Audit Company: Report Reference: Date

Supplier name: Fasa América Latina Participações Societárias S/A
Site country: Brazil

Site name: Farfri Indústria e Comércio Ltda.
Parent Company name (of the site): ---
SMETA Audit Type: 2–Pillar 4–Pillar
Date of Audit August 11 and 12, 2015
Audit Company: SGS SSC Report reference: 29673 Date: 11August2015 11December2015 1
Audit Company Name: Report Owner (payee):
SGS SSC Farfri Indústria e Comércio Ltda.
Sedex Company Reference: (only available on Sedex System) S000000087053
Sedex Site Reference: (only available on Sedex System) P000000192392
Audit Conducted By
Commercial Purchaser
NGO Retailer
Trade Union Brand Owner
Multi–stakeholder Combined Audit (select all that apply) SGS
Auditor Reference Number: (If applicable) --
SMETA Declaration
I declare that the audit underpinning the following report was conducted in accordance with SMETA best practice guidance
version 5.0. Any exceptions to this are recorded here:
(1) A SMETA audit was conducted which included some or all of Labour Standards, Health & Safety, Environment and
Business Ethics. The SMETA Best Practice Methodology v.5.0 Dec 2014 was applied. The scope of workers included
all types at the site e.g. direct employees, agency workers, workers employed by service providers and workers
provided by other contractors.
(2) The audit scope was against the following reference documents
2-Pillar SMETA Audit
- ETI Base Code
- SMETA Additions
o Management systems and code implementation,
o Entitlement to Work & Immigration,
o Sub-Contracting and Home working,
4-Pillar SMETA
o 2-Pillar requirements plus
o Additional Pillar assessment of Environment
o Additional Pillar assessment of Business Ethics
The Customer’s Supplier Code (Appendix 1)
(3) Where appropriate non-compliances were raised against the ETI code / SMETA Additions & local law and recorded as
non-compliances on both the audit report, CAPR and on Sedex.
(4) Any Non-Compliance against customer code shall not be uploaded to Sedex. However, in the CAPR these ‘Variances
in compliance between ETI code / SMETA Additions/ local law and customer code’ shall be noted in the observations
section of the CAPR.
Any exceptions to this must be recorded here (e.g. different sample size):
Auditor Name(s) (please list all including all interviewers): Ubiratan Schuch Pinto – Lead Auditor
Lead auditor: Ubiratan Schuch Pinto – Lead Auditor
Team auditor: Ubiratan Schuch Pinto – Lead Auditor
Interviewers: Ubiratan Schuch Pinto – Lead Auditor
Date: August 11 and 12, 2015
Non–Compliance Table
Area of Non–Conformity
(Only check box when there is a non–conformity, Record the number
and only in the box/es where the non–conformity of issues by line*:
Issue can be found)
(please click on the issue title to go direct to
the appropriate audit results by clause) Additional NC Obs GE
ETI Base Elements
Local Law
Code (i.e. not part
of ETI code )
0 Management systems and code 1

implementation
1 Employment Freely Chosen - - -
2 Freedom of Association - - -
3 Safety and Hygienic Conditions 8 1
4 Child Labour - - -
5 Wages and Benefits - - -
6 Working Hours 1
7 Discrimination - - -
8 Regular Employment - - -
8A Sub–Contracting and - - -
Homeworking
9 Harsh or Inhumane Treatment - - -
10A Entitlement to Work - - -
10B2 Environment 2–Pillar
10B4 Environment 4–Pillar 1 - -
10C Business Ethics
*Please note the table above records the total number of Non compliances (NC), Observations (Obs) and Good
Examples (GE). This gives the reviewer an indication of problem areas but does not detail severities of each issue
– Reviewers need to check audit results by clause.
Summary of Findings
Summary of main findings: (positive and negative)
(Please give a short summary of the main findings per clause)
Company has good facilities with good control of hygienic toilets, kitchen facilities and factories. All legal certificates
required for operation, such as environmental license and permit from the Fire Department, are available. Individually
interviewed six workers and four group interview: all the workers interviewed reported good working conditions and regular
working conditions (formal work registration, payment of labor and other benefits in accordance with the rules in relation to
formal work. payment of salaries and employee benefits - were sampled four workers in two different months and
researched vacation additional payments and others, and was found in normal according to Brazilian legislation The
company has code of ethics with the prohibition of discrimination practices,. corruption and other, and it is shown to the
workers during the time of integration. Environmental management was evidenced by waste management practices,
effluent treatment. Health management and occupational safety are being implemented, and that there was non-
compliance related to OSH management; important to note that the company has had several previous versions of this
event, related non-compliances identified. Regarding the payment of wages all interviewed workers receive on average
20% higher than the regional minimum wage.
Positives: relationship between workers and managers, practice of rainwater recovery, factory storage conditions.
Study points: health and safety management at work focusing on the legal requirements involved
Short summary: main findings per clause
Management systems and code implementation: Existing code of ethics and implemented.
Employment Freely Chosen.
Freedom of Association: There is no restriction on union activity.
Safety and Hygienic Conditions: necessary emphasis on health management and safety
Unconformities identified, numbers:
3.1 Not available assessment unifilar chapel compared to luminance parameters, sound pressure and exhaustion capacity
(Legal requirements NR-17, NR-15 and ACGIH )
3.2 Emergency exit doors allowing easy opening not from inside the establishment (Legal requirements NR-23 (2011)
3.3 Factory stairs/other units of Company do not have footers at odds with Legal requirements NR-12 (2015) Article 12.70
3.4 Not available Respiratory Protection Program in accordance with Instruction Legal requirements INSS 01 April 1994.
3.5 Not available. Hearing Conservation Program PCA in violation Annex I Schedule II Legal requirements NR-07 (2013)
3.6 Not available procedure for management of confined spaces, Legal requirements NR-33 (2012)
3.7 Not available procedure for labor management in height., Legal requirements NR-35 (2012
3.8 The organization has no storage facilities, disposal, containment or spill of hazardous chemicals for use in the
Chemical Analysis Laboratory, Legal requirements ILO Convention No. 170
Child Labour: All workers under 18 years of age, are learning under contract in accordance with Brazilian legislation.
Wages and Benefits: The wages paid are above the planned minimum; Additional such as overtime, night work and others
are being paid according to the Brazilian legislation and the impact of associated taxes.
Working Hours: Not identified excess overtime in a systemic way; there is a requirement of the organization it assessed
the adoption of preventive measures to avoid exceeding the nr overtime permitted by Brazilian law. The journey of hours
and the rest period is in accordance with Brazilian law.
Discrimination: no evidence during interviews with workers
Regular Employment: According to legislation
Sub-Contracting and Home working: The organization does not make outsourcing stages of its production process. Thus,
there is no evidence of outsourced process or work in homes of workers
Harsh or Inhumane Treatment: No evidence during interviews with workers
Entitlement to Work: The company has no foreign workers
Environment 4-Pillar: Evidenced environmental management of waste and effluents. There is a need for measuring
external noise.
Unconformities identified, numbers:
10B.1 Not available evidence external noise assessment in accordance Brazilian law CONAMA 01/90 NBR 10151: 2000
Business Ethics: The main suppliers are large companies, which already have implemented ethical codes.
Audit Details
Audit Details
A: Report #: # 29673
B: Time in and time out: (SMETA Best Practice August 11, 2015 Time in: 08:00 Time out: 17:00
Guidance/Measurement Criteria recommends 9–17 hrs. August 12, 2015 Time in: 08:00 Time out: 12:00
if any different state why in the SMETA declaration )
December 11, 2015 Time in: 08:00 Time out: 12:00
C: Number of Auditor Days Used: 1 auditor x 1,5 days = 1,5 MD
D: Audit type: Full Initial

Periodic
Follow–up Audit # 1
Partial Follow–Up
Partial Other – Define
E: Was the audit announced? Announced

Semi – announced: Window detail: weeks
Unannounced
F: Was the Sedex SAQ available for review? Yes

No
G: Any conflicting information SAQ/Pre-Audit Yes

Info to Audit findings? No
If Yes, please capture detail in appropriate audit by clause
H: Auditor name(s) and role(s): Ubiratan Schuch Pinto – Lead Auditor

Ubiratan Schuch Pinto – Lead Auditor
I: Report written by: Ubiratan Schuch Pinto – Lead Auditor
J: Report reviewed by: Elaine C. Perocco Dias
K: Report issue date: August 20, 2015
L: Supplier name: Fasa América Latina Participações Societárias S/A
M: Site name: Farfri Indústria e Comércio Ltda.
N: Site country: Brazil
O: Site contact and job title: Fabricio Domeneck Quality Assistant
P: Site address: Estrada RST453 km 81,4 São Luiz de Castro Boa Vista do Sul RS
Site phone: + 55 54 3435 6400
Site fax: --
Site e–mail: fabricio.d@faros.ind.br
Q: Applicable business and other legally Environmental permit FEPAM, LO 04931/2015-DL issued
required licence: for example, business license Fire permit PPCI 1471/1, average risk, valid until June 2016
no, and liability insurance Fuel station permit by ANP Brazilian Oil Agency valid until
November2015
R: Products/Activities at site; example: garment Flour viscera and bird feathers

manufacture/electrical/ toy/grower Oil from chicken birds
S: Audit results reviewed with site Yes

management?
T: Who signed and agreed CAPR Simone Laste Manager
U: Did the person who signed CAPR have yes

authority to implement changes?
V: Present at closing meeting (Please state Simone Laste Manager

name and position, including any workers/ union Fabricio Domeneck Quality Assistant
reps/worker reps): Freddy Kaufmann Engineer
W: What form of worker representation /union Union (name)

is there on site? Worker Committee
Other (specify)
None - There are no worker representation in plant
X: Are any workers covered by CBA Yes

Collective Bargaining Agreement No
Y: Previous audit date: August 11 and 12, 2015
Z: Previous audit type: SMETA 2–pillar SMETA 4–pillar Other
Full Initial
Periodic
Full Follow–Up Audit
Partial Follow–Up
Partial Other*
*If other, please define:
Audit Scope/Actual Results
Criteria Local Law Actual at the Site Is this part
(Please state legal (Record site results against the law) of a
requirement) Collective
Bargaining
Agreement?
A: Standard/Contracted work hours: Legal maximum: Factory area Yes

(Maximum legal and actual required working Brazilian Labor 36 hours per month No
hours excluding overtime, please state if possible Law (CLT)
per day, week and month) Article 59
B: Legal Overtime hours: Legal maximum: 2 hours per day Yes

(Maximum legal and actual overtime hours, Brazilian Labor No
please state if possible per day, week and month) Law (CLT)
Article 59
Federal
Constitution
Laws
Article 7º
Incise XIII
C: Legal age of employment: Legal minimum: 20 years old

(Minimum legal and actual minimum age at site) Brazilian Labor
Law (CLT)
Article 403
D: Legal minimum wage for Legal minimum: R$ 1.061,00 per month Yes
standard/contracted hours: Brazilian Labor No
(Minimum legal and actual minimum wage at site, Law (CLT)
please state if possible per hr, day, week and Article 611
month)
E: Legal minimum overtime wage: Legal minimum: Amount paid for overtime performed Yes
(Minimum legal and actual minimum overtime CLT 1) amount paid overtime performed No
wage at site, please state if possible per hr ,day, Article 59 for Cleaning Services Assistant due
week and month) § 1º to the salary of R$ 1,550 paid July
2015, additional 50% for each extra
50% plus/hour hour performed for holding 16.05
overtime during period in question
was paid to the employee in the
amount of R$ 169.62;
2) amount paid overtime performed
for Maintenance Mechanic due to
salary of R$ 2,486 paid July 2015,
additional 50% for each extra hour
performed for holding 12.70
overtime in the period in question
was paid to the employee in the
amount of R $ 215.26
Audit Scope
(Please select the code and additional requirements that were audited against during this audit)
2–Pillar Audit
10B4: Environment 4–Pillar
10C: Business Ethics
All groups of workers are included in the scope of this audit such as; Direct employees, Casual
and agency workers, Workers employed by service providers such as security and catering
staff as well as workers supplied by other contractors.
Note: The main focus of this ethical audit is on the ETI Base Code and local law. The additional elements will not be audited in
such depth or scope, but the audit process will still highlight any specific issues.
This report provides a summary of the findings and other applicable information found/gathered during the social audit
conducted on the above date only and does not officially confirm or certify compliance with any legal regulations or industry
standards. The social audit process requires that information be gathered and considered from records review, worker
interviews, management interviews and visual observation. More information is gathered during the social audit process than is
provided here. The audit process is a sampling exercise only and does not guarantee that the audited site prior, during or post–
audit, are in full compliance with the Code being audited against. The provisions of this Code constitute minimum and not
maximum standards and this Code should not be used to prevent companies from exceeding these standards. Companies
applying this Code are expected to comply with national and other applicable laws and where the provisions of law and this
Code address the same subject, to apply that provision which affords the greater protection. The ownership of this report
remains with the party who has paid for the audit. Release permission must be provided by the owner prior to release to any
third parties.
Audit Overview
Audit Overview
Management Worker Representatives
Audit attendance Senior management Worker Committee Union representatives

representatives
A: Present at the opening meeting? Yes No Yes No Yes No
B: Present at the audit? Yes No Yes No Yes No
C: Present at the closing meeting? Yes No Yes No Yes No
D: If Worker Representatives were not --

present please explain reasons why
(only complete if no worker reps present)
E: If Union Representatives were not Company does not have union representatives and others as workers
present please explain reasons why:
(only complete if no union reps present)
F: Site description:
(Include size, location and age of site. Also
include structure and number of buildings) Production Description Remark,
Building no if any
1 Factory 2700 m2
2 Final Product Storage 800 m2
3 Final Inspection 50 m2
4 General Management 100 m2
Is this a shared
No
building?
G: Site function: Agent

Factory Processing/Manufacturer
Finished Product Supplier
Grower
Homeworker
Labour Provider
Pack House
Primary Producer
Service Provider
Sub–Contractor
H: Month(s) of peak season: There is no peak season.

(if applicable)
I: Process overview:
(Include products being produced, main operations, number of production lines, main equipment used)
Receiving raw material (feathers of animals and viscera), cooking and drying with subsequent grinding process and
packaging of the final product. Major equipment: cooking tunnel, drying, grinder and product packer.
J: Attitude of workers:
(Include their attitude to management, workplace and the interview process.
Both positive and negative information should be included)
Note: Do not document any information that could put workers at risk
All workers showed up quite requested the audit process. They presented very quiet and calm during individual and
group interviews. They declare all professional activities in satisfaction in the audited company. There was no
complaint or complaint against the company.
K: Attitude of workers committee/union reps:

(Include their attitude to management, workplace and the interview process.
Note: Do not document any information that could put workers at risk
Attitude of the Workers' Committee: the Commission were evaluated workers engaged in preventing accidents
(CIPA - Internal Commission for Accident Prevention). They declare good relationship with immediate supervisor
and director; without evidence of any complaint relating to labour and other. It evidenced the presence of
emergency response and other routines of emergencies and health and safety practices. With respect to union
representation and freedom: it was evidenced freedom and no restrictions the presence of unions.
L: Attitude of managers:
(Include attitude to audit, and audit process.
The High Directors of the company extremely well received the SMS and its representative with great transferring
and receiving indications of the need for treatment of non-conformities and observations, and present action plans
for the non-conformities and observations. Regarding the main point of this study identified in audit - health
management practice and safety - is ongoing process of implementing the necessary practices and assessment of
applicable legal requirements, and the required training events have been conducted of workers.
Key Information
Key Information
(click on the key information title to go to appropriate section of the report)
A: Do all workers (including migrant workers) Yes

have contracts of employment/employment No
agreements? (Go to clause 8 Regular Employment) All workers interviewed have regular work according to Brazilian law
B: Are maximum standard/contracted Yes: maximum 44 hours per week

working hours clearly defined in No
contract/employment agreements?
(Go to clause 8 – Regular Employment)
C: Were appropriate records available to Yes - Recorded in wage roll.

verify hours of work and wages? No
(Go to clause 5 – Living Wage)
D: Were any inconsistencies found? Yes Poor record keeping

(if yes describe nature) No Isolated incident
(Go to Wages Table) Repeated occurrence
E: For the lowest paid production workers, Wages found: Please indicate the breakdown of workforce
are wages paid for standard/contracted according to earnings:
hours (excluding overtime) below or above
the legal minimum? Below legal min ____% of workforce earning under min wage
(Go to clause 5 – Living Wage) Meet ____% of workforce earning min wage
Above 100 % of workforce earning above min wage
F: % of piece rate workers: (if applicable) Not applicable
G: Do the standard/contracted hours stated Yes

in a contract/employment agreement exceed No
the law or 48 hours per week?
(Go to clause 6 – Working hours)
H: If yes, what are the standard/contracted --- hrs/week Approx. 100 % of ALL workers on these contacted
hours per week as stated in the contract/ hours
employment agreement?
(Go to clause 6 – Working hours)
I: Combined hours (standard/contracted plus Yes

overtime = total hours) over 60 per week No
found? (Go to Working Hours Analysis)
J: Are workers provided with 1 day off in Yes

every 7-day-period, or 2 in 14-day-period No
(where the law allows)? If ‘No’, please explain:
K: Are the correct legal overtime premiums Yes

paid? No
(Go to Wages Table) N/A
L: Please state what actual OT is paid. Please give details of overtime premium as a % of standard wages:
(As a percentage of the workers standard rate) 0%
(Go to Working Hours Analysis) 1% – 115%
116% – 124%
125% – 149%
150% – 199%
200%+
Overtime are by bay tax of 50 % increase and 100 % increase
M: Is there any night production work at the Yes

site? No
N: % of workers living in site provided 0%

accommodation (if applicable):
O: Age of youngest worker found: Age of youngest worker found: 20 years old. All workers who perform
(Go to clause 4 – Child labour) professional duties over 18 years. Exception for young people under
18 years of age, engaged learning functions with monitoring of the
Brazilian legal agencies and mandatory school course SENAI technical
school. Apprentices receive payment as the regional minimum wage
and are not exposed to unhealthy situations.
P: Workers under 18 subject to hazardous Yes

work assignments? (Go to clause 3 Health Safety) No
% of under 18’s at this site (of total workers) maximum 1 %
Q: What form of worker representation/union Union : Caxias do Sul Food Union workers
is there on site? Worker Committee
(Go to clause 2 – Freedom of Association) Other (specify)
None
R: Is it a legal requirement to have a union? Yes

(Go to clause 2 – Freedom of Association) No
S: Is It a legal requirement to have a workers Yes. It revealed the presence of internal Commission for the
committee? Prevention of Accidents (CIPA - Brazilian legislation NR-05), operating
(Go to clause 2 – Freedom of Association) in accordance with the provisions of the legislation in question.
No
T: Is there any other form of effective Yes

worker/management communication No
channel? (Other than union/worker committee) Describe: There is a channel of communication via claims record
(Go to clause 2 – Freedom of Association) collection box, doubts and other types of questioning. An employee
who wishes to communicate with senior management of the company
records in specific form your need and puts you in the collection box in
question. This channel has confidentiality protection system and
guarantee that there will not be any penalty for the worker.
U: Are there any External Processes? Sub–Contracting

(Go to clause 8A – Sub–contracting and Home Homeworking
working) Other External Process
No external processes
Management Systems
Management Systems:
A: Nationality of Management Brazilian
B: Gender breakdown of Management + Male: 90 %

Supervisors (Include as one combined group) Female: 10 %
C: Majority nationality of workers All brazilian
D: Number of workers leaving in last 12 months Maximum 1 %

as a % of average total number of workers on site
over the year (annual worker turnover)
E: Were accurate records shown at the first Yes

request? No
F: If No, why not? ---
G: In the last 12 months, has the site been subject Yes

to any fines/prosecutions for non–compliance to No
any regulations? Please describe:
H: Do policies and/or procedures exist that reduce Yes

the risk of forced labour, child labour, No
discrimination, harassment & abuse? Please describe:
I: If Yes, is there evidence (an indication) of Yes. Risk of forced labour, child labour, discrimination,
effective implementation? Please give details. harassment & abuse are prohibited by current code of ethics.
J: Have managers and workers received training Yes

in the standards for forced labour, child labour, No
discrimination, harassment & abuse? Please describe: The current code of ethics was implemented
with all company employees, from top management to workers at
the plant, ensuring that such practice is forbidden in the company.
K: If Yes, is there evidence (an indication) that It was evidenced ethics code implementation during first working
training has been effective e.g. training records
etc.? Please give details
L: Are there published, anonymous and/or open Yes

channels available for reporting any violations of No
Labour standards and H&S or any other Please describe: There is a internal box for collecting complains
rd
grievances to a 3 party? codes,
LM: If Yes, are workers aware of these channels? Yes. During the integration of the code of ethics is presented to
Please give details. worker the communication channel available to conduct
complaints in case the claims of receipt of cash and the assigned
form filling, and the guarantees of confidentiality and complaints
record anonymously.
N: Have health and safety risks been identified Yes
e.g. through internal audits, formal risk analysis No
process, worker involvement etc.? Please describe: According with map risk ( Brazilian law NR-05).
The organization has no internal audit and formal risk analysis
process
O: If Yes, has effective action been taken to Yes, the map risk is studying in CIPA Analyses. And besides,
reduce or eliminate these risks? there are a lot of tags with personal protective equipments
remarks along the factory.
P: Are accidents recorded? Yes

No
Please describe: It was evidenced the accident record of Mr. VB,
dated of March 2012.
Q: Has the auditor made a simple calculation to Yes

compare capacity with workers’ work load in order No
to identify possible unrecorded work hours? Please describe: At the beginning of the audit process it
confirmed the nr of staff, confirming with the design of the audit
with the provisions in the rules of SMETA. It was identified the
correct sizing identified
R: Does the site have all required land rights Yes.

licenses and permissions (see SMETA
Measurement Criteria)?
S; Does the site have any internationally The site have no internationally recognised system certifications
recognised system certifications e.g. ISO 9000,
14000, OHSAS 18000, SA8000 (or other social
audits).
Please detail (Number and date).
T: Is there a Human Resources Yes

manager/department? No
If Yes, please detail. Please describe: The Company has a Human Resources
manager, Ms Josilene Homercher
Worker Analysis
Worker Analysis
Local Migrant
Total
Home
Permanent Temporary Agency Permanent Temporary Agency
workers
Worker numbers male 39 - 2 - - - - 41
Worker numbers female 5 - - - - - - 5
Total 44 - - - - - - 46
Number of Workers
10 - - - - - - 10
interviewed
Contractors: (Individuals supplying workers to site with the workers paid by contractors, not by site)
A: Any contractors on site? Yes No
B: If Yes, how many workers supplied by contractors 2
C: Are all contractor workers paid according to law? Yes No
If Yes, Please give evidence for contractor workers Hiring contract workers to balance security service JRGF
being paid according to law: pay R$ 1,769.00 LAA pay R $ 1,769.00. Supplier of hand
Sell Janitorial Services Ordinance Ltda. Evidenced the
correct payment and in accordance with Brazilian law.
Migrant Workers: (Please see SMETA Best Practice Guidance and Measurement Criteria for definitions of migrant workers)
D: Originating Locations/Countries: No foreign workers.
E: Type of work undertaken by migrant workers : No foreign workers.
F: Were migrant workers recruited through an agency? Yes No

If yes, please give details. Please describe: No foreign workers.
If Yes, is there a contract with the agency? Provide No foreign workers.

details of agencies/contractual arrangements including
any fees lodged during the recruitment process.
G: Does the site have a system for checking labour Yes No

standards of agencies? If yes, please give details. Please describe:
H: Percentage of migrant workers in company provided No foreign workers.

accommodation:
Audit Results by Clause
0: Managements system and Code Implementation
0.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code.
0.2 Suppliers shall appoint a senior member of management who shall be responsible for compliance with the Code.
0.3 Suppliers are expected to communicate this Code to all employees.
0.4 Suppliers should communicate this code to their own suppliers and, where reasonably practicable, extend the principles of
this Ethical Code through their supply chain.
Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record
what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible
for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.
Current systems: The supplier has developed and implemented code of ethics. The senior member responsible
for managing the implementation process and compliance with the code of the unit is the unit of management. The
code communication step for employees is held during the stage of integration of the same enterprise. Regarding
the code of communication for their own suppliers, the company has suppliers who already have their code of
ethics and should ensure that all their suppliers, not only the main, receive the same.
Evidence examined – to support system description

(Documents examined & relevant comments. Include renewal/expiry date where appropriate):
Code of Ethics version 2015; implementation of evidence with the workers; communication channel - collection box
- available.
Non–compliance:
1. Description of non–compliance: NIL Objective evidence

NC against ETI/Additional Elements NC against Local Law observed:
Local law and/or ETI requirement: NIL
Recommended corrective action: NIL NIL
Observation:
Description of observation: Implementation of the code of ethics. Objective evidence

Local law or requirement ETI: Smeta Code observed:
Comments: The organization should take efforts to ensure the implementation of the
code of ethics with all its supply chain. Currently, only covers major suppliers and Implementation
suppliers of raw materials.
Good Examples observed:
Description of Good Example (GE): NIL Objective evidence observed: NIL
1: Employment is Freely Chosen
ETI
1.1 There is no forced, bonded or involuntary prison labour.
1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer
after reasonable notice.

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls
and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of
this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.
Current systems:
Well implemented without the need for corrective action.
It was not identified any complaint about forced labor or the need for prior deposit of assets or withholding
documents such as working papers.

Evidence obtained in interviews with workers and the evaluation of their employment contracts.
Non–compliance:

NC against ETI/Additional Elements NC against Local Law observed:
Recommended corrective action: NIL NIL
Observation:
Description of observation: NIL Objective evidence

Local law or ETI requirement: NIL observed: NIL
Comments: NIL
2: Freedom of Association and Right to Collective Bargaining are Respected
ETI
2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively.
2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
2.3 Workers’ representatives are not discriminated against and have access to carry out their representative functions in the
workplace.
2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and
does not hinder, the development of parallel means for independent and free association and bargaining.

Current systems:
Well Implemented without the need for corrective action.
No restriction was evidenced freedom of association, nor any union access impediment to business unit.

Evidence obtained in interviews with workers and the evaluation of their employment contracts.
Company workers exercising their right to join the trade union of the region without any kind of restriction of
freedom by exercising their choice, according to the signed collective bargaining agreement in force, the year 2015.
Non–compliance:

NC against ETI/Additional Elements NC against Local Law observed: NIL
Recommended corrective action: NIL
Observation:

Comments: NIL
A: Name of union and union Caxias do Sul Feed Industry Is there evidence of free elections?
representative, if applicable: Union Yes
No
N/A
B: If no union what is parallel means of NIL Is there evidence of free elections?

consultation with workers e.g. worker Yes
committees? No
N/A
C: Were worker representatives/union Yes

representatives interviewed No
If Yes, please state how many:
D: State any evidence that Employee stated during interviews although the company have a
union/workers committee is effective? positive attitude towards the union, they are not interest on union
Specify date of last meeting; topics covered; agreement issues
how minutes were communicated etc.
E: Are any workers covered by Yes

Collective Bargaining Agreement (CBA) No
F: If Yes what percentage by trade 100 % workers covered by Union ____% workers covered by worker
Union/worker representation CBA rep CBA
G: If Yes, does the Collective Yes

Bargaining Agreement (CBA) include No
rates of pay
3: Working Conditions are Safe and Hygienic
ETI
3.1 A safe/hygienic working environment shall be provided, bearing in mind prevailing knowledge of industry and of any specific
hazards. Adequate steps shall be taken to prevent accidents/injury to health arising out of, associated with, or occurring in the
course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
3.2 Workers shall receive regular and recorded Health & Safety training, and such training shall be repeated for new or
reassigned workers.
3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided.
3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for Health & Safety to a senior management representative.

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems: In the implementation phase. Some non-conformities were identified

Alignment between environmental risk prevention program programs, medical control of organizational health
program, an Occupational Health Certificate and distribution of personal protective equipment for workers IZ, steam
boiler worker; RM, Employee responsible for cleaning and conservation, and CG, Maintenance mechanic: EPI
distribution machine operators , Approval Certificate ( CA), number nr 5745, expiration 2019; nitrile glove CA
32070, validity 2018 and others. Assistance to NR-10. Inspection of SPDA, held in July 2015, by a qualified
professional CREA - RS191719 - evidenced visual inspection and measurement of electrical resistance of 4.3
Ohms ground. Technical Reports working conditions, version 2015. ergonomic Report, evidenced establishment
program and areas of fitness schedule. Already with ergonomic chairs were bought. The work activities do not
require staying in the same function. The responsible for ergonomic program is under the responsibility inhabited
Sizing of fall arrest pavilion flour PH CREA RD 136364 scaling resistance to 175 kgf with maximum load indication.
Non–compliance:
3.1. Description of non–compliance: Major Not available assessment unifilar chapel Objective evidence
compared to luminance parameters, sound pressure and exhaustion capacity at odds with observed:
the provisions of ETI, item 3.4
NC against ETI NC against Local Law
Local law and/or ETI requirement: ETI item 3.4 Inadequate provisions for safe
handling of hazardous chemicals or lapses in their application
Recommended Corrective Action: Conduct performance evaluation of assessment
unifilar chapel.
Follow-up: Evidenced conducting evaluation of sound pressure, exhaust flow and
illuminance. All assessments conducted in October 2015 on the responsibility of Joshua
Bussmann (Occupational Safety Technician, RS 1864); Alfredo Wesp (Eng. Safety, CREA-
RS 184850) and Cleberton Caesar (CREA-RS Engineer 191719). Expected annual
assessment. Satisfactory and closed action. Status Closed
Non–compliance:
3.2. Description of non–compliance: Major Emergency exit doors allowing easy opening not Objective
from inside the establishment, for example door emergence of chemical laboratory and factory. evidence
At odds with NR-23 (2011). observed:
Local law and/or ETI requirement: NR-23 (2011), item 23.5 Emergency exits can be equipped Documentation
with locking devices that allow easy opening inside the establishment. analysis
Recommended corrective action: Correct outputs of the exit doors; create design
systematically to prevent recurrence.
Follow-up: Fixed exit door emergence chemical laboratory opening from inside establishment.
Planning to inspect all emergency doors in on time. Satisfactory/closed action. Status Closed
Non–compliance:
3.3. Description of non–compliance: Major Without footer stairs. Factory stairs and Objective evidence
other units of the company do not have footers at odds with the NR-12 (2015), observed:
Local law and/or ETI requirement: NR-12(2015). Article 12.70 means of access ...,
must have protection system falls with as following. e) have baseboard at least 0.20 m
high and 0.70 m indent one intermediate height from the floor, located between the
baseboard and the upper crossbar.
Recommended corrective action: Correct stairs; create design systematically to
prevent recurrence.
Follow-up: Fixed footer in factory stairs in accordance with provisions of Brazilian law
NR12. Evidenced inspection plan to ensure projects of new stairs. Status Closed
Non–compliance:
3.4. Description of non–compliance: Major Not available the Respiratory Protection Objective
Program in accordance with the Instruction INSS 01 April 1994. evidence
NC against ETI NC against Local Law observed:
Local law and/or ETI requirement: Regular instruction INSS 01 April 1994 Article 1 The
employer must adopt a set of measures in order to tailor the use of respiratory- protective Documentation
equipment. EPR when needed to complement measures of collective protection implemented, analysis
or as long as they are being implemented, in order to ensure full protection to workers against
the risks in the workplace. Organization makes use of various chemicals, such as chloroform
and methanol, and no search respiratory possible contamination
Recommended Corrective Action: .Establish systematic program and its periodic review or
as needed
Follow-up: Evidenced respiratory protection program in accordance with the assumptions of
Brazilian legislation Instruction 01 INSS April 1994. Monitoring of exposure to Chloroform (test
report 89831/2015), measured value 1.61 ppm (limit of tolerance) 20 ppm; methanol exposure
(89826/2015 test report), no known exposure (156 ppm tolerance limit). Evidenced training in
the use of respiratory protection. Status Closed
Non–compliance:
3.5. Description of non–compliance: Major Not available. Hearing Conservation Objective evidence
Program (PCA) in violation of NR-07 (2013) observed:
Local law and/or ETI requirement: NR07 2013 Annex I to Schedule II 1.1 Hearing Documentation
Conservation Program Establish guidelines/minimum standards for evaluation/monitoring analysis
of workers' hearing through performing audiological tests of reference and sequential
Recommended Corrective Action: Establish systematic program and its periodic review
or as needed
Follow-up: Evidenced Hearing Conservation Program, developed by the Occupational
Safety Technician, Josuel Bussmann RS 1864, with an annual evaluation. Satisfactory
and closed corrective action. Status Closed
Non–compliance:
3.6. Description of non–compliance: Major Not available procedure for management of Objective evidence
confined spaces, at odds NR33. Company already has the training, in violation of NR33. observed:
Local law and/or ETI requirement: NR-33 (2006), item 33.2.1 It is up to the employer "to
implement safety and health management at work in confined spaces, for technical
preventive measures, administrative , personal and emergency and rescue in order to
permanently ensure environments with proper working conditions
Recommended Corrective Action: Establish systematic program and its periodic
review or as needed
Follow-up: Evidenced Program Confined Spaces Management, according to Brazilian
legislation NR-33, developed by the Occupational Safety Technician, Josue Bussmann,
RS nr 0001864, with an annual evaluation .Evidenced completion of the required training
Status Closed
Non–compliance:
3.7. Description of non–compliance: Major Not available procedure for labour Objective evidence
management in height, at odds with the NR-35 (2012). observed:
Local law and/or ETI requirement: NR35 2012 item 35.2.1 Employer's responsibilities:
a) ensure the implementation of protective measures set forth in this Standard;
b) ensure conduct of Risk Analysis AR; where applicable, to issue the Work Permit PT;
c) develop operational procedures for the routine activities of working at height
Recommended Corrective Action: Establish systematic program and its periodic
review or as needed.
Follow-up: Evidenced work management program in height, according to Brazilian
legislation NR-35 and developed by the Occupational Safety Technician, Josue
Bussmann, RS nr 0,001,864, with an annual evaluation. Evidenced risk analysis of sites
with height greater than 2.0 m; evidenced training workers. Status Closed
Non–compliance:
3.8. Description of non–compliance: Major Organization has no storage facilities, Objective evidence
disposal, containment or spill of hazardous chemicals for use in the Chemical Analysis observed:
Laboratory
Local law and/or ETI requirement: 3.4: Chemicals. Inadequate provisions for safe
handling of hazardous chemicals or lapses in their application
Recommended Corrective actions:
Evaluating reactivity of chemicals, create a routine for management infrastructure to
provide the correct storage )
Follow-up: Organization developed area to storage , containment and to avoid spill
of hazardous chemicals for use in Chemical Analysis Laboratory. Status Closed
Observation:
Description of observation: Use of electrical connection devices Objective evidence

Local law or requirement ETI: NR-10 (2004) observed:
Recommended corrective action: It is recommended to review the practice of using
electrical connection devices, is reducing its use or test their validity amperage of the Site visit
electrical equipment used
Description of Good Example (GE): NIL Objective evidence

observed: NIL
4: Child Labour Shall Not Be Used
ETI
4.1 There shall be no new recruitment of child labour.
4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any
child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child.
4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO Standards.

Current systems:
Well Implemented without the need for corrective action.
The company does not have workers less than 18 years of age, except those in apprenticeship contract, according
to Brazilian legislation; these are in vocational schools, with wage guarantee in accordance with Brazilian law and
are not exposed to any risk. The current code of ethics prevents the hiring of workers under 18 years old.

All workers interviewed have more than 20 years.
Evidenced apprenticeship contract with several young, executed in accordance with Brazilian law.
Non–compliance:

Observation:

Comments: NIL
5: Living Wages are Paid
ETI
5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark
standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some
discretionary income.
5.2 All workers shall be provided with written and understandable information about their employment conditions in respect to
wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they
are paid.
5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided
for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be
recorded.

Current systems: Well Implemented without the need for corrective action.
It was shown that all the company's workers have wages above the Brazilian minimum wage and the regional
minimum wage. In relation to additional payments such as overtime, night work and of others, identified the correct
payment, in accordance with Brazilian law.
Regarding the discounts, all identified discounts, such as union dues, discount rates are in accordance with
Brazilian law. Workers receive salary receipt with the correct record of wages and wage rates discounts.

Evaluated 12 records of payments within 2 months of the year 2015 as well as vacation pay, and other additional.
Non–compliance:

Observation:

Comments: NIL
Wages analysis:
A: Sample Size Checked (State number of worker Tens workers, two payrolls . They evaluated the months of July
records checked and from which weeks/months – should and January 2015; assessed payments for overtime, additional
be current, peak and random/low. Please see SMETA
Best Practice Guidance and Measurement Criteria)
end-of-year and holidays. All payments are registered and in
accordance with Brazilian legislation
B: Are there different legal minimum wage Yes If Yes, please give details:
grades? If Yes, please specify all. No None
C: If there are different legal minimum grades, Yes If No, please give details:
are all workers graded correctly? No None
N/A
D: What deductions are required by law e.g. Social charges and income tax
social insurance? Please state all types:
E: Have all of these deductions been made? Yes If Yes, Please list all deductions that have been
Please list all deductions that have/have not No made: Social charges and income tax
been made.
If No, please give details on any deductions
which have not been made:
F: Industry norm for this region: Union Agreement (Month payment)

(please include time period e.g. hour/week/month)
Wages table
Process Operator Process Operator Process Operator

Worker Type
(Lowest paid) (Average paid) (Highest paid)
Select from individual worker records one worker from, lowest, average and highest wages and populate the boxes. Ensure comparison is
made for same pay period and only uses full–time workers. See SMETA Best Practice Guidance and Measurement Criteria for completing this:
A: Pay period: (State month selected) 2015 January & July 2015 January & July 2015 January & July
B: Anonymous Employee Reference/Dept. Cleaning and Electrical Mechanical

conservation Maintenance Maintenance
services
C: Employee Gender Female Male Male
D: Contracted/Standard working hours: Month Month Month

(excluding OT – please include time period)
E: Contracted /Standard work pay rate: Month Month Month

(excluding OT – please include time period)
F: Standard day overtime – hours: One hour per day, Two hours per day, Two hours per day,
(please include time period e.g. hour/week/month) maximum maximum maximum
G: Standard day overtime – wage: Maximum two hours Maximum two hours Maximum two hours
(please include time period e.g. hour/week/month) per day per day per day
H: Rest day overtime – hours: One day per week One day per week One day per week
I: Rest day overtime – wage: One day per week One day per week One day per week
J: Statutory Holiday overtime – hours: One day per week One day per week One day per week
K: Statutory holiday OT – wages: --- ---- ---

L: Total overtime hours: 16,05 hours per 11,52 hours per 12,70 hours per
(please include time period e.g. hour/week/month) month, March month, Jun month, July
M: Incentives/Bonus/Allowances etc.: -- --- ---

N: Gross wages: R$ 1550 R$ 1847,00 R$ 2486

O: Social insurance and other deductions; Social Tax,9 % Social Tax, 9 % Social Tax,11 %
please list which and amount.
P: Actual wage paid after deduction: R$ 1.410,50 R$ 1.680,77 R$ 2.189,40

Comments: (Please state here any specific reasons/circumstances that explain the lowest and highest gross wages)
Evidence of attendance Brazilian law associated with the payment of salaries.
Q: Is there a defined living wage: Yes

This is not normally minimum legal wage. If answered No
Yes please state amount and source of info:
Please see SMETA Best Practice Guidance and
Please specify amount/time period: R$ 1061,00 per month
Measurement Criteria.
R: Are workers paid in a timely manner in Yes

line with local law? No
S: Is there evidence that equal rates are Yes

being paid for equal work: No
Details:
T: How are workers paid: Cash

Cheque
Bank Transfer
Other
If other explain:
6: Working Hours are not Excessive
ETI
6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever
affords the greater protection for workers. Sub–clauses 6.2 to 6.6 are based on international labour standards.
6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.
6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent,
frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular
employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the
regular rate of pay.
6.4 The total hours worked in any 7 day period shall not exceed 60 hours, except where covered by clause 6.5 below.
6.5 Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all of following are met:
– this is allowed by national law;
– this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant
portion of the workforce;
– appropriate safeguards are taken to protect the workers’ health and safety; and
– The employer can demonstrate that exceptional circumstances apply such as unexpected production peaks,
accidents or emergencies.
6.6 Workers shall be provided with at least one day off in every 7 day period or, where allowed by national law, 2 days off in
every 14 day period.

Current systems: Well Implemented without the need for corrective action. Evidenced excess hours, not
exceeding the maximum of two hours, according to Brazilian law Consolidation of labour laws. There was not
above journeys of 48 hours per week. All overtime is carried out by free will of workers
Evidence examined to support system description
It was evaluated ten sheets points of workers.
Non–compliance:

Observation:
Description of observation: Overtime Objective evidence

Local law or ETI requirement: CLT - Consolidation of Labor Laws observed:
Comments: The organization could adopt routine to evaluate possible trends Overtaking possibility nr of
overtaking the number of overtime provided for by law. permitted overtime
Working hours analysis
Please include time period e.g. hour/week/month
Systems & Processes
A. What timekeeping systems are used: Describe: time card

time card etc.
B: Sample Size Checked (State number of Sampled points cards of the year 2015 to ten employees from different
worker records checked, from which weeks/ functions
months and type –current, peak and random/low:
See SMETA Best Practice Guidance and
Measurement Criteria)
C: Do ALL workers have contracts/ Yes If NO, state which type of workers do NOT have
employment agreements? No contracts/employment agreements:
---
D: Are standard/contracted working Yes If NO, please state which type of workers do NOT have
hours defined in all contracts/ No standard hours defined in contracts/employment
employment agreements? agreements.
---
E: Are there any other types of Yes If YES, Please complete as appropriate:
contracts/employment agreements No
used? 0 hrs Part time Variable hrs Other
If “Other”, Please define:
---
Standard/Contracted Hours worked
F: Do standard/contracted standard Yes If YES give details/comparison (local law/48 hrs week)
hours ever exceed the law or 48 No
hours per week? ---
G: What are the actual standard/ Highest hours: 16,05 hours per month, March
contracted hours worked in sample
(State per week/month) Lowest hours: 11,52 hours per month, June
H: Any local waivers/local law or Yes If YES, Please give details

permissions which allow averaging/ No
annualised hours for this site? ---
Overtime Hours
I: Actual overtime hours worked in Highest OT hours: 16,05 hours per month, March
sample (State per day/week/month)
Lowest OT hours: 11,52 hours per month, June
J: Range of overtime hours over all 1,5 to 16,05 in March

workers/or as large a sample as 11,52 to 15,07 in June
possible. (State per week/month/ details) 0,6 to 10 in July
K: Approximate percentage of workers 30 %

on highest overtime hours
L: Is overtime voluntary? Yes Please detail evidence e.g. Wording of contract/

No employment agreement/handbook/worker
Conflicting interviews/refusal arrangements:
Information
worker interviews
Overtime Premiums
M: Is overtime paid at a premium? Yes Please give details of normal day overtime premium as a
No % of standard wages:
0% 1– 116 – 125 – 150 – 200%+

115% 124% 149% 199%
Any other comments:---
N: ETI Code requires a prevailing No

standard to give greatest worker Consolidated pay (May be standard wages above minimum legal wage, with
protection. no/low overtime premium)
If a site pays less than 125% OT Collective Bargaining agreements
premium and this is allowed under Other
local law, are there other
considerations? Please complete the Please explain any checked boxes in N above e.g. detail of consolidated
boxes where relevant. Multi select is pay CBA or Other.
possible.
Brazilian Labor Law requires manufacturers to pay employees for overtime
in accordance with following rate structure:
a – In accordance with Brazilian Labor Law, Article 59, paragraph 1,
overtime hours should be paid 50% or more over regular wage per hour.
b – In accordance with Brazilian Labor Law, Article 457, Paragraph 1, not
only the stipulated value but also overtime wage, commissions,
percentages, gratifications, etc., are part of the salary.
c – In accordance with Brazilian Labor Law, Article 71, Paragraph 4, when
employer does not allow lunch time or rest time, he must pay the
corresponding time by 50% over normal working time wage.
d – In accordance with Court Statement no. 146, the overtime hours
performed on holidays should be paid in double.
Rest Days
O: Are workers provided with 1 day Yes Maximum number of days worked without a day off (in sample):
off in every 7–day–period, or 2 in 14– No
day–period (where the law allows)? Day off: 1 day off in every 7–day–period
Total Hours
P: Range of total hours: Highest total hours 236 hours per month
(Quote highest and lowest please include
time period e.g. hour/week/month)
Lowest total hours 220,6 hours per month
R: If more than 60 total hours per Overtime is voluntary

week and this is legally allowed, are Onsite Collective bargaining allows 60+ hours/week
there other considerations? Please Safeguards are in place to protect worker’s health and safety
complete the boxes where relevant. Site can demonstrate exceptional circumstances
Multi select is possible. Other reasons
Please explain any checked boxes in R above
There are no more than 60 total hours per week
Comments: (please state here any specific reasons/circumstances that explain the highest working hours)
NONE
7: No Discrimination is Practiced
ETI
7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race,
caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

Current systems: Well implemented; without corrective action. It was shown no hint of any colour discrimination,
sex, creed, religion and others. It was shown that the current Code of Ethics prohibits any kind of discrimination.
Evidence examined - to support system description

(Documents examined & comments relevant Include renewal / expiry date where Appropriate.):
They interviewed ten employees, without all state that there is no type of practice regarding discrimination..
Non–compliance:

Observation:

Comments: NIL
8: Regular Employment Is Provided
ETI
8.1 To every extent possible work performed must be on the basis of recognised employment relationship established through
national law and practice.
8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment
relationship shall not be avoided through the use of labour–only contracting, sub–contracting, or home–working arrangements,
or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any
such obligations be avoided through the excessive use of fixed–term contracts of employment.

Current systems: It was shown that the work is carried out on the basis of recognized employment relationship
established through legislation and practices. It was shown for all workers interviewed the presence of valid work
contract and according to the Brazilian labor laws. It was not evidenced any subcontracting, work at home, work, or
other work scheme in illegal Brazilian law

Assessed employment contracts than ten employees and all according to Brazilian law.
Non–compliance:

Observation:

Comments: NIL
8A: Sub–Contracting and Homeworking
8A.1. There should be no sub–contracting unless previously agreed with the main client.
8A.2. Systems and processes should be in place to manage sub–contracting, homeworking and external processing.
Note to auditor on homeworking:
Report on whether it is direct or via agents. How many workers, relationship with site and what control systems are in place.

Current systems: The organization has not outsourced production process. All steps related to the case -
processing animal waste - are held internally.

(Documents examined & relevant comments. Include renewal/expiry date where appropriate): None
If any processes are sub–contracted – please populate below boxes None
Non–compliance:

Observation:

Comments: NIL
Summary of sub–contracting – if applicable
A: If sub–contractors are used, is there Yes

evidence this has been agreed with the main No
client? If Yes, summarise details:
B: Number of sub–contractors/agents used None
C: Is there a site policy on sub–contracting? Yes

No : The organization has not outsourced production process
If Yes, summarise details:
D: What checks are in place to ensure no None

child labour is being used and work is safe?
E: What processes are sub–contracted? None
Summary of homeworking – if applicable
F: If homeworking is being used, is Yes

there evidence this has been agreed No - The organization has not outsourced production process
with the main client? If Yes, summarise details:
G: Number of homeworkers Male: None Female: None Total: None
H: Are homeworkers employed direct Directly

or through agents? Through Agents
I: If through agents, number of ---

agents
J: Is there a site policy on Yes

homeworking? No - There are no home working
K: How does site ensure worker ---

hours and pay meet local laws for
homeworkers?
L: What processes are carried out by ---

homeworkers?
M: Are written agreements in place Yes

for homeworkers that include regular No
employment? None
N: Are full records available at the Yes

site? No
None
9: No Harsh or Inhumane Treatment is Allowed
ETI
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of
intimidation shall be prohibited.

and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of
Current systems: Well implemented without non-compliance.

There were no records or complaints from workers during the interviews about the presence of physical abuse or
discipline, the threat of physical abuse, sexual harassment or other and verbal abuse or other forms of intimidation.

Interviews with ten workers
Non–compliance:

Observation:

Comments: NIL
10. Other Issue areas: 10 A: Entitlement to Work and Immigration
Additional Elements
10A1 Only workers with a legal right to work shall be employed or used by the supplier.
10A2 All workers, including employment agency staff, must be validated by the supplier for their legal right to work by reviewing
original documentation.
10A3 Employment agencies must only supply workers registered with them.
10A4 The supplier shall implement processes to enable adequate control over agencies with regards the above points and
related legislation.

Current systems: Legal contract: all interviewed workers have regular contract, according to the provisions of
Brazilian law. Workers who act as vigilantes have regular and hired contract employment agency with assessment
provided the contractor with respect to regular work. The company exercises control over employment agencies
hand labour providers regarding the correct payment of wages, payment of benefits such as the tenth-third parties,
holidays, overtime and others; ditto for assessing the actual discounts such as income taxes and others. Currently
the company has no foreign workers, but if they are hired, will be hired with the same rights of Brazilian workers.

Interview with ten workers
Non–compliance:

Observation:

Comments: NIL
10. Other issue areas 10B4: Environment 4–Pillar
To be completed for a 4–Pillar SMETA Audit and remove the previous page which is 10B2 environment 2 pillar
B.4. Compliance Requirements

10B4.1 Suppliers as a minimum must meet the requirements of local and national laws related to environmental standards.
10B4.2.Where it is a legal requirement, suppliers must be able to demonstrate that they have the relevant valid permits
including for use and disposal of resources e.g. water, waste etc.
10B4.3. The supplier shall be aware of their end client’s environmental standards/code requirements and have a system in
place to monitor their performance against these.
B4. Guidance for Observations
10B4.4. Suppliers should have completed the appropriate section of the SAQ and made it available to the auditor.
10B4.5. Suppliers should have an environmental policy, covering their environmental impact, which is communicated to all
appropriate parties, including its own suppliers.
10B4.6. Suppliers shall be aware of the significant environmental impact of their site and its processes.
10B4.7. The site should measure its impacts, including continuous recording and regular reviews of use and discharge of
natural resources e.g. energy use, water use (see 4–pillar audit report and audit checks for details).
10B4.8. Suppliers shall seek to make continuous improvements in their environmental performance.
10B4.9. Suppliers shall have available for review any environmental certifications or any environmental management systems
documentation
10B4.10. Suppliers should have a nominated individual responsible for co–ordinating the site’s efforts to improve environmental
performance.
10B.4.11. Has the site recently been subject to (or pending) any fines/prosecutions for noncompliance to environmental
regulations.
Note for auditors and readers. This environment section is intended to take not more than 0.25 auditor days. It is an assessment only
and the main requirement is to establish whether a site is meeting applicable environmental laws and/or has any certifications or
environmental management systems in place. Following this assessment the client/supplier may decide a full environmental audit is
required (see also best practice guidance/environment and guidance for auditor)

Current systems: Well implemented. Software for management of waste and liquid effluents and air emissions.
Monitoring of environmental performance in waste management, wastewater and atmospheric emissions
Non–compliance:
10B4.1. Description of non–compliance: Major: Environmental licensing. External noise Objective

assessment. Not available evidence of external noise assessment in accordance Environmental evidence
permit FEPAM LO 04931/2015-DL and Brazilian law CONAMA 01/90 (NBR 10151:2000) observed:
NC against ETI NC against Local Law Documental
Local law and/or ETI requirement: CONAMA 01/90 NBR 10151:2000 Items: I noise emissions Analysis :
as a result of any industrial, commercial, social, including those of political propaganda, obey, in Environmental
the interests health, public peace, the standards, criteria and guidelines set forth in this Resolution permit FEPAM
II are harmful to health and public peace, for the fi ns of the previous item, the with noise levels LO
above those considered acceptable by the NBR-10.15179 - Rating Noise in Inhabited Areas to 04931/2015-
ensure the comfort of the community, the Association Brazilian Technical Standards - ABNT. DL External
Recommended Corrective Actions: Perform evaluation of external noise; to create systematic noise
periodic evaluation. assessment.
Follow-up: Available report of external noise, made by Engineer Geraldo Ribar, CREA-RS82645.
Status Closed
Observation:

Comments: NIL
Environmental Analysis
(Site declaration only – this has not been verified by auditor. Please state units in all cases below.)
A; Responsible for Environmental issues Freddy Kaufmann Environmental Engineer
B: Does the site have a recognised Yes

environmental system certification such as No
ISO 14000 or equivalent? Please detail. Details:
C: Does the site have an Environmental Yes : The organization has drafted environmental policy, with
policy? the same being implemented
(For guidance, please see Measurement criteria ) No
Does the site have a Biodiversity policy? Yes

(For guidance, please see Measurement criteria ) No
E: Is there any other sustainability systems Yes

present such as Chain of Custody, Forest No
Stewardship Council (FSC), Marine Details:
Stewardship Council (MSC) etc.? Please
detail. (For guidance, see Measurement criteria )
F: Have all legally required permits been Yes

shown? No
Please detail. Details:
Environmental permit FEPAM LO 04931/2015-DL issued.
Fire permit PPCI 1471/1 average risk valid until June 2016
Fuel station permit By ANP (Brazilian Oil Agency, valid until
November 2015)
G: Is there a documentation process to record Yes

hazardous chemicals used in the No
manufacturing process? N/A
Details:
H: Is there a system for managing client’s Yes

requirements and legislation in the destination No
countries regarding environmental and Details:
chemical issues?
Usage/Discharge analysis
Criteria Current year: Please state period: Previous Year: Please state period:
(1)
july, 2015____________ Not available
Electricity Usage: Kw/hrs 152.205
Renewable Energy Usage: Kw/hrs -
Gas Usage: Kw/hrs -
Has site completed any carbon Yes Yes

Footprint Analysis? No No
If Yes, please state result
Water Sources: Please list all sources • Groundwater •

e.g. lake, river, and local water authority.
Water Volume Used: (m³) 77 (average)
Water Discharged: Please list all • Factory cleaning •

receiving waters/recipients. • Boiler purges •
Water Volume Discharged: (m³) 35 (average)
Water Volume Recycled: (m³) -
Total waste Produced: Paper, Paperboard, Plastic, iron,

(please state units) non-recyclable, hazardous waste
Total hazardous waste Produced: Fluorescent lamps, waste

(please state units) contaminated with oil
Waste to Recycling: Paper, paperboard, plastic, iron

(please state units)
Waste to Landfill: Non-recyclable waste

(please state units)
Total Product Produced: Feather Meal – 331.680 kg

(please state units) Poultry Meal – 648.810 kg
Poultry Oil – 362.180 kg
(1) The results of the previous year were not available
10C: Business Ethics – 4-Pillar Audit
To be completed for a 4–Pillar SMETA Audit
10C. Guidance for “Observations”

10C.1. Suppliers should have completed the appropriate section of the SAQ and have made it available to the auditor.
10C.2. The supplier should have received and acknowledged– preferably in writing – the Business Ethics policy of the
auditor/audit company.
10C.3. Suppliers shall seek to conduct their business ethically without bribery/corruption/any type fraudulent Business Practice.
10C.4. Suppliers shall be aware of any applicable laws, their end client’s Business Ethics standards/code requirements and
have a system in place to monitor their performance against these.
10C.5. Supplier should have a Business Ethics policy concerning bribery, corruption, or unethical Business Practice. This
should be clearly communicated to all relevant parties.
10C.6. Suppliers should have a designated person responsible for implementing standards concerning Business Ethics
10C.7. Suppliers should have a transparent system in place for confidentially reporting, and dealing with unethical Business
Ethics without fear of reprisals towards the reporter
10C.8. Suppliers should ensure that the staff whose job roles carry a higher level of risk in the area of ethical Business Practice
e.g. sales, purchasing, logistics are trained on what action to take in the event of an issue arising in their area.
Note for auditors and readers. This Business Ethics section is intended to take not more than 0.25 auditor days. It is an assessment not
an audit and the main requirement is to gather information on the relevant Business Ethics issues in a supply chain. All findings will be
recorded as observations not Non– Compliances and the data collected will allow the membership to define appropriate standards over
time as part of a continuous review process.

and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of
Current systems: Well implemented. Organization developed code of ethics, which provides all of standard items,
focusing especially on prohibition of any kind of prejudice, corruption practices, irregular and other work. The same
is implemented with workers during the beginning of work, with the responsibility of this task performed by the
Human Resources department.
Code of ethics, version 2015. Interviews with workers
Non–compliance:

Observation:
Description of observation: Code of Ethics Objective evidence

Local law or ETI / demand additional elements: ETI Code observed:
Comments: It is recommended to improve the implementation of the code of ethics in all Ethics Code
the organization's supply chain. Currently, the major suppliers of the organization, already implementation
has its own code of ethics, it is important to extend efforts to achieve all the other suppliers. supply chain
Worker Interview Summary
Worker Interview Summary
A: Were workers aware of the audit? Yes

No
B: Were workers aware of the code? Yes

No
C: Number of group interviews: (Please specify number 1 group of 4

and size of groups. Please see SMETA Best Practice
Guidance and Measurement Criteria)
D: Number of individual interviews: (Please see SMETA Male: 4 Female: 2

Best Practice Guidance and Measurement Criteria)
E: Total number of interviewed workers Male: 8 Female: 2

(Please see SMETA Best Practice Guidance and
Measurement Criteria)
F: Interviews were done in private and the Yes

confidentiality of the interview process was No
communicated to the workers?
G: In general, what was the attitude of the workers Favourable

towards their workplace? Non–favourable
Indifferent
H: What was the most common worker complaint? There are no complaint
I: What did the workers like the most about working at Payment of wages on time without any delay; favourable
this site? and healthy working environment.
J: Any additional comment(s) regarding interviews: None
K: Attitude of workers to hours worked: Normal Attitude: workers indicated that the performance
of overtime was accepted with the same, without any
pressure. It has also indicated that all the hours were paid
in accordance with Brazilian law and the incidence of
associated benefits and taxes, which was evidenced by
the auditor during the evaluation of payroll thereof.
Agency Workers
Agency Workers (if applicable)
(workers sourced from a local agent who are not directly paid by the site)
A: Number of agencies used (average): And names if available: One; Supplier of hand Sell
Janitorial Services Ordinance Ltda. Company responsible
for providing armed security guard for the balance of the
facility. Single event worker agent and this is not part of
the main process of the company.
B: Were agency workers’ age/pay/hours included Yes

within scope of this audit No
C: Were sufficient documents for agency workers Yes

available for review? No
Other findings
Other Findings Outside the Scope of the Code
None
Community Benefits
(Please list below any specific community benefits that the site management stated that they were involved in, for example, HIV
programme, education, sports facilities)
None
Appendix 1
Comparison between ETI code and Customer's Supplier's Code. Any areas where a site complies with the Customer's Supplier
Code, but not with the ETI code are discussed at the audit close out meeting and recorded on the CAPR. Note to supplier "for
this customer it may not be necessary to complete corrective actions where NC's DO NOT meet the ETI code, but DO meet
your customer's code. If the audit is shared with other customers who work to the ETI code or an equivalent international
standard, corrective actions will be necessary."
NOTE: The provisions of the ETI base Code constitute minimum and not maximum standards, Instruction to Audit
and this code should not be used to prevent companies from exceeding these standards. Company: fill in relevant
Companies applying the ETI Base Code are expected to comply with national and other clauses from the Customer
applicable law and, where the provisions of law and the ETI Base Code address the same subject, Supplier Code - where
to apply that provision which affords the greater protection. applicable.
ETI Code Customer's Supplier

Code equivalent
ETI 1. Employment is freely chosen

(2)
1.1. There is no forced, bonded or involuntary prison labour. Yes
1.2. Workers are not required to lodge "deposits" or their identity papers with their employer and
are free to leave their employer after reasonable notice.
ETI 2. Freedom of association and the right to collective bargaining are respected
(2)
2.1. Workers, without distinction, have the right to join or form trade unions of their own choosing Yes
and to bargain collectively.
2.2. The employer adopts an open attitude towards the activities of trade unions and their
organisational activities.
2.3. Workers representatives are not discriminated against and have access to carry out their
representative functions in the workplace.
2.4. Where the right to freedom of association and collective bargaining is restricted under law, the
employer facilitates, and does not hinder, the development of parallel means for independent and
free association and bargaining.
ETI 3. Working conditions are safe and hygienic

(2)
3.1. A safe and hygienic working environment shall be provided, bearing in mind the prevailing Yes
knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent
accidents and injury to health arising out of, associated with, or occurring in the course of work, by
minimising, so far as is reasonably practicable, the causes of hazards inherent in the working
environment.
3.2. Workers shall receive regular and recorded health and safety training; such training shall be
repeated for new or reassigned workers.
3.3. Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for
food storage shall be provided.
3.4. Accommodation, where provided, shall be clean, safe, and meet the basic needs of the
workers.
3.5. The company observing the code shall assign responsibility for health and safety to a senior
management representative.
ETI 4. Child labour shall not be used
4.1. There shall be no new recruitment of child labour. Yes (2)

4.2. Companies shall develop or participate in and contribute to policies and programmes which
provide for the transition of any child found to be performing child labour to enable her or him to
attend and remain in quality education until no longer a child; “child” and “child labour” being
defined in the appendices.
4.3. Children and young persons under 18 shall not be employed at night or in hazardous
conditions.
4.4. These policies and procedures shall conform to the provisions of the relevant ILO standards.
ETI 5. Living wages are paid
5.1. Wages and benefits paid for a standard working week meet, at a minimum, national legal Yes (2)
standards or industry benchmark standards, whichever is higher. In any event wages should
always be enough to meet basic needs and to provide some discretionary income.
5.2. All workers shall be provided with written and understandable Information about their
employment conditions in respect to wages before they enter employment and about the
particulars of their wages for the pay period concerned each time that they are paid.
5.3. Deductions from wages as a disciplinary measure shall not be permitted nor shall any
deductions from wages not provided for by national law be permitted without the expressed
permission of the worker concerned. All disciplinary measures should be recorded.
ETI 6. Working Hours are not excessive
6.1 Working hours must comply with national laws, collective agreements, and the provisions of Yes (2)
6.2 to 6.6 below, whichever affords the greater protection for workers. Sub–clauses 6.2 to 6.6 are
based on international labour standards.
6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48
hours per week.
6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the
following: the extent, frequency and hours worked by individual workers and the workforce as a
whole. It shall not be used to replace regular employment. Overtime shall always be compensated
at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.
6.4 The total hours worked in any 7 day period shall not exceed 60 hours, except where covered
by clause 6.5 below.
6.5 Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances
where all of the following are met:
– this is allowed by national law;
– this is allowed by a collective agreement freely negotiated with a workers’ organisation
representing a significant portion of the workforce;
– appropriate safeguards are taken to protect the workers’ health and safety; and
– The employer can demonstrate that exceptional circumstances apply such as unexpected
production peaks, accidents or emergencies.
6.6 Workers shall be provided with at least one day off in every 7 day period or, where allowed by
national law, 2 days off in every 14 day period.
ETI 7. No discrimination is practised
There is no discrimination in hiring, compensation, access to training, promotion, termination or Yes (2)
retirement based on race, caste, national origin, religion, age, disability, gender, marital status,
sexual orientation, union membership or political affiliation.
ETI 8. Regular employment is provided
8.1. To every extent possible work performed must be on the basis of recognised employment Yes (2)
relationship established through national law and practice.
8.2. Obligations to employees under labour or social security laws and regulations arising from the
regular employment relationship shall not be avoided through the use of labour-only contracting,
sub-contracting, or home-working arrangements, or through apprenticeship schemes where there
is no real intent to impart skills or provide regular employment, nor shall any such obligations be
avoided through the excessive use of fixed-term contracts of employment.
ETI 9. No harsh or inhumane treatment is allowed
Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal Yes (2)
abuse or other forms of intimidation shall be prohibited.
(2) The Code of Ethics was drafted in a single text, with no subdivisions such as items and chapters. So there is no relationship
of shapes of the items under this point with the text in question.
SMETA Extra Sections for 4 Pillar Audit:

Environment Section
10B.4. Compliance Requirements Yes

10B4.1 Suppliers as a minimum should meet the requirements of local and national laws related to
environmental standards.
10B4.2.Where it is a legal requirement, suppliers must be able to demonstrate that they have the
relevant valid permits including for use and disposal of resources e.g. water, waste etc.
10.B4.3. The supplier shall be aware of their end client’s environmental standards/code requirements
and have a system in place to monitor their performance against these.
10B4. Guidance for Observations
10B4.4. Suppliers should have completed the appropriate section of the SAQ and made it available to
the auditor.
10B4.5. Suppliers should have an environmental policy, covering their environmental impact, which is
communicated to all appropriate parties, including its own suppliers.
10B4.6. Suppliers shall be aware of the significant environmental impact of their site and its
processes.
10B4.7. The site should measure its impacts, including continuous recording and regular reviews of
use and discharge of natural resources e.g. energy use, water use (see 4-pillar audit report and audit
checks for details).
10B4.8. Suppliers shall seek to make continuous improvements in their environmental performance.
10B4.9. Suppliers shall have available for review any environmental certifications or any
environmental management systems documentation
10B4.10. Suppliers should have a nominated individual responsible for co-ordinating the site’s efforts
to improve environmental performance.
10B.4.11. Has the site recently been subject to (or pending) any fines/prosecutions for noncompliance
to environmental regulations.
Business Practices Section
10C. Guidance for Observations Yes

10C.1. Suppliers should have completed the appropriate section of the SAQ and have made it
available to the auditor.
10C.2. The supplier should have received and acknowledged- preferably in writing – the Business
Practices policy of the auditor/audit company.
10C.3. Suppliers shall seek to conduct their business ethically without bribery, corruption, or any type
of fraudulent Business Practice.
10C.4. Suppliers shall be aware of any applicable laws, their end client’s Business Practices
standards/code requirements and have a system in place to monitor their performance against these.
10C.5. Supplier should have a Business Practices policy concerning bribery, corruption, or unethical
Business Practice. This should be clearly communicated to all relevant parties.
10C.6. Suppliers should have a designated person responsible for implementing standards
concerning Business Practices
10C.7. Suppliers should have a transparent system in place for confidentially reporting, and dealing
with unethical Business Practices without fear of reprisals towards the reporter
10C.8. Suppliers should ensure that the staff whose job roles carry a higher level of risk in the area of
ethical Business Practice e.g. sales, purchasing, logistics are trained on what action to take in the
event of an issue arising in their area.
Photo Form
General View Factory View Final Product Storage
Steam boiler Steam boiler wood (fuel) Risk Management
Emergency meeting point Emergency door. Exhaust system for chemicals.

Non Conformity nr 3.1
Work platform height. Device for first aid Waste Management
Non Conformity nr 3.3
Protection equipment danger zone Protection equipment danger Electric risk - personal protective
zone uniform
Your feedback on your experience of the SMETA audit you have observed is extremely valuable.
It will help to make improvements to future versions.
You can leave feedback by following the appropriate link to our questionnaire:
Click here for A & AB members:

http://www.surveymonkey.com/s.aspx?sm=riPsbE0PQ52ehCo3lnq5Iw_3d_3d
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Supplier name: Fasa América Latina Participações Societárias S/A

Site country: Brazil

Sedex Company Reference: (only available on Sedex System) S000000087053

Sedex Site Reference: (only available on Sedex System) P000000192392

Trade Union Brand Owner

Multi–stakeholder Combined Audit (select all that apply) SGS

Auditor Reference Number: (If applicable) --

0 Management systems and code 1

1 Employment Freely Chosen - - -

3 Safety and Hygienic Conditions 8 1

5 Wages and Benefits - - -

9 Harsh or Inhumane Treatment - - -

10A Entitlement to Work - - -

10B2 Environment 2–Pillar

10B4 Environment 4–Pillar 1 - -

10C Business Ethics

C: Number of Auditor Days Used: 1 auditor x 1,5 days = 1,5 MD

D: Audit type: Full Initial

E: Was the audit announced? Announced

F: Was the Sedex SAQ available for review? Yes

G: Any conflicting information SAQ/Pre-Audit Yes

H: Auditor name(s) and role(s): Ubiratan Schuch Pinto – Lead Auditor

I: Report written by: Ubiratan Schuch Pinto – Lead Auditor

J: Report reviewed by: Elaine C. Perocco Dias

K: Report issue date: August 20, 2015

L: Supplier name: Fasa América Latina Participações Societárias S/A

M: Site name: Farfri Indústria e Comércio Ltda.

N: Site country: Brazil

O: Site contact and job title: Fabricio Domeneck Quality Assistant

Site phone: + 55 54 3435 6400

Site e–mail: fabricio.d@faros.ind.br

R: Products/Activities at site; example: garment Flour viscera and bird feathers

S: Audit results reviewed with site Yes

T: Who signed and agreed CAPR Simone Laste Manager

U: Did the person who signed CAPR have yes

V: Present at closing meeting (Please state Simone Laste Manager

W: What form of worker representation /union Union (name)

X: Are any workers covered by CBA Yes

Y: Previous audit date: August 11 and 12, 2015

Z: Previous audit type: SMETA 2–pillar SMETA 4–pillar Other

Full Follow–Up Audit

*If other, please define:

A: Standard/Contracted work hours: Legal maximum: Factory area Yes

B: Legal Overtime hours: Legal maximum: 2 hours per day Yes

C: Legal age of employment: Legal minimum: 20 years old

10B4: Environment 4–Pillar

10C: Business Ethics

Management Worker Representatives

Audit attendance Senior management Worker Committee Union representatives

A: Present at the opening meeting? Yes No Yes No Yes No

B: Present at the audit? Yes No Yes No Yes No

C: Present at the closing meeting? Yes No Yes No Yes No

D: If Worker Representatives were not --

G: Site function: Agent

H: Month(s) of peak season: There is no peak season.

K: Attitude of workers committee/union reps:

A: Do all workers (including migrant workers) Yes