhou Environmental Technical Company which has the treatment licence from environmeantal bureau. The transfer contract is avialable.
The canteen waste is transfered to a farmer. The documented waiver is provided by the local environmental government.
Hazardous materials
including wastes are Data point 3: Document review;
properly categorized, Last hazardous waste transferring records shows that the waste PCB, Waste oil and waste organic solvent were tranfered to the waste treatment agent on Mar 28, 2016.
Control requirements of hazardous waste
labeled, handled, stored,
C3.1 Conformance and waste are defined and controlled in
transported and disposed Data point 4: Management interview:
compliance with the legal requirements.
using government-approved Ms. Rui WANG / EHS supervisor, states that the legal requirements of chemical storage, usage and transfer and hazardous waste collection, store and dispose are treated in
and/or licensed vendors as relevant control procedure. The documented waiver is provided by the local environmental government.
per local laws
2 out of 67 interviewed workers work related to chemicals and 1 out of 67 interviewed workers works with hazardous waste state that they are trained and know how the
chemical be classified, the storage and disposal requirement.
Legal references: Not applicable

Supporting evidence reference(s): None
Dangerous chemical operation qualification indicated that one workers on chemical management was trained.
Data point 2: Management review:

Ms. Rui WANG / EHS supervisor, states that training of chemical control requirements is provided to chemical-relevant workers by orientation and refreshing training, and
Workers who work with Chemical-relevant workers are annually
training on hazardous waste are provided to all workers by orientation training.
hazardous substances are trained on chemical control requirements.
C3.2 Conformance
provided adequate and Training on hazardous waste requirements
effective training is provided to all workers.
1 out of 1 interviewed workers work related to chemicals and 1 out of 1 interviewed workers works with hazardous waste, all of them state that they are trained and know how
the chemical and hazardous waste be classified, the storage and disposal requirement.

Hazardous waste disposal Data point 1: Document review:

supplier(s) have been Hazardous waste treatment vendor audit report is checked to show that the waste vender Fujian Luzhou environmental technology co., LTD. (license number: F0720039) was on-
assessed to verify that The hazardous waste treatment vendor is site audited on Dec 12, 2015.
waste is handled, stored 180-minute away from the facility, and on-
C3.3 and disposed of in Conformance site audit for the vendor was conducted to Data point 2: Management review:
accordance with local verify that waste is disposed in Ms. Rui WANG / EHS supervisor, states that the audit for hazardous waste vender was implemented on Jul 7, 2015.
regulations, permit accordance with the legal requirement.
conditions and contract Legal references: N/A
requirements Supporting evidence reference(s): Nil
C4) Wastewater and Solid Waste

Wastewater and solid waste generated from operations, industrial processes and sanitation facilities are to be characterized, monitored, controlled and treated as required prior to discharge or disposal.

All solid wastes in the production and living areas are collected and managed by different categories. For example, hazardous solid waste, normal recyclable waste and
unrecyclable waste are collected by different bins.

The solid waste is treated to Fuqing Pingxiang Renewable materials recycling Ltd(license number: 350181100061372), and hazardous waste was transferred to Fujian Luzhou
All solid wastes in the production and environmental technology co., LTD. (license number: F0720039). The transfer records in the past 3 years are checked.
Solid waste is managed and
dormitory areas are collected, managed by
disposed of in accordance
C4.1 Conformance different categories and treated by Data point 3: Management review:
with applicable legal
licensed vendors. The hazardous waste is Ms. Rui WANG / EHS supervisor, states the normal wastes are disposed by the local recycling company and the hazardous waste should be transported and disposed by qualified
requirements
collected by the qualified vendor. vendor. They know the legal requirements for waste classification for hazardous waste and normal waste, handling, labeling, storage, use, transportation and disposition.

1 out of 67 interviewed worker, responsible for solid collection, states that solid waste is collected in different category and placed at different area.

Data point 1: Document review: Monitoring and measurement operation procedure (TPVFQ-SHEP-19/03) indicates that monitoring for wastewater need be conducted once a year.
Monitoring report (CTPF16HJ027) for wastewater indicated that wastewater monitoring was conducted on 16/05/2016. The result showed that the effluent discharge could meet
the legal requirements.
Data point 2: Management review: Ms. rui WANG / EHS supervisor, states that all waste water is collected to wasterwater collection pool (whick was controlled by TPV
group) and discharged to local municipal treatment system, and wastewater discharge was yearly monitored, and last in May. 2016.
Effluent discharges
Just sanitary wastewater raised and Data point 3: Site observation; Just sanitary wastewater raised, and wastewater was discharged to wastewater collection pool and then discharged to municipal treatment
(industrial/process
discharged to municipal treatment system, system, and no storm water used.
wastewater, sewage and
C4.2 Conformance and wastewater discharge is monitored, and
storm water) meet the
the results meet the discharge limits in Legal references: N/A
discharge limits for
accordance with legal requirements. Supporting evidence reference(s): Nil
regulated constituents
1 out of 1 interviewed worker, responsible for operation of sanitary sewage station, states that he has been trained and has good knowledge on sanitary sewage station
operation.

C5) Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated from operations are to be characterized, monitored, controlled and treated as required prior to discharge.
Data point 1: Document review: Monitoring and measurement operation procedure (TPVFQ-SHEP-19/03) indicates that monitoring for air emission need be conducted once a year.
Monitoring report (CTPF16HJ027) for air emission from kitchen indicated that wastewater monitoring was conducted on 16/05/2016. The result showed that the effluent
discharge could meet the legal requirements.
There is just air emission from the
kitchen and air emission from production
Air emissions meet the Data point 2: Management review: Ms. Rui WANg / EHS supervisor, states that air emission from kitchen and production workshop is monitoring yearly, and the kitchen was
lines on soldering raised, and air
C5.1 discharge limits for Conformance controlled and last in May. 2016.
emission is monitored on 16 May. 2016 by
regulated constituents
its headquarter, and the results meet the
Data point 3: Site observation: Air emission from kitchen and production lines on soldering was available.
discharge limits for legal requirements.
Data point 1: Document review: Monitoring and measurement operation procedure (TPVFQ-SHEP-19/03) indicates that monitoring for boundary noise need be conducted once a
year. Monitoring report ((CTPF16HJ027) for boundary noise indicated that boundary noise was conducted on 16/05/2016. The result showed that the effluent discharge could
meet the legal requirements.
Environmental noise levels Boundary noise is annually monitored, and
C5.2 are within regulatory Conformance the results meet the legal requirements in
Data point 2: Management review: Ms. Rui WANG / EHS supervisor, states that boundary noise is monitoring yearly, and last in May. 2016.
limits the company.
C6) Product Content Restrictions

Participants are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances, including labeling for recycling and disposal.
An effective program is in
place to meet legal and
An effective management system is Data point 1: Document review: QC080000 certificate (by SGS, valid date:16/09/2018 ) indicates that the control of environment-controlled substance was sytematically
customer requirements for
established at the facility to ensure conducted. Environment-controlled substance standard (RDEMS-01/A09.0) indicates that the control requirements on hazardous substance in product is established. Environment-
product content as a formal
their product content complies with protection agreements (from all suppliers, HeLian sampled) indicate Environment Protection Warranty signed by all suppliers indicates that all suppliers promise to provide
part of their procurement
European Directive 2011/65/EU (RoHS materials compliance with RoHS requirements for every parts, and test reports indicate that all parts are tested on hazarouds substance content by suppliers.
and manufacturing processes
C6.1 Conformance Directive), 2006/96/EC (WEEE Directive),
including effective
and REACH (No 1907/2006) to meet customer Data point 2: Management review: Ms. Jianfang LEI / SQA supervisor, states that the control instruction for hazardous substance in product is implemented in the facility.
processes, procedures and
requirements. The management system is
records are in place to
effectively implemented and the system is Legal references: N/A
measure or document the
certified on customer requirements. Supporting evidence reference(s): Nil
chemical composition of
products
Effective processes and Data point 1: Document review: Environment-controlled substance standard (RDEMS-01/A09.0) indicates that the control requirements on hazardous substance in product
procedures are in place to Environment-protection agreements (from all suppliers, HeLian sampled) indicate test reports indicate that all parts are tested on hazarouds substance content by
request and obtain relevant suppliers.Component HSF test data sheet indicates that in-coming parts were periodically tested by XRF equipment.
The procedures in place to request and
chemical composition
obtain chemical composition information
C6.2 information from their Conformance Data point 2: Management review: Ms. Jianfang LEI / SQA supervisor, states that every parts is provided test report on hazardous substance content by suppliers, and in-
from the suppliers are established and
suppliers, including coming parts is tested by XRF equipment.
effectively implemented.
certificates and analytical
reports if required by law Legal references: N/A
or customers Supporting evidence reference(s): Nil
Ethics
D1) Business Integrity

The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero tolerance policy to prohibit any and all forms of bribery, corruption, extortion and embezzlement (covering promising, offering, giving or accepting any bribes). All business
dealings should be transparently performed and accurately reflected on Participants business books and records. Monitoring and enforcement procedures shall be implemented to ensure compliance with anti-corruption laws.
Data point 1:
No identified risk that
The policy was defined in the <Labor and Ethics Management Manual>, TPVFQ-LEM-01, Ver 04, issued on DEC.12, 2012. It states that the company supports and protects the
Employees/Workers who
employee who refuses to bribery or other against the business code. The revenge is prohibited.
refuse to participate in
bribery, facilitation
No employees are found they are punished Data point 2: Management interview:
payments or who have
due to employees/workers refuse to Mr. Hui Zhao, HR supervisor, stated that employees will not be punished due to employees/workers refuse to participate in bribery or declared conflicts of interest, even
declared conflicts of
D1.1 Conformance participate in bribery, facilitation though loss of business. The policy is approved by GM.
interest do not suffer
payments or who have declared conflicts of
demotion, penalty or other
interest. Data point 3: Worker interview:
adverse consequences even
67 interviewed workers stated that they will not be punished due to employees/workers refuse to participate in bribery, or declared conflicts of interest.
if this action may result
in the enterprise losing
business
D2) No Improper Advantage

Bribes or other means of obtaining undue or improper advantage are not to be offered or accepted.
No identified risk of
gifts, hospitality or
promises to or from
suppliers and customers
The gifts policy is stated in TPV employee manual that the cost is RMB 1500 for gifts and the frequency is at most twice each year.
which are excessive in cost
and frequency which may
compromise the principles The company had defined the limit on the
Mr. Hui Zhao, HR supervisor, stated that there is formal policy that the cost is RMB 1500 for gifts for gifts. And the frequency is at most two time each year.
of fair competition or to amount/frequency of gifts
D2.1 Conformance
influence the course of the
business or governmental
67 interviewed workers stated that they know the gift policy.
decision-making process.
Appropriate investigations
Legal references: not applicable.
and sanctions occur when if
Supporting evidence reference(s): none.
there is an alleged
violation per written gift-
policy and procedures
D3) Disclosure of Information

Information regarding business activities, structure, financial situation and performance is to be disclosed in accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in the supply chain is
unacceptable.

The policy was defined in the <Labor and Ethics Management Manual>, TPVFQ-LEM-01, Ver 04, issued on DEC.12, 2012. . The approval authority form is available.
The annually finance was audited by the 3rd accounting firm, the audit report (2016)T-023
The company reports Annual financial
misreporting, record
D3.1 Conformance report in accordance with local Data point 2: Document Review:
falsification, or
regulations. 2015 annual Financial report is released.
misrepresentation
Legal references: Not applicable.
D4) Intellectual Property

Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property rights.

Intellectural property control procedure states that the intellectrual property control requirements. And the agreement was signed by relevant worker
Intellectual Property or
Mr. Hui Zhao, HR supervisor, stated that the intellectrual property control procedure is established, and relevant workers/employees sign confidential agreement.
business information loss The procedure is established to protect
D4.1 or unauthorized disclosure Conformance intellectual property (their own and of
(the Auditees own and their customers) in the company.
67 interviewed workers stated that they have trained about intellectrual property control procedure.
that of their
customers/suppliers)
D5) Fair Business, Advertising and Competition

Standards of fair business, advertising and competition are to be upheld. Appropriate means to safeguard customer information must be available.
The policy was defined in the <Labor and Ethics Management Manual>, TPVFQ-LEM-01, Ver 04.
The company has established a procedure to
communicating inaccurate Data point 2: Management interview:
D5.1 Conformance ensure fair Business, Advertising and
company information to the Mr. Hui Zhao, HR supervisor, stated how the procedure implemented in HR Dept. The recruitment policy had trained to the labor service agent.
Competition
public

The policy was defined in the <Labor and Ethics Management Manual>, TPVFQ-LEM-01, Ver 04.

Mr. Hui Zhao, HR supervisor, stated how the procedure implemented. The company has provided the hotline telephone number/suggestion box to employees
A written procedure on prohibiting
D5.2 Conformance collusion is established. No collusion is
collusion Data point 3: Worker interview:
found in the facility.
67 interviewed workers reported that they know the means of collusion. They also know the hotline number.
D6) Protection of Identity

Programs that ensure the confidentiality and protection of supplier and employee whistleblowers are to be maintained.
Data point 1: Site observation: The suggestion boxes were placed in the workshop.
Data point 2: Document review: Informant identity secret rules was defined in the <Labor and Ethics Management Manual>, TPVFQ-LEM-01, Ver 04, issued on DEC.12, 2012..
A way to confidentially The confidentially report way was
report suspected ethical available to workers and employee of
Mr. Hui Zhao, HR supervisor, can explain how the procedure implemented. The company provided the the hotline and GM email address to the suppliers.
D6.1 misconduct is available to Conformance suppliers
workers and employee of
suppliers
67 interviewed workers stated that they knew the complain channel.

D9) Responsible Sourcing of Minerals

Participants shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture does not directly or indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic of the Congo
or an adjoining country. Participants shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures available to customers upon customer request.
The related policy was defined in employee manual, it stated the employee will be protected to report the suspected ethical misconduct.
The personal information was not Data point 2: Management interview:

No identified risk of disclosured. Mr. Hui Zhao, HR supervisor, can explain that the policy of protection the personal information.
D7.1 unauthorized disclosure of Conformance
personal information Data point 3: Worker interview:
67 interviewed workers reported that they had trained about policy of protection the personal information.

Supporting evidence reference(s): none
D7) Privacy
We are committed to protecting the reasonable privacy expectations of personal information of everyone we do business with, including suppliers, customers, consumers and employees. Comply with privacy and information security laws and regulatory requirements when personal information is
collected, stored, processed, transmitted, and shared.

Labour& Ethics manual states that no retaliation is acceptable.

No retaliation was found in the company.
Mr. Hui Zhao, HR supervisor, can explain HR should handle any complaints about retaliation.
D8.1 Conformance
retaliation
67 workers stated that they know that grievance channel. No retaliation issue is found in the company.

Supporting evidence reference(s): none
D8) Non-Retaliation
Participants should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.
A policy to reasonably
assure that purchasing of
the 3TG minerals does not
"No conflict mineral commitment" was signed by all suppliers. It stated that conflict minerals from these serious-human-rights Democratic Republic of Congo or surrounding
directly or indirectly
The policy has been established to avoid countries are forbidden to be purchased.
finance armed groups that
knowingly purchasing of the 3TG minerals The CFSI CMRT sheet of 'Guanhao' was sample checked.
are perpetrators of serious
that directly or indirectly finance armed
human rights abuses in the
groups that are perpetrators of serious Data point 2: Management review:
Democratic Republic of
human rights abuses in the Democratic Ms. Hong Wei, Purchasing supervisor, states that all suppliers must sign EICC agreement. No conflict mineral commitment need to be signed.
D9.1 Congo or surrounding Conformance
Republic of Congo or surrounding
countries with an effective
countries. Data point 3: Worker interview:
procedures to establish and
Purchasing staff states that he was trained on the requirements of non-usage conflict minerals, and all suppliers must sign commitment.
monitor responsible
sourcing of minerals and
Legal references: Not applicable
capable of making the due-
Supporting evidence reference(s): None
diligence measures
available upon request from
customers
Management Systems
Does the facility have
credible, accredited third-
party certified (valid)
management systems for:
The company has third-party certified
A) Labor (e.g. SA8000)
E0 Not rated management system for ISO9001, ISO14001, See general info tab for certifcate details
B) Health & Safety (e.g.
OHSAS18001 and QC080000.
OHSAS18001)
C) Environment (e.g.
ISO14001)
D) Ethics
E1) Company Commitment

Corporate social and environmental responsibility policy statements affirming Participants commitment to compliance and continual improvement, endorsed by executive management.

Social accountability and ethic management manual (number: TPVFQ-LEM-01, version: 04, issue date: Dec 12, 2012) indicates that top management shall review and evaluate
labor & ethics management system for suitability, adequacy and effectiveness once a year, the last management review of labor and ethics was on Feb 26, 2016.
policies/Code(s) that are
The EICC policy is established and Mr. Lock HUANG - vice manager of ISO office, states that the last management review of labor and ethics was on Feb 26, 2016.
endorsed by executive
E1.1 Conformance communicates to all workers.
management, covering: A)
Labor B) Health & Safety C)
67 workers out of 67 interviewed stated that the policy about no retaliation has been communicated to them.
Environment and D) Ethics
E2) Management Accountability and Responsibility

The Participant clearly identifies company representative[s] responsible for ensuring implementation of the management systems and associated programs. Senior management reviews the status of the management system on a regular basis.
Responsibilities and Data point 1: Document review:

authorities are adequately Social accountability and ethic management manual (number: TPVFQ-LEM-01, version: 04, issue date: Dec 12, 2012) indicates that responsibilities for labor & ethics are
and effectively defined and defined, and Mr. PW CHEN / director, is appointed as the EICC management representative.
assigned for all
employees/workers (senior Responsibilities for all employees for Data point 2: Management interview:
managers to workers) for implementation of labor & ethics Mr. Lock HUANG - vice manager of ISO office claims that the responsibility of EICC is defined, and management could state their responsibility of EICC.
E2.1 implementation of Conformance management systems are defined in the
management systems, and for document of "EICC Implementation Committee Data point 3: Worker interview:
compliance with laws, Organization Chart and Responsibilities". 67 out of 67 interviewed workers could state their responsibility of EICC.
regulations and codes
pertaining to: A) Labor B) Legal references: N/A
Health & Safety C) Supporting evidence reference(s): Nil
EICC Management Review Procedure indicates that top management shall review and evaluate labor & ethics management system for suitability, adequacy and effectiveness once a
year. The last management review of labor and ethics was on Feb 26, 2016.
management review and
Top management reviews and evaluates labor
continuous improvement
& ethics management system for Data point 2: Management interview:
process for A) Labor, B)
E2.2 Conformance suitability, adequacy and effectiveness Mr. Lock HUANG - vice manager of ISO office, states that the output from the management review is effective and acceptable.
Health & Safety, C)
once a year, the last management review of
labor and ethics was on Feb 26, 2016. Legal references: N/A
performance and management
systems is established
E3) Legal and Customer Requirements

A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.

Data point 1: Document review: Law regulation and other requirements identification and update procedure (TPVFQ-SHEP-03/05) indicates that ifrntification and compliance
compliance process to
evaluation for legal requirements of labor & ethics is defined, and suitable law regulation and other requirements list indicates that legal requirements of labor and
monitor, identify,
ethics is available.
understand and ensure The identification and compliance
compliance with applicable evaluation for labor and ethics law
Data point 2: Management interview: Mr. Lock HUANG - vice manager of ISO office, shows identification of the law/regulation list on labor & ethics laws/ regulations is
E3.1 laws and regulations and Conformance regulation and other requirements is
suitbaly conducted.
customer requirements established, and the legal requirements on
pertaining to: A) Labor B) ethics are available.
Health & Safety C)
is established
E4) Risk Assessment and Risk Management

Process to identify the labor practice and ethics risks associated with Participants operations. Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified risks and ensure regulatory
compliance.
Data point 1: Document review: Labor & ethics management manual (TVE-LEM-01/04) to show that the requirements of risk assessment on labor & ethics were defined, Labor &
ethics risk assessmnet sheet, updated on Apr. 11, 2016, that risk identification, risk assessment and management is established that the risks of labor & ethics are
risk management process to
The risk management process to identify, identified and the control methods are determined.
identify, assess, and
assess and manage risks on labor & ethics
minimize/mitigate/control
E4.1 Conformance is established, and effectively Data point 2: Management interview: Mr. Lock HUANG - vice manager of ISO office, shows the risk lists were avaiable, and they could explain the cotrol methods of the risks
its risks in the areas of:
implemented. The control methods are control.
A) Labor B) Health & Safety
determined.
C) Environment and D)
Ethics is in place
E5) Improvement Objectives

Written performance objectives, targets and implementation plans to improve the Participants social performance, including a periodic assessment of Participants performance in achieving those objectives.
performance management
process for A) Labor, B)
Data point 1: Document review: Labor & ethics management manual (TVE-LEM-01/04) indicates that objectives and targets on labor & ethics should be established, "labor &
Health & Safety, C)
ethcis objectvies and management program forms" indicate that there are serval objectives on labor & ethics, The objectives are reviewed monthly.
Environment, and D) Ethics,
including setting
The procedure for objective and target on Data point 2: Management interview: Mr. Lock HUANG - vice manager of ISO office, shows the there are several objectives on labor & ethics and monthly statistic of labor
performance (improvement)
labor & ethics was established, and &ethics objectives.
E5.1 objectives and targets, Conformance
objectives on labor & ethics were
developing and implementing
available. Data point 3: Worker interview: 67 interviewed workers stated that the objectives on labor & ethics are basically communicated to them.
improvement plans,
regularly reviewing
progress toward achieving
targets, and making
appropriate adjustments if
needed is in place
E6) Training
Programs for training managers and workers to implement Participants policies, procedures and improvement objectives and to meet applicable legal and regulatory requirements.
Data point 1: Document review: Education training procedure (TPVFQ-QP-31/08) indicates that training requirements on labor & ethics are defined, Annual training plan is
established. Education training attendance sheets showed that training on labor & ethics was conduced on Mar. 29, 2016. The training on labor & ethics is performed to new
training process is
employees when they join the company. Training materials for new employees checked.
established for all
employees/workers on all An effective training process is
Data point 2: Manangement interview: Mr. Lock HUANG - vice manager of ISO office, can explain that the training on labor & ethics has covered new employees and exiting
policy/procedures/job established for all employees/workers on
E6.1 Conformance employees.
related aspects and labor & ethics code, and suitably
performance targets related implemented.
Data point 3: Worker interview: 67 interviewed workers stated that they are trained on labor & ethiucs when they joined the company
to A) Labor, B) Health &
Safety, C) Environment, and
D) Ethics
E7) Communication
Process for communicating clear and accurate information about Participants policies, practices, expectations and performance to workers, suppliers and customers.
An adequate and effective Data point 1: Document review: Consultation and communication control procedure (TPVFQ-SHEP-05/02) states the communication methods to workers, customer, supplier,
worker/employee, supplier employees for labor & ethics code are established.
and customer
The communication process is established
communication/reporting Data point 2: Management interview: Mr. Lock HUANG - vice manager of ISO office, can explain the communication process.
for customer, supplier, employees on labor
E7.1 process for A) Labor, B) Conformance
& ethics code, and effectively
Health & Safety, C) Data point 3: Worker interview: 67 interviewed workers stated that the company communicate them for labor & ethics issues by the meeting, bulletin board.
implemented.
Environment, and D) Ethics
policies, practices and Legal references: N/A
performance is established Supporting evidence reference(s): Nil
E8) Worker Feedback and Participation

Ongoing processes to assess employees understanding of and obtain feedback on practices and conditions covered by this Code and to foster continuous improvement.
Data point 1: Document review: TPV employee manual indicates that the way for workers complaint is established, such as suggestion box, hotline, HR service center, etc.
An adequate and effective Suggestions in suggestion box and the feedbacks are avaialble.
worker grievance/complaint
process whereby workers can Data point 2: Mangement interview: Mr. Lock HUANG - vice manager of ISO office, can explain the appeal process, and the the records of suggestion box. The feedbacks are
The adequate and effective worker
confidentially communicate available for the suggestions.
E8.1 Conformance complaint process is esblished in the
work-related grievances or
company.
complaints without fear of Data point 3: Worker interview: 67 interviewed workers stated that they can use the suggestion box, tell the manager for the appeal channel.
reprisal or intimidation is
established Legal references: N/A
Data point 1:Consultation and communication control procedure (TPVFQ-SHEP-05/02) indicates that the process of consulation and participation for workers is established.
worker
Data point 2: Management interview: Mr. Lock HUANG - vice manager of ISO office, states that the participation process is established in the company and encourage workers
consultation/participation
to participate EICC issues.
process whereby management The adequate and effective participation
E8.2 solicits and encourages Conformance process is esblished, and is suitably
Data point 3: Worker interview: 67 interviewed workers stated that they get EICC konwledge from training and employee manual, and they can participate EICC issue by
worker feedback and implemented.
suggestion box, hotline and HR service center, etc..
participation for
improvement via various
channels is in place
E9) Audits and Assessments

Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements related to social and environmental responsibility.

Audit process to
Data point 1: Document review: Internal audit control procedure (TPVFQ-PELMP-30/08) is available, and EICC internal audit reports were checked to show that internal audit
periodically assess
on labor & ethics was conducted in Apr. 2016. The internal audit report was available.
conformance with the EICC The audit process to periodically access
Code including compliance conformance with the labor & ethics code
E9.1 Conformance Data point 2: Mangement interview: Mr. Lock HUANG - vice manager of ISO office, states that internal EICC audit was annually conducted, last in Apr. 2015.
with applicable laws and is established, and suitbaly annually
regulations pertaining to: conducted..
A) Labor B) Health & Safety
C) Environment and D)
Ethics
E10) Corrective Action Process

Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.
Has established an adequate
and effective corrective
actions process to rectify Data point 1: Document review: Labor & ethics corrective and preventive action control procedure (TPVFQ-LEP-02/02) is available. Internal audit non-conformity reports to
and close Nonconformances show that corrective action for the non-conformities were taken.
with the EICC Code
including legal non- The corrective action procedure for Data point 3: Management interview: Mr. Lock HUANG - vice manager of ISO office, states that corrective and preventive action procedure on EICC nonconformity is established
E10.1 compliances identified via Conformance nonconformity on labor & ethics is and implemented.
internal or external established, and suitably conducted.
Audits, assessments, Legal references: not applicable.
inspections, investigations Supporting evidence reference(s): none.
and reviews, covering A)
Labor B) Health & Safety C)
Violations have been

corrected or are on track Data point 1: Document review: Survey internet website - www.baidu.com no monetary penalty found.
for correction, where
monetary penalties were Data point 2: Management interview: Mr. PW CHEN /director and Mr. Lock HUANG - vice manager of ISO office , - no monetary penalty on Labor & Ethics, EHS was happened from
assessed, or where formal No pending penalty or citation on EHS the establishment of the company.
E10.2 Conformance
corrective actions were Labor & Ethics was identified.
mandated by the issuing Legal references: Not applicable
government agency for A) Supporting evidence reference(s): None
Labor B) Health & Safety C) Note:
Environment D) Ethics
E11) Documentation and Records

Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with appropriate confidentiality to protect privacy.
Data point 1: Site observation: The documents are maintained well on-site. Personal files were kept at file room of HR deaprtment, and personal information could be
accessed only by the approval of HR manager.
documentation and records
Data point 2: Document review: Document and data control procedure (TPVFQ-QELMP-06/17) and Record control procedure (TPVFQ-QELMP-29/12) state that the procedures are
for A) Labor, B) Health &
The procedures for cotnrol of documents established in company to ensure adequate and effective documents and records for EICC management systems.
Safety, C) Environment, and
and records for labor & ethics management
E11.1 D) Ethics management Conformance
systems are adequately established, and Data point 3: Management interview: Mr. Lock HUANG - vice manager of ISO office, states that the company has maintained documents and records to ensure that the company can
systems are maintained and
are effectively implemented. meet the legal requirements and customer requirements.
appropriate levels of
access to ensure privacy
are implemented
E12) Supplier Responsibility

Process to communicate Code requirements to suppliers and to monitor supplier compliance to the Code.
Data point 1: Document review: "Supplier evaluation and audit procedure (TPVFQ-QP-08)" has states that communication way suppliers about EICC Code.
Data point 2: Document review: EICC agreement including purchase contracts signed with each vendor states that the EICC Code is included in the commitment and the
The EICC Code requirements The communication way to next tier commitment is signed by all suppliers.
have been communicated to suppliers about the Code is established,
E12.1 Conformance
the next tier major and the EICC code was communicated to all Data point 3: Management interview: Ms. Hong Wei / Purchase supervisor states that all suppliers have signed the EICC commitments.
suppliers next tier suppliers.
Supporting evidence reference(s):NA
Data point 1: Document review: "Supplier evaluation and audit procedure (TPVFQ-QP-08, 08Version)" indicates that on-site audit for main suppliers should be conducted once
a year. "Approved vendor list" indicates that there are 468 suppliers, and at present. "Supplier QSA system audit checklist" indicate that the requirements on EICC is
defined for supplier audit.
An effective process to
The company has established an audit
ensure that the next tier Data point 2: Management interview: Mr. Hong Wei / Purchase supervisor, states that the supplier evaluation on EICC is established, the audits were performed as the
E12.2 Conformance process to ensure the next tier suppliers
major suppliers implement anuanlly audit plan.
have implemented the EICC Code.
the Code is implemented
Leading Practices
Labor Provision NA
Good Practice:
Health & Safety Provision NA
Good Practice:
Environment Provision NA
Good Practice:
Ethics Provision NA
Good Practice:
Management System Provision NA
Good Practice:

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EICC CONFIDENTIAL - EICC Gap Analysiss ONLY

Auditee/Facility Name TPV Electronics (Fujian) Co., Ltd.

name email Phone

Issued by/service date of issue/start valid until/end date

Legal Nonconformance Risks

Totally, 1 major findings, 3 minor finding raised during the audit:

Governance and acceptance

Auditee Agreement Section

AUDIT SCORE DETAIL

General code and legal compliance

Tool reference Question Significance Description Supporting evidence

A1 Freely Chosen Employment

Data point 1: Document review

Data point 1: Document review:

Data point 1: Document review:

Data point 1: Site observation:

Data point 2: Document review:

A2) Child Labor Avoidance

Data point 1: Site observation:

Data point 2: Document review:

Data point 4: Workers interview:

Data point2: Document review:

Data point 1: Site observation:

Data point 2: Document review:

Data points: 1, Document review:

Data points: 2, Management interview:

A3) Working Hours

Data point 1: Document review

Data point 2: Management Interview

Data point 1: Document Review:

Data point 1: Document review:

Data point 2: Management Interview:

Data point 1: Documental Review:

Data point 3: Management Interview:

Data point 1: Documental Review:

Data point 2: Management Interview:

Data point 2: Management Interview:

Data point 1: Documental Review:

Data point 2: Management Interview:

Data point 1: Documental Review:

A5) Humane Treatment

Data point 2: Document review:

Data point 1: Document review:

Data point 1: Document review:

Data point 1: Document review:

Data point 2: Management interview:

A7) Freedom of Association

Data point 1: Document review:

Data point 2: Management interview:

Data point 1: Site observation:

Data point 2: Document review:

Data point 1: Document review:

No evidence of control or Data point 2: Management interview:

Data point 1: Document review:

Workers are informed when Data point 2: Management interview:

Data point 2: Management review

Health & Safety

B1) Occupational Safety

Data point 1: Onsite observation:

Legal references: N/A

The document of "Personal Protective Data point 2: Document Review:

Legal references: N/A

B2) Emergency Preparedness