Sedex Audit Report - 2020-2021 Jamuna Fashion Wears LTD

Version 6.
1
Sedex Audit Reference:2020BDZAA411484214 • Sedex Members Ethical Trade Audit ReportVersion 6.1
Audit Details
Sedex Company ZC:407501248 Sedex Site Reference: ZS:407520134
Reference: (only available on Sedex
(only available on Sedex System)
System)
Business name Jamuna Fashion Wears Ltd.

(Company name):
Site name: Jamuna Fashion Wears Ltd.
Site address: Plot No-75, Road no-5, Country: Bangladesh
(Please include full Block-5, Section -2,
address) Rupnagar I/A, Mirpur,
Dhaka 1216,
Bangladesh.
Site contact and job Md. Mizanur Rahman(Manager-HR & Compliance)
title:
Site phone: +88 01857370475 Site e–mail: mizan@shamsgroupbd.com,
hhca@shamsgroupbd.com,
SMETA Audit Pillars: Labour Health & Environment Business Ethics
Standards Safety (plus 4-pillar
Environment 2-
Pillar)
Date of Audit: 17th August, 2020
Audit Company Name & Logo:
Report Owner (payer):

(Jamuna Fashion Wears Ltd.)
Audit Conducted By
Affiliate Audit Purchaser

Company Retailer
Brand owner NGO Trade Union
Multi– Combined Audit (select all that apply)

stakeholder
Audit company:Accordia Global Compliance GroupReport reference:JFWL17082020Date:17.08.2020 2

Audit Content:
(1) A SMETA audit was conducted which included some or all of Labour Standards, Health &
Safety, Environment and Business Ethics. The SMETA Best Practice Version 6.1 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. Any
deviations from the SMETA Methodology are stated (with reasons for deviation) in the
SMETA Declaration.
(2) The audit scope was against the following reference documents
2-Pillar SMETA Audit
•ETI Base Code
•SMETA Additions
•Universal rights covering UNGP
•Management systems and code implementation,
•Responsible Recruitment
•Entitlement to Work & Immigration,
•Sub-Contracting and Home working,
4-Pillar SMETA
•2-Pillar requirements plus
•Additional Pillar assessment of Environment
•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.

SMETA Declaration
I declare that the audit underpinning the following report was conducted in accordance
with SMETA Best Practice Guidance and SMETA Measurement Criteria.
(1) 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.
(2) Any Non-Compliance against customer code alone 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): During audit
facility management was transparent and support was very prompt.
Auditor Team (s) (please list all including all interviewers):

Lead auditor: Md. Ripon Uddin APSCA number: RA21701540
Lead auditor APSCA status:Registered Auditor
Team auditor: Md. Shahinul Islam APSCA number: RA21701537
Interviewers: Shimul Kar APSCA number: ASCA21704639
Report writer: Md. Ripon Uddin

Report reviewer: Jeffrey Hawkins
Date of declaration: 17th August, 2020
Note: The 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.

Sedex Audit Reference:2020BDZAA411484214Sedex Members Ethical Trade Audit ReportVersion 6.1
Summary of Findings
Area of Non–Conformity Findings
Issue (Only check box when there is a non– Record the number (note to auditor, summarise in as few words as
(please click on the issue title to go direct conformity, and only in the box/es where the of issues by line*: possible NCs, Obs and GE)
to the appropriate audit results by clause) non–conformity can be found)
Note to auditor, please ensure that when issuing
the audit report, hyperlinks are retained. ETI Base Additional Customer NC Obs GE
Local Law
Code Elements Code
0A Universal Rights covering UNGP 01 00  During the documentation review and

management interview it was noted the
facility has not yet declared Policy
regarding Universal Rights Covering
UNGP (UN Guiding Principles).
(Observation)
 Summary of Good Example None
0B Management systems and 01 00 01  During documentation review and

code implementation management representative interview it
was observed that the facility
management has not communicated
ETI base code with its suppliers (NC)
 The facility has an internal audit team to

conduct internal audit to maintain the
standard and audit is conducted in
every three months (Good example )
 Summary of Observation: None
1. Freely chosen Employment 00 00 00  Summary of Non-Compliance: None

 Summary of Good Example: None
2 Freedom of Association 00 00 00  Summary of Non-Compliance: None
3 Safety and Hygienic Conditions 05 00 00

 During documentation review it was
observed that the facility management
is maintaining safety record book but it
was not found updated and not
displayed on Safety Board (NC)
 It was noted through document review

and management interview that factory
is maintaining injury/accident register in
the medical room. But it was noted they
did not submit the injury/accident
register to the labor inspector as
specified in law. They shared
injury/accident register on 24th
December, 2019 (NC)
 Interviewed fire fighters were not

conversant about the use of different
type of fire fighting equipment kept in
the factory. Interviewed first aiders were
not conversant about the use of
different type of first aid equipment kept
in the first aid boxes (NC)

 During the facility tour it was noted that

the facility is providing canteen facility
to worker and canteen shop was found
functional but it was not found well
equipped with enough food supply.
(NC)
 During the facility tour aisles marking &

emergency arrow were faded in 1st,
2nd 3rd, 4th and 5th floors (NC)
4 Child Labour 00 00 00  Summary of Non-Compliance: None
5 Living Wages and Benefits 00 00 01  The facility is giving attendance bonus

for full attendance BDT 200 and 350
(Good Example)
6 Working Hours 00 00 00  Summary of Non-Compliance: None
7 Discrimination 00 00 00  Summary of Non-Compliance: None

8 Regular Employment 00 00 00  Summary of Non-Compliance: None
8A Sub–Contracting and 00 00 00  Summary of Non-Compliance: None

Homeworking


9 Harsh or Inhumane Treatment 00 00 01  Summary of Non-Compliance: None
10A Entitlement to Work 00 00 00  Summary of Non-Compliance: None
10B2 Environment 2-Pillar 00 00 00  Summary of Non-Compliance: None

10B4 Environment 4–Pillar 00 00 03  Not applicable
10C Business Ethics 00 00 00

 Not applicable
General observations and summary of the site:
Accordia Global Compliance Group conducted SMERTA/SEDEX audit at Jamuna Fashion Wears Ltd. was established and started operation in 1991 here. It is
located at Plot No.-57, Road-No. 05, Block-K, Section-2, Rupnagor I/A, Mirpur, Dhaka-1216, Bangladesh. It‟s about ½ kilometre from Mirpur She-E-Bangla
Stadium and It is about 13 KM away from Hazarat Shah Jalal International Airport Dhaka.
The facility is operating its operation in one six storied building. Building structural approving authority is RAJUK-Rajdhani Unnayan Kartripakka- (Capital
Development Authority of Bangladesh) and the building is approved for Industrial purpose.Accord conducted the building structural assessment and
construction quality was found good as there were no visible defects identified during the audit. The facility achieved Yellow Category in building structural
assessment audit.
Factory total fire license space is 81, 250 Square feet. The facility does not have peak and off peak seasons in production operation. The facility is not
operating any shifting in their production operation. This factory is a 100% export oriented Woven Garments manufacturing company.
The main production processes are listed as follows –Cutting-Sewing-Finishing-Packing and Export. Finishing & total production capacity of the factory is
300,000 pcs/month.
Total number of worker is 822 currently working in the factory, which includes 575 female employees and 247 male employees. Child care room is located at
ground floor and medical rooms is located at first floor of the building one were found well organised.
Boilers was found separated from production building, Generators, and Compressor are located at ground floor in the building.
The facility has elected Participation Committee (PC). Workers were also found to be satisfied with the work environment in the factory. Housekeeping in the
factory was good and overall health and safety conditions were satisfactory.
- Legal minimum is given to 100% of workers. Overtime payment is 200% of basic wage.
- Company has well documented policies and procedures complying with all legal requirements and ETI Code elements. Regular trainings are provided to
employees and records are maintained.
- There is good communication between workers and management. Management was found committed to provide good work environment to its

employees.
*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.

Site Details
Site Details
A: Company Name: Jamuna Fashion Wears Ltd.
B: Site name: Jamuna Fashion Wears Ltd.
C: GPS location: GPS Address: Plot No.-57, Latitude: 23.822350

(If available) Road-No. 05, Block-K, Section- Longitude: 90.365417
2, Rupnagor I/A, Mirpur,
Dhaka-1216
D: Applicable business and other BGMEA:

legally required licence numbers and Registration No: 869
documents, for example, business Issued by BGMEA
license number, liability insurance, any Valid Till: 31st December, 2020
other required government inspections
Group Insurance:
Reg. No: 245
Issued by: BGMEA 869
Valid Till: 31st December, 2020
Factory License:
License Number: 8558/Dhaka
Valid till 30th June, 2020
Category-I
Applied for renewal dated on 22nd June, 2020
Fire License:
License Number: DD/Dhaka/21325/2009
Valid till: 30th June, 2021
Issued by: Bangladesh Fire Service and Civil
Defense, Dhaka, Bangladesh
Total coverage 81, 250 square feet
Trade License:
License number: 44716
Valid Till: 30th June, 2021
Issued byDhata Uttar City Corporation , Bangladesh
Certificate of Incorporation:
C-20861/91
Issued by Deputy Registrar of Joint Stock Companies & Firms,
Bangladesh
Bond License:
License. No: 970/CUS-SBW/1991
Valid till: 23rd November, 2021
Bangladesh Energy Regulatory Commission:

Certificate No. LWC-1633
Reference No. BERC/Power/LWC-1633/1293/6017
Valid up 22nd September,2020

Boiler License:
Boiler No. Ba: Bo: 8209, Rating-83, valid 3rd March, 2021
Boiler Operator:Md, Nurul Afsar
Certificate number: 4826/2015
EPB:BD00927,
Issued by Export Promotion Bureau
Import License: Ba,125290
Export License: Ra 06412
TIN: 166369482247
E: Products/Activities at site, for Manufacturer of Woven Garments (Tops &Bottoms Garments)

example, garment manufacture,
electricals, toys, grower, cutting,
sewing, packing etc
F: Site description: Full description of the building(s):

(Include size, location, and age of site.
Also, include structure and number of Jamuna Fashion Wears Ltd.was established and started
buildings) operation in 1991 here. It is located at Plot No.-57, Road-No. 05,
Block-K, Section-2, Rupnagor I/A, Mirpur, Dhaka-1216,
Bangladesh and ¼ kilometre from Mirpur She-E-Bangla Stadum
and It is about 13 KM away from Hazarat Shah Jalal International
Airport Dhaka.
The facility is operating its operation one six storied building.

Building structural approving authority is RAJUK-Rajdhani
Unnayan Kartripakka- (Capital Development Authority of
Bangladesh) and the building is approved for Industrial
purpose.Accord conducted the building structural assessment
and construction quality was found good as there were no
visible defects identified during the audit.The facility achieved
Yellow category in building structural assessment audit.
The layout of the factory buildings is as follows:
Building 1: main production Building:-
Floor Operation / Activity Remarks, if any

observed
Ground Generator, Sub-station,
Floor Child Care room,
Compressor, Fabrics store,
Rejection store, Fire pump
house and Accessories.
1st Floor Finishing, Finished goods,
Medical room, spot
removing room and Admin
office
2nd Floor Sewing, Maintenance and
Inspection room
3rdFloor Sewing, Maintenance,

Needle issue room, and

Inspection room
4thFloor Sewing, Maintenance
Sample and CAD room
5thFloor Office , Fusing and Cutting
Section
Roof top Prayer room, Worker Dining&
Canteen and 70% free
space
Building 2: Boiler Building:-

Floor Operation / Activity Declared on Layout
observed
Ground Boiler room
Floor
Roof 100% free
top
Building Approval
 Floor Layout taken for all floors of the facility from Chief
Inspector Factory labor department.
 Approved for Industrial purpose.
 Fire license of the factory covers all floors.
 Building approving authority is RAJUK-Rajdhani Unnayan
Kartripakka- (Capital Development Authority of
Bangladesh)
For below, please add any extra rows if appropriate.
F1: Visible structural integrity issues (large cracks) observed?

Yes
No
F2: Please give details: No visible structural integrity issues (large

cracks) was observed during the facility visit.
F3: Does the site have a structural engineer evaluation?

Yes
No
F4: Please give details:
Building structural Assessment: -Accord conducted building

structural assessment, Fire safety and Electrical Safety. Alliance
Details given in below:-
Inspection Last Inspection Date Present Status
Standard
Building Conducted on 6th May, The facility
structural 2014(initial) and last completed 95%
assessment follow-up was retrofitting.
conducted 15th July,
2019

Electrical Conducted on 14th The facility

Safety May, 2014(initial) and corrected 100% in
assessment last follow-up was Electrical Safety
by Accord conducted on 2019 part
(August-December)
Fire Safety Conducted on 14th The facility
assessment May, 2014(initial) and completed 96% in
by Accord last follow-up was Fire Safely part
conducted on 2019
(August-December)
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: The facility does not have any peak and off peak seasons in
(if applicable) process operation.
I: Process overview: Production processes- Cutting-Sewing--Finishing-Packing &

(Include products being produced, main Export.
operations, number of production lines,
main equipment used) The factory produces Garments Bottoms Garments
Total production line:- 12 running
Production Capacity:-
Per month production capacity 300,000 pcs/month
Chemical use: Spot Lifter 833, diesel for generator and machine
oil
List of Machinery: Cutting Machine, Plain Machine-, Button Hole,

Button Stitch, Fit of the arms, Back Tape, Rib Cutter, Vacuum
Ironing. Table, Over Lock 4 Thread, Flat lock machine, Bartek
machine, Fit of the arm, Thread Sucker, P/M.D.KANSAI, Steam
Irons, Fusing machine, Needle Detector machine, Phull Tas
machine, Knitting Machine, CAD Machine, Cutting Lay
Machine.
J: What form of worker representation Union (name)

/ union is there on site? Worker Committee (Elected Workers Participation
Committee)
Other (specify)
None
K: Is there any night production work Yes

at the site? No

L: Are there any on site provided Yes

worker accommodation buildings e.g. No
dormitories L1: If yes, approx. % of workers in on site accommodation
M: Are there any off site provided Yes

worker accommodation buildings No
M1: If yes, approx. % of workers
N: Were all site-provided Yes

accommodation buildings included in No
this audit N1: If no, please give details

Audit Parameters
A: Time in and time out A1: Day 1 Time in: 8:10am A3: Day 2 Time in: A5: Day 3 Time in:
A2: Day 1 Time out:4:30pm A4: Day 2 Time out: A6: Day 3 Time out:
B: Number of auditor 3auditors in one day (3 man-day)

days used:
C: Audit type: Full Initial

Periodic
Full Follow–up
Partial Follow–Up
Partial Other
If other, please define
D: Was the audit Announced

announced? Semi – announced: Window detail: Three weeks
Unannounced
E: Was the Sedex SAQ Yes

available for review? No
E1: If No, why not?
F: Any conflicting Yes

information SAQ/Pre- No
Audit Info to Audit If Yes, please capture detail in appropriate audit by clause
findings?
G: Who signed and Md. Mizanur Rahman(Manager-HR & Compliance)

agreed CAPR
(Name and job title)
H: Is further information Yes

available No
(If yes, please contact audit
company for details)
I: Previous audit date: 29th July, 2019
J: Previous audit type: It was 2 pillar audit
K: Were any previous Yes No

audits reviewed for this
audit N/A

Audit attendance Management Worker Representatives
Senior Worker Committee Union representatives

management 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 During opening and closing meeting Worker representatives were
present please explain reasons why present. PC vice president is Ms. Shapla (Gr. Sewing Machine
(only complete if no worker reps Operator)
present)
E: If Union Representatives were not N/A as No union found in factory.

present please explain reasons why:
(only complete if no union reps
present)

Worker Analysis
The term "migrant worker" refers to a person who is engaged or has been engaged in a remunerated activity in a country of which they are not a national or
permanent resident or has purposely migrated on a temporary basis to another in-country region to seek and engage in a remunerated activity.
Worker Analysis
Local Migrant*
Total
Permanent Temporary Agency Permanent Temporary Agency Home workers
Worker numbers – 0 0 0 0 0 0
247 247
Male
Worker numbers – 0 0 0 0 0 0
575 575
female
Total 822 0 0 0 0 0 0 822
Number of Workers 0 0 0 0 0 0
13 13
interviewed – male
Number of Workers 0 0 0 0 0 0
29 29
interviewed – female
Total – interviewed 0 0 0 0 0 0
42 42
sample size

A: Nationality of Management Bangladeshi
B: Please list the nationalities of all Nationalities: Bangladeshi Was the list completed during peak season?
workers, with the three most common B1: Nationality 1: 100% worker Bangladeshi Yes
nationalities listed first. B2: Nationality 2: ________ No
Please add more nationalities as applicable to B3: Nationality 3: ________
site. Add more rows if required.
If no, please describe how this may vary during
peak periods: Not applicable as the facility does
not have any peak and off peak seasons.
C: Please provide more information for C: approx 100% total workforce: Nationality 1 Bangladeshi
the three most common nationalities. C1: approx % total workforce: Nationality 2 ________
C2: approx % total workforce: Nationality 3 ________
D: Worker remuneration D: 0% workers on piece rate

(management information) D1: _______% hourly paid workers
D2: __100__% salaried workers
Payment cycle:
D3: _______% daily paid
D4: _______% weekly paid
D5: __100_ % monthly paid
D6: _______% other
D7: If other, please give details

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: Group Interview done in 6Groups of 5 (30)

(Please specify number and size of groups. Please see SMETA Best
Practice Guidance and Measurement Criteria. If the auditor was
not able to follow the BPG, please state within the declaration)
D: Number of individual interviews D1: Male: 5 D2: Female: 7

(Please see SMETA Best Practice Guidance and Measurement
Criteria)
E: All groups of workers are included in the scope of this Yes

audit such as; Direct employees, Casual and agency No
workers, Workers employed by service providers such as
security and catering staff as well as workers supplied by If N, please give details
other contractors.
Note to auditor: please record details of migrant /agency/contractor
workers in section 8 – Regular Employment, under Responsible
Recruitment
F: Interviews were done in private and the confidentiality Yes

of the interview process was communicated to the No
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? No soap in washroom and to increase Eid
vacation.
I: What did the workers like the most about working at this During interview workers were found satisfied
site? about facilities provided by the company.
J: Any additional comment(s) regarding interviews: During interview was observed that workers are
satisfied with working environment, on time
salary, medical facility, Eid gift, yearly picnic,
Rainwater harvesting, Using Led light and
management.
K: Attitude of workers to hours worked: During interview workers were found satisfied
with facilities provided by the company.
L. Is there any worker survey information available?

Yes
No
L1: If yes, please give details:
M: 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
Workers‟ attitude was positive. It was noted during the worker interview that workers are not afraid of talking.
They were able to comment about their regular meetings like H&S, PC and Fire related training.
During the interview workers found satisfied towards the management and the benefits they are getting. No
objection or complaints were found.
N: Attitude of worker‟s committee/union reps:

(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
Elected PC members found well aware about workers‟ rights. Frequency of PC meeting is monthly. PC
members concerned about compensation policy and open door policy, which is declared by
management.
O: Attitude of managers:
(Include attitude to audit, and audit process. Both positive and negative information should be included)
Managers were found to be well aware about the legal requirements and the ETI Code elements.
Management had very positive attitude towards the audit process and they wanted to improve their social
compliance systems and practices learning from the audit findings.

Audit Results by Clause

0A: Universal Rights covering UNGP
0A: Universal Rights covering UNGP
(Click here to return to summary of findings)
0.A. Guidance for Observations

0.A.1 Businesses should have a policy, endorsed at the highest level, covering human rights impacts and
issues, and ensure it is communicated to all appropriate parties, including its own suppliers.
0.A.2 Businesses should have a designated person responsible for implementing standards concerning
Human rights
0.A.3 Businesses shall identify their stakeholders and salient issues.
0.A.4 Businesses shall measure their direct, indirect, and potential impacts on stakeholders (rights holders)
human rights.
0.A.5 Where businesses have an adverse impact on human rights within any of their stakeholders, they shall
address these issues and enable effective remediation.
0.A.6 Businesses shall have a transparent system in place for confidentially reporting, and dealing with
human rights impacts without fear of reprisals towards the reporter.
Note for auditors and readers. ThisisnotafullHuman Rights Assessment,but instead a check on the
business‟s implementation of processes to meet their Universal rights covering UNGP responsibilities.
Current Systems and Evidence Examined

To complete ‘current systems’ Auditorsexaminepoliciesandwrittenproceduresinconjunction withrelevantmanagers, 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 facility does not have a policy, endorsed at the highest level, covering human rights
impacts and issues.
But the facility management assigned Md. Mizanur Rahman(Manager-HR & Compliance)as responsible for
implementing standards concerning Human rights. They identified their stakeholders and salient issues. The
facility management measures their direct, indirect, and potential impacts on stakeholders‟ human rights.
The facility management implemented policy and procedure to address any adverse impact on human
rights within any of their stakeholders and how to enable effective remediation of these issues. Management
has a transparent system in place for confidentially reporting, and dealing with human rights impacts without
fear of reprisals towards the reporter.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Details:
-Company policy and procedure
-Factory rules
-Employee handbook
-Management and worker interview
-Contracts for security guards
A: Policy statement that expresses commitment to Yes

respect human rights? No

Please give details: The facility has not yet declared

Policy regarding Universal Right Covering UNGP (UN
Guiding Principles).
B: Does the business have a designated person Yes

responsible for implementing standards No
concerning Human Rights? Please give details:
1. Mr. Rafiquel Islam (EED)
2. Md. Mizanur Rahman (Manager-HR &
Compliance)
3. Mr. Ponir Hossain (Sr. Officer Compliance)
4. Mr. Ariful Isalm ((Fire Safety Officer)
5. Mr. Sonia Khatun (Welfare Officer)and
6. Ms. Tania Sultana (Officer HR & Compliance)
C: Does the businesses have a transparent system Yes

in place for confidentially reporting, and dealing No
with human rights impacts without fear of reprisals Please give details:The businesses have a transparent
towards the reporter? system in place for confidentially reporting, and
dealing with human rights impact without fear of
reprisals towards the reporter
D: Does the business demonstrate effective data Yes

privacy procedures for workers‟ information, No
which is implemented? Please give details:The facility implemented effective
data privacy procedure for worker information
E: Policy statement that expresses commitment to Yes

respect human rights? No
Please give details: The facility has not yet declared
Policy regarding Universal Right Covering UNGP (UN
Guiding Principles).
Findings
Finding: Observation Company NC Objective evidence

observed:
Description of observation: Not applicable
During the documentation review and management interview it was noted the
facility has not yet declared Policy regarding Universal Rights Covering UNGP
(UN Guiding Principles). (Observation)
Local law or ETI/Additional elements / customer specific requirement:

0.A.1 Businesses should have a policy, endorsed at the highest level, covering
human rights impacts and issues, and ensure it is communicated to all
appropriate parties, including its own suppliers.
Comments:
None
Good examples observed:

Description of Good Example (GE): Objective Evidence

Observed:
Measuring Workplace Impact

Measuring Workplace Impact Table
Workplace Impact
A: Annual worker turnover: A1: Last year: 2019 (August- A2: This year: 2020 (January-
Number of workers leaving in last 12 months as a % December) July) 1.9%
of average total number of workers on site over the
2.1
year (annual worker turnover)
B: Current % quarterly (90 days) turnover: During documentation review it was found in last three months
Number ofworkers leaving from the first day of the turnover was 1.5%
90 days period through to the last day of the 90day
period / [(number of employees on the 1st day of
90 day period + number of employees on the last
day of the 90 day period) / 2]
C: Annual % absenteeism: C1: Last year: 2019 (August- C2: This year: 2020 (January-
Number of days lost through job absence in the December) July)-1.6
year /
2.4 %
[(number of employees on 1stday of the year +
number employees on the last day of the year) / 2]
* number available workdays in the year
D: Quarterly (90 days) % absenteeism: During documentation review it was foundabsenteeism 1.02%
Number of days lost through job absence in the employees on 1stquarter of the period.
period /
[(Number of employees on 1st of the period +
Number of employees on the last day of the
period) / 2]
* Number of available workdays in the month
E: Are accidents recorded? Yes

No
Please describe: Govt. prescribed accident register
maintained by facility, Medical officer and Nurse are
responsible to keep record of any kind of accidents. End of the
month responsible Doctor Hayat report to HR and Compliance
F: Annual Number of work related F1: Last year:2019 F2: This year:2020
accidents and injuries per 100 workers:
[(Number of work related accidents and Number: 25 minor injury Number: 19 minor injury
injuries * 100) / Number of total workers]
G: Quarterly (90 days) number of work During documentation review no major accident and injury
related accidents and injuries per 100 were found recorded.
workers:
[(Number of work related accidents and injuries *
100) / Number of total workers]
H: Lost day work cases per 100 workers: H1: Last year: 0 H2: This year: 0
[(Number of lost days due to work accidents and

work related injuries * 100) / Number of total

workers]
I: % of workers that work on average I1: 6 months I2: 12 months

more than 48 standard hours / week in ____0___% workers ___0_____% workers
the last 6 / 12 months:
J: % of workers that work on average J1: 6 months J2: 12 months

more than 60 total hours / week in the ___0____% workers ____0____% workers
last 6 / 12 months:
0: Management systems and Code Implementation

0B: Management system and Code Implementation

0.B.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code.
0.B.2 Suppliers are expected to be operating legally in premises with the correct business licenses and
permissions and to have systems to ensure that all relevant land rights have been complied with
0.B.3 Suppliers shall appoint a senior member of management who shall be responsible for compliance with
the Code.
0.B.4 Suppliers are expected to communicate this Code to all employees.
0.B.5 Suppliers should communicate this code to their own suppliers and, where reasonably practicable,
extend the principles of this Ethical Code through their supply chain.

To complete ‘current systems’ Auditorsexaminepoliciesandwrittenproceduresinconjunction withrelevantmanagers, 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:- Factory has documented policies which prohibit forced labor and supporting procedures
addressing each clause of the ETI Code and legal requirements. All policies and procedures were up to
date, approved by management and complying with the legal requirements. All policies were available to
review.
The management has communicated the policies and procedures to all workers by displaying them on
notice board in local language,
The facility has appointed Md. Mizanur Rahman(Manager-HR & Compliance to implement any changes
and monitor the compliance of factory‟s policies, procedures and practices with the code and applicable
legal requirements.
Facility has not communicated ETI Base Code to its all suppliers.
-ETI Base code displayed

-Trained all worker
-Internal audit documents (Internal is conducting in every three months)
-Client‟s code of conduct at the factory
Any other comments: - A manual was created by the factory which contains all required documents and
all appropriate procedures for meeting the client‟s code of conduct and the legal requirements.
Management Systems:

A: In the last 12 months, has the site been subject to Yes

any fines/prosecutions for non–compliance to any No
regulations? A1: Please give details:No such issue found
during the audit
B: Do policies and/or procedures exist that reduce the Yes

risk of forced labour, child labour, discrimination, No
harassment & abuse? B1: Please give details:
C: If Yes, is there evidence (an indication) of effective Facility declared policies and procedures
implementation? Please give details. complying with buyer‟s requirements, ETI Base
Code and Local Labor law and rules. All policies
and procedures displayed throughout the
organization to communicate with workers. Also
facility included polices and procedure in the
workers training materials.
D: Have managers and workers received training in Yes

the standards for forced labour, child labour, No
discrimination, harassment & abuse? D1: Please give details:Training is provided to the
recruitment committee & other responsible
persons against forced labor policy &
procedure.
Facility has a program and materials used to
train relevant individuals, including all individuals
responsible for the hiring process, on the facility‟s
policies and procedures prohibiting forced or
involuntary labor
E: If Yes, is there evidence (an indication) that training Yes

has been effective e.g. training records etc.? Please No
give details E1: Please give details:Documented training
records verified and cross checked during
management and workers interview.
F: Does the site have any internationally recognised Yes

system certifications e.g. ISO 9000, 14000, OHSAS No
18000, SA8000 (or other social audits). F1: Please give details:The facility does not have
Please detail (Number and date). such type certificates but the buyer conducted
audit based on their own code.
G: Is there a Human Resources manager/department? Yes

If Yes, please detail. No
G1: Please give details:: Facility declared HR
Management system to identify, provide and
track employee-training requirement, for all
employees in the organization, Manager HR &
Compliance is responsible to follow this
procedure & monitor the update status of the
activities.
H: Is there a senior person/manager responsible for Yes

implementation of the code No
H1: Please give details:Md. Mizanur Rahman

(Manager-HR & Compliance)is responsible
I: Is there a policy to ensure all worker information is Yes

confidential? No
I1: Please give details:Documented policy
procedure found in place which declared
details about the confidentiality regarding
employee information, HR Department is
responsible regarding this.
J: Is there an effective procedure to ensure Yes

confidential information is kept confidential? No
J1: Please give details:Documented policy
procedure found in place which declared
details about the confidentiality regarding
employee information, HR Department is
responsible regarding this.
K: Are risk assessments conducted to evaluate policy Yes

and procedure effectiveness? No
K1: Please give details:Risk assessment displayed
in notice board to communicate to workers.
L: Does the facility have a process to address issues Yes

found when conducting risk assessments, including No
implementation of controls to reduce identified risks? L1: Please give details:Declared risk assessment
covered all process of the facility. Besides that,
management reviews risk assessment regularly
and if anything raised concerned person is
responsible to report to concerned department
head and compliance department.
M: Does the facility have a policy/code which require Yes

labour standards of its own suppliers? No
M1: Please give details:Documented Policy
procedure manual found in place to cover
various international code (i.e. SMETA, ETI, WRAP,
Local Labor Law and Buyers‟ COC).
Land rights
N: Does the site have all required land rights licenses Yes
and permissions (see SMETA Measurement Criteria)? No
Details The facility management purchased the
factory land in 1990 and the factory building is
their own building. The land is registered with the
name of Jamuna Fashion Wears Ltd.
O: Does the site have systems in place to conduct Yes

legal due diligence to recognize and apply national No
laws and practices relating to land title? O1: Please give details: the facility has systems in
place to conduct legal due diligence to
recognize and apply national laws and
practices relating to land title

P: Does the site have a written policy and procedures Yes

specific to land rights. No
If yes, does it include any due diligence the company P1: If yes, how does the company obtain FPIC:
will undertake to obtain free, prior and informed Documented records available site have a
consent, (FPIC) even if national/local law does not written policy and procedures specific to land
require it rights.
Q: Is there evidence that facility / site compensated Yes

the owner/lessor for the land prior to the facility being No
built or expanded. Q1: Please give details:land related all required
documents verified to ensure facility
compensated the previous owner of the land.
Yes
R. Does the facility demonstrate that alternatives to a No
specific land acquisition were considered to avoid or R1: Please give details:All required documents
minimize adverse impacts? verified to ensure facility compensated the
previous owner of the land.
S: Is There any evidence of illegal appropriation of land Yes

for facility building or expansion of footprint. No
S1: Please give details: No such evidence found
of illegal appropriation of land for facility
building or expansion of footprint
Non–compliance:
1. Description of non–compliance: Objective evidence

NC against ETI/Additional Elements NC against Local Law observed:
NC against customer code: (where relevant please
add photo numbers)
During documentation review and management representative interview it was
observed that the facility management has not communicated ETI base code
with its suppliers. Through documentation
review and
Local law and/or ETI requirement: management interview
ETI Requirement:-0.B.2 Suppliers are expected to be operating legally in

premises with the correct business licenses and permissions and to have systems
to ensure that all
Recommended corrective action: The facility management informed they would

communicate ETI base with all suppliers.
Observation:
Description of observation: Objective evidence

observed:
Local law or ETI requirement:
Comments:

Good Examples observed:
Description of Good Example (GE): Objective evidence

observed:
1. The facility has an internal audit team to conduct internal audit to Through documentation
maintain the standard and audit is conducted in every three months. review and
management interview

1: Employment is Freely Chosen

1: Freely Chosen Employment
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.

out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal
Current systems:-The facility introduced forced labor policy during audit and it was available to review.
During worker interviews and review of personal files of workers it was found that the factory is not retaining
any original identity papers or asking the worker to lodge deposits and they are free to leave the job giving
one month notice.
The appointment letter includes all terms & conditions of employment and a statement confirming that the
worker has read and understood the employment terms and accepts to join the factory on voluntary basis.
The appointment letter is signed both by the factory and the worker. Copy of the employment letter is
issued to the workers. There is a system for worker to bring national ID card and school certificate to prove
age, and photo copies are kept in the personnel file and original copies are given back to worker. The
facility provides worker handbook to all workers on joining.
During management and worker interviews it was found that the factory prohibits use of forced and
bonded labor.
While recruiting, the workers are required to submit the application against which they are interviewed and
tested for their skill by the concerned department. If the worker qualifies in interview and skill test the worker
is explained the terms and conditions of employment. If the worker agrees to the employment terms the
appointment letter is signed both by the factory and the worker and a copy of letter is issued to the worker.
Overtime is voluntary and workers are free to leave once the regular shift hours are completed. This was
verified during worker interview.
Details:
-Personnel files
-Resignation letter
-Factory rules
-Employee handbook
-Management and worker interview
-Contracts for security guards
A: Is there any evidence of Yes

retention of original documents, No

e.g. passports/ID‟s A1: If yes, please give details and category of workers affected:
B: Is there any evidence of a loan Yes

scheme in operation No
B1: If yes, please give details and category of worker affected:
C: Is there any evidence of Yes

retention of wages /deposits No
C1: If yes, please give details and category of worker affected:
D: Are there any restrictions on Yes

workers‟ freedom to terminate No
employment? D1: Please describe finding:
E: If any part of the business is UK Yes

based or registered there & has a No
turnover over £36m, is there a Not applicable
published a „modern day slavery E1: Please describe finding:
statement?
F: Is there evidence of any Yes

restrictions on workers‟ freedoms to No
leave the site at the end of the F1: Please describe finding:
work day?
G: Does the site understand the Yes

risks of forced / trafficked / No
bonded labour in its supply chain Not applicable
G1: If yes, please give details and category of workers affected:
H: Is the site taking any steps taking Yes

to reduce the risk of forced / No
trafficked labour? H1: Please describe finding:
Non–compliance:


NC against ETI NC against Local Law: NC against customer observed:
code: (where relevant please
add photo numbers)
Local law and/or ETI requirement
Recommended corrective action:
Observation:

observed:
Comments:
Description of Good Example (GE): Objective evidence

observed:
Nil

2: Freedom of Association and Right to Collective Bargaining are Respected

2: Freedom of Association and Right to Collective Bargaining are Respected
(Click here to return to Key Information)
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: -The facility doesn‟t have any worker union. During review of documents it was found that
Worker Participation Committee meetings are held once every two months. The minutes are posted on
notice board in local language in order to communicate to the workers. The worker‟s complaint/suggestion is
recorded in a register.
Factory does not have trade union. Factory has introduced alternate means to have good communication
with workers. The initiatives include:
Formation of Worker Participation Committee

 Installation of complaint boxes
 Open door policy
Election Date: 22nd August, 2019

PC Meeting Interval In every two months and last was held on23rd June, 2020. Also sent minutes to labor
inspector.
Participation Committee details:

The facility has elected Participation Committee (PC) and the president is Mohammad Mr. Saibbir Ahmed
(Director) and vice president Ms. Shapla (Gr. Sewing Machine Operator)with a total of 14 members, out of
which 4 members are management staff and 10 workers. PC was formed through election dated on 22nd
August, 2019 Last meeting was held on 23rd June, 2020
Facility has installed Suggestion/Complaint boxes at locations where workers can use them in privacy (like
inside toilets, etc.) and boxes are opened every Thursday checked and found ok.
Factory has Open Door Policy encouraging workers to directly approach the top management in case they
have any concern that they would like to share. The facility introduced policy mentioning meeting will be
held in very two months.
 List of Participation Committee (PC) Members

 PC Meeting Agenda & Minutes

 Workers Complaint/Suggestion Register
A: What form of worker Union (name)

representation/union is there on Worker Committee (Elected PC)
site? Other (specify)
None
B: Is it a legal requirement to Yes

have a union? No
Legal requirementis to have registered committee/union
C: Is it a legal requirement to Yes

have a worker‟s committee? No
D: Is there any other form of Yes

effective worker/management No
communication channel?(Other D1: Please give details:
than union/worker committee e.g.
H&S, sexual harassment) H&S Committee, Grievance committee, Participation Committee,
Canteen Committee, Maintenance Committee, Recruitment Committee.
D2: Is there evidence of free elections?

Yes
No
E: Does the supplier provide Yes

adequate facilities to allow the No
Union or committee to conduct E1: Please give details:The supplier provide adequate facilities to allow
related business? the committees to conduct related business.
F: Name of union and union The facility does not F1: Is there evidence of free elections?
representative, if applicable: have any union Yes No N/A
G: If there is no union, is there a The facility have G1: Is there evidence of free elections?
parallel means of consultation elected Participation Yes No N/A
with workers e.g. worker Committee(PC)
committees?
H: Are all workers aware of who Yes No Yes during worker interview it was noted that
their representatives are? workers are aware about their representatives.
Verified during workers interview.
I: Were worker representatives Yes No I1: Date of last election: 22nd August, 2019and the
freely elected? facility is in the process of PC election.
J: Do workers know what topics Yes No

can be raised with their Yes during worker interview it was noted that worker can know through
representatives? notice board/PA systems if anything raised with in their representative.
Verified during workers interview.

K: Were worker Yes No

representatives/union If Yes, please state how many:one group of 5
representatives interviewed?
L: Please describe any evidence The facility introduced policy mentioning meeting will be held in very two
that union/worker‟s committee is months.
effective?
Specify date of last meeting; topics Meeting minutes displayed in Notice board and also facility
covered; how minutes were communicated PC Meeting decision through PA System. Workers
communicated etc. confirmed in interview about PC meeting
Interval of Meeting: In every 2 months. Last meeting was held on 23rdJune,

2020
M: Are any workers covered by Yes No

Collective Bargaining
Agreement (CBA)?
If Yes, what percentage by M1: ____% workers covered by M2: ____% workers covered by worker
trade Union/worker Union CBA rep CBA
representation
M3: If Yes, does the Collective Yes

Bargaining Agreement (CBA) No
include rates of pay?

Non–compliance:
1. Description of non–compliance: Objective evidence observed:

NC against ETI NC against Local Law NC against (where relevant please add photo
customer code: numbers)
Local law and/or ETI requirement:
Observation:
Description of observation: Objective evidence observed:
Comments:
Description of Good Example (GE): Objective evidence observed:

3: Working Conditions are Safe and Hygienic

3: Working Conditions are Safe and Hygienic
ETI
3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing 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 & 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.

Current systems: -During review of Health & Safety documents it was found that all documents reviewed
comply with all applicable laws and regulations and everything is explained in the health and safety policy.
Factory has formed Health & Safety Committee comprised of members selected from both management and
workers. The committee was selected by elected PC. This Committee meets regularly to review the health &
safety conditions in the factory. Any concerns raised during the meeting are resolved and actions taken are
followed up in a subsequent meeting. Dr. Khaled Ibne Ashraf, Nurse-Asma Begum & Mr. Ariful Islam (Fire Safety
Officer)are assigned as the Health and Safety Representative and coordinates the activities of the Health &
Safety Committee.
Total committee members are 10, from management 5 and from worker 5. Last meeting was held on 16th July,
2020
Factory has conducted Health & Safety Risk Assessment for all processes, including Boiler, Generator and
Compressor, in the factory and safety measures have been introduced to minimize the risk.
Factory has conducted Health & Safety Risk Assessment for all processes in the factory and safety measures
have been introduced to minimize the risk. Last training conducted on 18th June, 2020
Boilers, Compressors, Generator maintenance record available. The details are maintained by Md. Shahadat
Hossain (Manager-Maintenance)
Total number of Fire Fighters-95

Total rescue team member-95
Total number of First Aid Responders-90
During the factory tour it was observed that the facility is well built and the layout is well designed, ensuring
safe and healthy work environment for workers. In general the facility was found to comply with applicable
health & safety laws and regulations. The facility has total 190 trained fire fighter, rescue and first aid responder
trained from Fire Service and Civil Defence.

The factory complies with fire safety regulations in general. Evacuation Plans were displayed in local language
throughout the factory.
Fire fighting equipment:-Fire Extinguishers ABC Fire Extinguisher ABC-128, CO2 -18, Lock Cutter-8 , First aid box-
13, Helmet-10, Hand Gloves: 9P, Gas Mask: 17P, Fire Beater-6, Hose pipe-13, Pillar-hydrant-12, Auto Heat
detector and smoke detector-241, are available as required by law.
Factory has trained Fire fighters, rescuer were found identified by specified dress codes. Emergency exits and
aisles were identified and were free of any kind of blockage. Assembly area was identified and workers were
found aware about it. The aisles were marked and meet the legal requirements. Fire Hydrant and Fire control
room is in place. Underground water reservoir and overhead reservoir are found available.
Fire fighting team is available that is trained on a regular basis and records maintained. Fire-fighter team
members were found aware of the fire policy. The facility management also conducts fire safety training by
Fire Service26th July, 2020
The facility is conducting emergency fire evacuation in every month and also conducting evening fire
evacuation fire drill doing by BFSCD in every six months.
Last day drill was conducted 16th June, 2020(Day) time taken to evacuate2 minute 55 seconds. Total
participants were 963 Including Guest, Management as well as workers and last fire drill by BFSCD on
17thFebruary, 2020 evacuate 3 minute 32seconds. Total participants were1198 Including Guest, Management
and workers
The Factory has 13 First Aid Boxes and a team of 90First Aid providers trained by company doctor.
Photographs of all first aid providers have been displayed with relevant first aid box. Each First Aid box was
found to have all items required by law. List of items was available with each first aid box. Last meeting was
conducted on 21st July, 2020 Participant was 20and trainer-DR.
Factory provided dining hall and Canteen facilities where workers can take their lunch. Canteen and dining
are located at same area i.e. at roof top of the factory building. Canteen is operative and Mr. Zalini Miya is
responsible for looking after canteen. And the seating capacity as per legal specification and seating
accommodation was found for 340 worker.
Total toilet-63, Male-20, Female-35 and Staff-8, The toilets were found to be clean and hygienic.
Fulltime cleaners have been appointed to keep the factory clean and tidy.
Factory holds regular training covering various aspects of Health & Safety for all employees. The newly hired
workers are provided health & safety training as part of orientation program. Records of such trainings are
maintained.
Company is not providing any Accommodation/Dormitory Facility.
 Clinic Logs, Accident/Injury Register

 Health and Safety Training Records (First Aid, Fire Fighting, Rescue, use of PPE, use of machine guards,
Chemical handling, MSDS, etc.)
 Fire Drill Records, Fire Plan, Inspection Records for firefighting equipment (Fire Extinguishers and

Hosepipe)
 Canteen Committee
 Childcare Register
 Broken Needle Record
 First Aid Box item list
 List of Health & Safety Committee members
 Health & Safety Committee Meeting Minutes
 Fire Safety & Committee Meeting Minutes
 Electricity Safety & Committee Meeting Minutes
 Risk Assessment
 Drinking Water Test Report
 Machine Maintenance Record
 Health & Safety related licenses (Fire License, Boiler License, Boiler Operator certificate, Building layout
approval, Generator Approval and Group Insurance)
A: Does the facility have general Yes

and occupational Health & Safety No
policies and procedures that are fit A1: Please give details: The facility has general Health & Safety and
for purpose and are these occupational Health & Safety policies and procedures that are fit
communicated to workers? for purpose and are communicated to workers
B: Are the policies included in Yes

workers‟ manuals? No
B1: Please give details: During the health and safety manual review
it was noted that the manualincluded all policies
C: Are there any structural additions Yes

without required permits/inspections No
(e.g. floors added)? C1: Please give details: The facility management taken building
structural approval andBuilding is approved as Industrial purpose.
D: Are visitors to the site informed on Yes
H&S and provided with personal No
protective equipment D1: Please give details: The facility is informing and providing
related PPE to visitor.
E: Is a medical room or medical Yes

facility provided for workers? No
If yes, do the room(s) meet legal E1: Please give details: The facility has well-furnished medical
requirements and is the size/number facility for workers located at first floor of building.
of rooms suitable for the number of
workers.
F: Is there a doctor or nurse on site Yes
or there is easy access to first aider/ No
trained medical aid? F1: Please give details: Facility appointed full time Doctor and nurse
and regular training sessions for first aid responder found in place.
During worker interview it was noted that there is easy access to
first aider/ trained medical aid.
G: Where the facility provides Yes

worker transport - is it fit for purpose, No

safe, maintained and operated by G1: Please give details: Facility is not providing any transportation.
competent persons e.g. buses and
other vehicles?
H: Is secure personal storage space Yes

provided for workers in their living No
space and is fit for purpose? H1: Please give details: Facility is not providing any dormitory facility
for workersinside the factory premises.
I: Are H&S Risk assessments are Yes
conducted (including evaluating No
the arrangements for workers doing I1: Please give details: Facility declared risk assessment which
overtime e.g. driving after a long covered basically production process to reduce health and safety
shift) and are there controls to risk, Fire incident.
reduce identified risk?
J: Is the site meeting its legal Yes
obligations on environmental No
requirements including required J1: Please give details:The site is meeting its legal obligations on
permits for use and disposal of environmental requirements including required permits for use and
natural resources? disposal of natural resources
K: Is the site meeting its customer Yes

requirements on environmental No
standards, including the use of K1: Please give details: The site meeting its customer requirements
banned chemicals? on environmental standards, No hazardous chemical is used.
Non–compliance:

NC against ETI NC against Local Law NC against customer code: observed:
(where relevant please
During documentation review it was observed that the facility management is add photo numbers)
maintaining safety record book but it was not found updated and not displayed on
Safety Board. Through the facility tour
and document
Local law requirement:In accordance with Bangladesh Labor Rules 2015 section 45
(2)

update & display safety record on safety board.
2. Description of non–compliance:
NC against ETI NC against Local Law NC against customer code:
It was noted through document review and management interview that factory is
maintaining injury/accident register in the medical room. But it was noted they did
not submit the injury/accident register to the labor inspector as specified in law.
They shared injury/accident register on 24th December, 2019
Through documents
Local law requirement:In accordance with Bangladesh Labor Rules 2015 section 1& review and
2 management

interview.
share their injury/accident with labor inspector as per the legal requirement.
Interviewed fire fighters were not conversant about the use of different type of
firefighting equipment kept in the factory. Interviewed first aiders were not
conversant about the use of different type of first aid equipment kept in the first aid
boxes.
Local law requirement:In accordance with Bangladesh labor rule 2015 section 55
Recommended corrective action: The facility management informed they provide

training to fire fighter, first aider and fire rescuer.
Through worker
4. Description of non–compliance: interview.
During the facility tour it was noted that the facility is providing canteen facility to
worker and canteen shop was found functional but it was not found well equipped
with enough food supply.
Local law requirement:In accordance with Bangladesh labor law 2006 section 92.
And rules 2015 section 87-88

provide enough food supply at Canteen.
During the facility tour aisles marking & emergency arrow were faded in 1st, 2nd 3rd, Through the facility tour
4th and 5th floors. and worker interview.
Local law requirement:In accordance with Bangladesh labor 2006 section 77 (1)
and 78 (1)

ensure visual aisles marking and arrow indicators
Through the facility tour
Observation:


observed:
Description of Good Example (GE): Objective Evidence

Observed:

4: Child Labour Shall Not Be Used

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: During review of personnel files it was found that all age verification documents (age
verification certificate by registered medical doctor) were present
The factory does not employ any employee below the age of 18 years. The recruitment process requires
workers to undergo a medical examination to verify the age by registered medical doctor. Training record
and meeting minutes were available to review. Child care room is located at ground floor at of the building
and maintaining with as per law requirement. Ms. Lipi Akter (Governance )
During management and worker interview it was found that all workers had been examined by the medical
doctor for age verification purpose as defined in recruitment procedure. Where possible the workers had
also provided the birth certificates, school certificates, and National ID. Copies of age verification
documents are retained in personnel files. Further it was confirmed during interview that factory does not
employ any child labor.
During factory tour no child or young looking worker was noted.
 Recruitment Policy
 Personal File
 Young worker details
 Age Verification by Doctor
 Latest list of employee
 Age Verification documents (Birth Certificate, National ID, and School certificate)
A: Legal age of employment: 18 years
B: Age of youngest worker found: 18.6 years
C: Are there children present on the work Yes

floor but not working at the time of No
audit?

D: % of under 18‟s at this site (of total 0%

workers)
E: Are workers under 18 subject to Yes

hazardous work assignments? No
(Go to clause 3 – Health and Safety) If Y give details
Non–compliance:

NC against ETI NC against Local Law NC against customer code: observed:
(where relevant please
add photo numbers)
Observation:
Comments:
Description of Good Example (GE): Objective Evidence Observed:

5: Living Wages are paid

5: Living Wages are Paid
(Click here to return to Key information)
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.

Compensation records of 42 randomly selected workers, including 13 male and 29 female. Workers were
checked covering 2 pay periods (July-2020 and February-2020).
All documents were found to comply with applicable laws and regulations. The legal Minimum legal wage is
grade 7: 8000 BDT as per government gazette 25th November, 2018 and 24th January, 2019.
During review of compensation documents and worker interviews it was confirmed that factory is paying
salaries meeting legal minimum wage. The overtime is recorded on Swipe Cards and is paid at the rate of
200% of the basic salary as required by law.
All workers are communicated breakdown of their salary by stating the salary in their appointment letters,
worker handbooks, and displaying the legal minimum wages on notice board in local language. Further the
factory also explains the calculation of wages during orientation training.
Workers sign the salary sheets and are issued pay slips explaining all components of the salary including
deductions (if any) in local language.
During worker interviews the workers seem to be aware of the legal minimum wage, overtime calculation and
the breakup of their salaries.
The calculation of other financial benefits including earned leave, maternity and service benefits was verified
and found to comply with legal requirements.
Company had paid the group Insurance premium and had valid group Insurance license covering the life
insurance in case a worker meets any fatal accident during work.
The factory only deducts salary if the worker is absent, as permitted by law. There is also 10 taka deducted for
revenue stamp

 Appointment Letter (stating the salary breakdown).

 Salary Sheet
 Pay slip
 Minimum Wage and calculation of Overtime displayed
 Increment records
 Working hour record
 Service Book
 Maternity Benefit
 Earned Leave
 Service Benefit
 Group Insurance
 Worker Participation Fund and Worker Welfare fund and
 Training record
Non–compliance:

Observation:
Comments:
Through worker interview and

1. The facility is giving attendance bonus for full attendance BDT 350 documentation review
and BDT 200

Summary Information
Criteria Local Law Actual at the Site Is this part of a
(Please state legal (Record site results Collective
requirement) against the law) Bargaining
Agreement?
A: Standard/Contracted work hours: Legal A1: 48 hours A2:

(Maximum legal and actual required working maximum:48 Yes
hours excluding overtime, please state if possible hours per week No
per day, week, and month)
B: Overtime hours: Legal maximum:2 B1: 12/week with B2:

(Maximum legal and actual overtime hours, hours per day highest in the Yes
please state if possible per day, week, and month) and 12 hours per month of June-2020 No
week.
C: Wage for standard/contracted hours: Legal C1: 8000 taka C2:

(Minimum legal and actual minimum wage at site, minimum:8000 monthly Yes
please state if possible per hr, day, week, and taka No
month)
D: Overtime wage: Legal D1: Double of the D2:

(Minimum legal and actual minimum overtime minimum:Double basic Yes
wage at site, please state if possible per hr, day, of the basic. No
week, and month)
Wages analysis:
Wages analysis:
A: Were accurate Yes

records shown at the No
first request?
A1: If No, why not? Not applicable
B: Sample Size 42 from taken from the month of July-2020 (Currant month) and February-2020
Checked (Random month)
(State number of
worker records
checked and from
which weeks/months –
should be current,
peak, and random/low.
Please see SMETA Best
Practice Guidance and
Measurement Criteria)

C: Are there different Yes C1: If Yes, please give details:The factory is following Garments Gazette
legal minimum wage No Please see below:-
grades? If Yes,
please specify all. Food &
Basic House Medical Gross
Grade Transport
Salary Rent Allowance Salary
Allowances
1. 10440 5220 600 1250 17510
2. 8520 4260 600 1250 14630
3. 5160 2580 600 1250 9590
4. 4930 2465 600 1250 9245
5. 4670 2335 600 1250 8855
6. 4370 2185 600 1250 8405
7. 4100 2050 600 1250 8000
D: If there are Yes D1: If No, please give details:

different legal No
minimum grades, are N/A
all workers graded
and paid correctly?
E: For the lowest paid Lowest actual wages found: Note: full time employees and please state hour / week /
production workers, Below month etc.
are wages paid for legal min
standard/contracted Meet The facility is maintaining the wage structure which is mentioned in the
hours (excluding Above legal law.
overtime) below or
above the legal The Labor Ministry and Employment Circular of Bangladesh
minimum? No.40.00.0000.018.30.008.17.33 dated 16th July 2020 that allowed factories
to work 4 hrs OT from 17th April 2020 to 16th October 2020
F: Please indicate the F1: 0% of workforce earning under minimum wage

breakdown of F2: 20% of workforce earning minimum wage
workforce per F3: 80% of workforce earning above minimum wage
earnings:
G: Bonus Scheme Bonus Scheme found:

found: Note: full time employees and please state hour / week/month etc.
Please specify
details: The facility is giving attendance bonus for full attendance: BDT-500 to all worker and
also paying Eid bonus in two
Eid bonus on basic salary.

For religious festivals (2 Eid) bonuses are legal requirement: one year completed worker
will get a bonus for each festival. Amount is not mentioned in Law. It is defined as
bonus will not be more than the basic salary of that worker. Ref: Bangladesh Labor
Rules no:111-5)
H: What deductions As per section Bangladesh labour 2006 section 125 factory can deduct wages from
are required by law basic wages for unauthorised absent, fines, housing facility, advance payment, loan
e.g. social insurance? and provident found.
Please state all types:
As per Bangladesh stamp act 1899, amendment 2010 factory can deduct BDT-10 for

government revenue stamp
I: Have these Yes I1: Please list all 1. Unauthorised absent

deductions been No deductions that Please describe: As per section Bangladesh labour 2006
made? have been section 125 factory can deduct wages from basic wages
made. for unauthorised absent, fines, housing facility, advance
payment, loan and provident found.
As per Bangladesh stamp act 1899, amendment 2010

factory can deduct BDT-10 for government revenue
stamp
Please describe:
I2: Please list all 1.

deductions that 2.
have not been
made.
J: Were appropriate Yes

records available to No
verify hours of work
and wages?
K: Were any Yes K1: Type

inconsistencies No
found? Poor record keeping
(if yes describe Isolated incident
nature) Repeated occurrence:
L: Do records reflect Yes

all time worked? (For No
instance, are workers
asked to attend L1: Please give details:In/out time are recorded on Swipe Cards and Thumb system. All
meetings before or time worked by the workers are recorded.
after work but not
paid for their time)
M: Is there a defined Yes

living wage: No
This is not normally M1: Please specify amount/time: The facility management has not defined living wage
minimum legal wage. as this is not legally required by law.
If answered yes,
please state amount
and source of info:
Please see SMETA Best
Practice Guidance and
Measurement Criteria.
M2: If yes, what was ISEAL/Anker Benchmarks

the calculation Asia Floor Wage
method used. Figures provided by Unions
Living Wage Foundation UK
Fair Wear Wage Ladder
Fairtrade Foundation

Other – please give details:
N: Are there periodic Yes

reviews of wages? If No
Yes give details N1: Please give details:
(include whether
there is consideration
to basic needs of
workers plus
discretionary
income).
O: Are workers paid Yes

in a timely manner in No
line with local law? Please specify amount/time: Workers getting salary designation and grading wise as
legally required by law within 7thworking day of the month.
P: Is there evidence Yes

that equal rates are No
being paid for equal P1: Please give details: Workers getting salary designation and grading wise.time
work: records and pay slips show that equal rate of wages are being paid for equal work
done by workers.
Q: How are workers Cash

paid: Cheque
Bank Transfer
Other
Q1: If other,please explain: The facility is paying wages in hand cash

6: Working Hours are not Excessive

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
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.

Current systems: During review of working hour documents and worker interviews it was found that factory
does not exceed overtime 2 hours per day and 12 hours per week. Also, one day off is provided for every 7
day period and weekend is Friday.
The working hours are recorded on Swipe Card. The Swipe Card records are maintained by the time office.
The factory operates six days a week, providing 1 day off every Friday. Factory operates 8 hours per day
and 48 hours per week as regular working hours. Overtime does not exceed the legal limit of 2 hours per day
and 12 hours per week.
During document review and worker interview it was found that the factory does not operate on holidays or
weekly day off. Further it was found that the overtime is voluntary and workers are free to leave after regular
working hours.
The working hour policy was displayed on company notice board in local language and also included in

the worker handbooks. Further, workers are provided training on working hours during orientation.
-Employee interview
-Management interview
-Local and national laws
-Factory policy on working hour
-Swipe Card
-Attendance
-Overtime record
-Leave entitlement
-Leave register
-Computerised time login system
-Sample pay slip and with recorded hours all worker interview
-12 months hours records to establish highest and lowest hours for all workers
-Quality and production records cross-checked with hours
Any other comments:-
Non–compliance:

Observation:
Comments:
Working hours’ analysis

Working hours’ analysis

Please include time e.g. hour/week/month

(Go back to Key information)
Systems & Processes
A. What timekeeping Describe: Facility is using Swipe card and Thumb system to keep workers attendance
systems are used: time record updated. Swipe card issued to all workers after hire
card etc.
Yes
B: Is sample size same No
as in wages section? B1: If no, please give details
C: Are Yes C1: If NO, please give details including % and which type of workers
standard/contracted No do NOT have standard hours defined in contracts/employment
working hours defined agreements.
in all Please give details:
contracts/employment
agreements?
D: Are there any other Yes D1: If YES, please complete as appropriate:
types of No
agreements used? 0 Part time Variable hrs Other
hrs
If “Other”, Please define:
E. Do any Yes E1: If yes, please detail hours, %, types of workers affected and
standard/contracted No frequency
working hours defined Please give details:
in
agreements exceed
48 hours per week?
F: Are workers F2: Please F3: Is this allowed by local law?

provided with at least select all Yes
1 day off in every 7- applicable: No
day-period, or 2 in 14- 1 in 7 days
day-period? 2 in 14
days
No
If „No‟, please
explain:
Maximum number of days worked without a day off (in sample):
6 days

Standard/Contracted Hours worked
G: Were standard Yes G1: If yes, % of workers & frequency:

working hours over 48 No
hours per week found?
H: Any local Yes H1: If yes, please give details:

waivers/local law or No
permissions which
allow
averaging/annualised
hours for this site?
Overtime Hours worked
I: Actual overtime Highest OT were found 12 hours/weekly in the month of June, 2020 (recent month)
hours worked in and February 2020 random month in sample out from 42 samples.
sample (State per
day/week/month)
J: Combined hours Yes

(standard or No
contracted + overtime Legally standard working hour is 2 hours/day and over time 12 hours/week
hours = total) over 60 combined 48+12 hours= 60 hours/week
found?
Please give details:
K: Approximate 50%
percentage of total
workers on highest
overtime hours:
L: Is overtime Yes L1: Please detail evidence e.g. Wording of contract/employment

voluntary? No agreement/handbook/worker interviews/refusal arrangements:
Conflicting
Information Overtime is voluntary. Verified during workers interview and
documentation review.
Overtime Premiums
M: Are the correct Yes M1: Please give details of normal day overtime premium as a % of
legal overtime No standard wages:
premiums paid? N/A –
there is no 200% of basic
legal
requirement
to OT
premium
requirement
to OT
premium
N: Is overtime paid at a Yes N1: If yes, please describe % of workers & frequency:100% of workers
premium? No receive OT premium

O: If the site pays less No

than 125% OT premium Consolidated pay (May be standard wages above minimum legal wage, with no/low
and this is allowed overtime premium)
under local law, are Collective Bargaining agreements
there other Other
considerations? Please
complete the boxes
where relevant. O1: Please explain any checked boxes above e.g. detail of consolidated pay / CBA
or Other
The Labor Ministry and Employment Circular of Bangladesh

No.40.00.0000.018.30.008.17.33 dated 16th July 2020 that allowed factories to work 4
hrs OT from 17th April 2020 to 16th October 2020
P: If more than 60 total Overtime is voluntary

hours per week and Onsite Collective bargaining allows 60+ hours/week
this is legally allowed, Safeguards are in place to protect worker‟s health and safety
are there other Site can demonstrate exceptional circumstances
considerations? Please Other reasons (please specify)
complete the boxes
where relevant. P1: Please explain any checked boxes above e.g. detail of consolidated pay / CBA
or other:
Q: Is there evidence Yes

that overtime hours are No
being used for Q1: If yes, please give details: Due to increased order quantity sometimes the facility
extended periods to management does overtime if requires
make up for labour
shortages or increased
order volumes?
R: If sufficient workers Yes

cannot be hired, are No
new working time
arrangements
explored to ensure
that overtime is the
exception rather than
the rule.
7: No Discrimination is practiced
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: During document review and worker interviews it was found that the factory does not
discriminate among employees in hiring, compensation, access to training, promotion, termination or
retirement based on race, caste, national origin, religion, age, gender, marital status, sexual orientation or
membership in any union or political affiliation
Factory has documented policy on prohibition of discrimination, which is communicated to all employees by
displaying on notice board in local language, including it in worker handbook and by providing training to all
employees (management and workers). Records of training are maintained.
Any employee found to violate the company policy on prohibition of discrimination is subject to disciplinary
action. Further the employees can also use grievance procedure to complain about such violation.
During management and worker interviews it was found that all employees were aware about the policy on
prohibition of Discrimination and Grievance Procedure. The facility posted Grievance box in both male and
female toilets and opens them every seven days.
renewal/expiry date where appropriate)
 Policy on Prohibition of Discrimination

 Recruitment Policy
 Promotion Policy
 Interview Sheet/Skill Test Records
 Worker performance records by industrial engineering department
 Grievance Procedure
 Disciplinary Procedure
 Increment records
 Salary Sheets/payroll
 Training Records
Any other comments:
A: Gender breakdown of Management A1: Male: 30%

+ Supervisors (Include as one combined A2: Female 70 %
group)
B: Number of women who are in skilled

or technical roles e.g. where specific
qualifications are needed i.e. machine no such record found.
engineer / laboratory analyst:
C: Is there any evidence of Hiring

discrimination based on race, caste, Compensation
national origin, religion, age, disability, Access to training
gender, marital status, sexual orientation, Promotion
union membership or political affiliation?: Termination or retirement
No evidence of discrimination found

C1: Please give details: No evidence of discrimination found.

Verified during documentation review and worker interview.
Professional Development
A: What type of training and development

are available for workers? Skills training was provided to workers and if skilled workers were
assigned to sampling workshop, which could bring them more
income.
B: Are HR decisions e.g. promotion,

training, compensation based on Yes
objective, transparent criteria?
No
If no, please give details:
Non–compliance:

Observation:
Comments:


8: Regular Employment Is Provided

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.
Additional Elements: Responsible Recruitment

8.3 Suppliers have full understanding of the entire recruitment process and assess all labour recruiters and
intermediaries against legal and/or ethical requirements.
8.4 There are effective management systems in place to identify and monitor the hiring and management of
all migrant workers, contract workers, agency workers, temporary or casual labour The supplier shall
implement processes to enable adequate control over agencies with regards the above points and related
legislation.
8.5 Employment agencies must only supply workers registered with them.
8.6 Workers pay no recruitment fee at any stage of the recruitment process.
8.7 Worker contracts accurately reflect the agreed payment and terms in the recruitment process and are
understood and signed by workers.

Current systems: During document review and worker interview it was found that factory issues appointment
letters to all workers. The appointment letter is signed both by the factory representative and the worker.
All workers are recruited directly by the factory on permanent basis. All workers are issued appointment
letters as required by law. All workers are entitled to legally mandated benefits like Group Insurance, Service
benefit, earned leave and maternity benefit as per the legal requirement
 Personnel files
 ID cards,
 Service book,
 Employment Terms & Conditions.
 Group Insurance

Non–compliance:

Observation:
Comments:
Responsible Recruitment
All Workers
A: Were all workers presented Terms & Conditions presented

with terms of employment at Understood by workers
the time of recruitment, did Same as actual conditions
they understand them and are
they same as current A1: If any are unchecked, please describe finding and specific
conditions? category(ies) of workers affected:
B: Did workers‟ pay any fees, Yes

taxes, deposits or bonds for No
the purpose of B1: If yes,please describe details and specific category(ies) of workers
recruitment/placement? affected:

C: If yes, check all that apply: Recruitment / hiring fees

Service fees
Application costs
Recommendation fees
Placement fees
Administrative, overhead or processing fees
Skills tests
Certifications
Medical screenings
Passports/ID‟s
Work / resident permits
Birth certificates
Police clearance fees
Any transportation and lodging costs after employment offer
Any transport costs between work place and home
Any relocation costs after commencement of employment
New hire training / orientation fees
Medical exam fees
Deposit bonds or other deposits
Any other non-monetary assets
Other – (Govt. Revenue)
C1: If other, please give details:
D: If any checked, give details:
Migrant Workers:
The term "migrant worker" refers to a person who is engaged or has been engaged in a remunerated activity in a country
of which they are not a national or permanent resident or has purposely migrated on a temporary basis to another in-
country region to seek and engage in a remunerated activity
A: Type of work undertaken by N/A – No migrant workers

migrant workers:
B: Please give details about B1: Total number of (in country recruitment agencies) used:N/A
recruitment agencies for migrant
workers: B2: Total number of (outside of local country) recruitment agencies
used: N/A
C: Are migrant workers‟ voluntary Yes C2: Observations:

deductions (such as for No
remittances) confirmed in writing C1: Please
by the worker and is evidence of describe finding:
the transaction supplied by the
facility to the worker?
Yes
D: Are Any migrant workers in No
skilled, technical, or management
roles D1: If yes, number and example of roles:
Migrant Workers (this should include all

migrant workers including permanent
workers, temporary and/or seasonal

workers)
NON-EMPLOYEE WORKERS
Recruitment Fees:
A: Are there any fees? Yes
No
B: If yes, check all that Recruitment / hiring fees

apply: Service fees
Application costs
Recommendation fees
Placement fees
Administrative, overhead or processing fees
Skills tests
Certifications
Medical screenings
Passports/ID‟s
Work / resident permits
Birth certificates
Police clearance fees
Any transportation and lodging costs after employment offer
Any transport costs between work place and home
Any relocation costs after commencement of employment
New hire training / orientation fees
Medical exam fees
Deposit bonds or other deposits
Any other non-monetary assets
Other
B1– If other, please give details:
C: If any checked, give

details:
Agency Workers (if applicable)

(workers sourced from a local agent who are not directly paid by the site, but paid by the agency, Usually the agencies
are paid by the site and the wages of the individual workers are paid by the agency.)
A: Number of agencies used A1: Names if available: N/A – No agencies used

(average):
B: Were agency workers‟ Yes

age/pay/hours included within No
the scope of this audit?
C: Were sufficient documents Yes

for agency workers available for No
review?

D: Is there a legal contract / Yes

agreement with all agencies? No
D1: Please give details:
E: Does the site have a system Yes

for checking labour standards of No
agencies?
If yes, please give details. E1: Please give details:
Contractors:
Note: contractors in this context are generally individuals who supply several workers to a site. Usually the contractors are
paid by the site and the wages of the workers are paid by the contractor. Common terms include, gang bosses, labor
provider,
Yes
A: Any contractors on site? No
A1: If yes, how many contractors are present, please give details:
B: If Yes, how many workers

supplied by contractors?
C: Do all contractor workers Yes

understand their terms of No
employment? C1: Please describe finding:
D: If Yes, please give evidence for

contractor workers being paid per
law:

8A: Sub–Contracting and Homeworking:

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.
Note to auditor on subcontracting: auditor should use this section for subcontractors of part made or wholly
made finished goods, this section should not be used for raw material manufacturers unless instructed
otherwise by customers

Current systems: The factory is subcontracting its production Washing & Embroidery from third-party.
If any processes are sub–contracted – please populate below boxes

Process Subcontracted Process 1- Washing Process 2Embroidery
Name of factory Vision Washing Ltd. Vision Washing Ltd.
Address Vurilia, Ashulia, Savar Vurilia, Ashulia, Savar
Process Subcontracted Process 3 Process 4

Name of factory
Address
Process Subcontracted Process 5 Process 6

Name of factory
Address
Details:

Non–compliance:

NC against ETI/Additional Elements NC against Local Law (where relevant please add photo
NC against customer code: numbers)
Local law and/or ETI /Additional Elements requirement:
Observation:
Local law or ETI/Additional elements requirement:
Comments:
Summary of sub–contracting – if applicable

Not Applicable please x
A: Has the auditor made a Yes

simple calculation to compare No
capacity with workers‟ work A1: Please describe: As factory‟s production process does not include
load in order to identify embroidery and washing they are subcontracting embroidery and
possible unrecorded work or washing process. As per production plan subcontracting process
undeclared sub-contracting monitored by production department.
B: If sub–contractors are used, Yes

is there evidence this has been No
agreed with the main client? If Yes, summarise details: Agreement between factory and sub-contractor
is available. During the audit verified.
C: Number of sub– Number of sub–contractors are 2

contractors/agents used:
D: Is there a site policy on sub– Yes

contracting? No
summarise details:The facility has well organised sub-contracted policy
and procedure

E: What checks are in place to Yes

ensure no child labour is being No
used and work is safe? If Yes, summarise details: Agreement between factory and sub-contractor
is available. During the audit verified.
Summary of homeworking – if applicable

A: If homeworking is being Yes

used, is there evidence this has No
been agreed with the main A1: If Yes, summarise details:
client?
B: Number of homeworkers B1: Male: B2: Female: Total:
C: Are homeworkers employed Directly C1: If through agents, number of agents:

direct or through agents? Through Agents
D: Is there a site policy on Yes

homeworking? No
E: How does the site ensure

worker hours and pay meet
local laws for homeworkers?
F: What processes are carried

out by homeworkers?
G: Do any contracts exist for Yes

homeworkers? No
G1: Please give details:
H: Are full records of Yes

homeworkers available at the No
site?

9: No Harsh or Inhumane Treatment is allowed

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.
Additional elements:
9.2 companies should provide access to a confidential grievance mechanism for all workers
A: Are there published, anonymous Yes

and/or open channels available for No
reporting any violations of Labour A1: Please give details:Documented open channel policy
standards and H&S or any other and procedure is available. The facility has a designated
grievances to a 3rd party? person to conduct grievance and handling procedure
B: If Yes, are workers aware of these All workers were found aware of these channel and have full
channels and have access? Please give access to these channels. Documented policy is in place
details. which clearly described harassment and abuse policy of the
factory. The facility is handing procedure and check every
complaint box every week.
C: If yes, what type of mechanism is used The facility posted hotline and provided grievance box in
e.g. hotline, whistle blowing mechanism, male and female toilets.
comment box etc. Please give details.
D: Which of the following groups is there Workers
a grievance mechanism in place for? Communities
Suppliers
Other
D1: Please give details: Facility declared grievance

procedure for workers and staff to report any instances of
harassment and encourage them to do so. Suggestion boxes
posted in a confidential area through which one can raise
his/ her grievance to management. The suggestion boxes
are opened by or on behalf of top management twice in a
month and the issues are solved immediately
E: Are there any open disputes? Yes
No
E1: If yes, please give details
F: Does the site encourage its business Yes

partners (e.g. suppliers) to provide No
individuals and communities with access
to effective grievance mechanisms F1: If no,please give details
(e.g.helplines or whistle blowing
mechanism)
G: Is there a published and transparent Yes
disciplinary procedure? No
G1: If no, please explain

H: If yes, are workers aware of these the Yes

disciplinary procedure? No
H1: If no, please give details
I: Does the disciplinary procedure allow Yes

for deductions from wages (fines) for No
disciplinary purposes (see wages
section)? I1: If yes, please give details

Factory has a documented policy on prohibition of Harassment & Abuse and employees (management &
workers) have been trained. Training records are maintained. They also communicate the policy during
orientation training. Last training was conducted on 9th July, 2020
During factory tour and worker interview it was found that behaviour of the management with workers is very
professional. No worker complained about any harsh or inhumane treatment.
Any employee found to use harsh or inhumane treatment with any other employee is subject to disciplinary
action. Further the employees can also use grievance procedure to complain about such violations.
During management and worker interviews it was found that all employees were aware about the policy on
prohibition of inhumane treatment and Grievance Procedure.
 Policy on Prohibition of Harassment & Abuse

 Suggestion/Complaint Register
 Grievance Procedure and
 Training records

Non–compliance:

Observation:
Comments:

10 A: Entitlement to Work and Immigration

10. Other Issue areas: 10A: Entitlement to Work and Immigration
(Click here to return to NC–table)
Additional Elements
10A.1 Only workers with a legal right to work shall be employed or used by the supplier.
10A.2 All workers, including employment agency staff, must be validated by the supplier for their legal right to
work by reviewing original documentation.

Current systems:-During document review and worker interview it was found that all workers are directly
employed by the factory and that all employees had been issued appointment letter and were recruited
following the process defined in the recruitment procedure.
During factory tour and worker interviews it was found that all workers are directly employed and that no
immigrant worker is employed by the factory. Further no agency worker is working in the factory. Security,
cleaners and canteen staff all are directly employed by the factory.
Details:
 Personal Files
 Recruitment procedure
Any other comments:


Non–compliance:

NC against customer code: numbers)
Local law and/or ETI /Additional Elements requirement:

Observation:
Local law or ETI/Additional Elements requirement:
Comments:

10 B 2: Environment 2–pillar
10. Other issue areas 10B2: Environment 2–Pillar
To be completed for a 2–Pillar SMETA Audit, and remove the following page which is 10B4 environment 4
pillar
10B2.1 Suppliers must comply with the requirements of local and international laws and regulations including
having necessary permits.
10B2.2 The supplier should be aware of and comply with their end clients‟ environmental requirements.
Note for auditors and readers, this is not a full environmental assessment but a check on basic systems and
management approach.

Current systems: The factory production processes areCutting-Sewing-Finishing & PackingGarment factories
that do not have processing like printing & dyeing, etc. don‟t require environmental license
Training program available for material safety. Documented training record available. All workers related
with chemical handling are well aware about chemical safety program. The facility is Softener, Detergent
and Soap.
Facility assesses its ability to prevent and control harmful releases of industrial waste into the environment as a
part of the environmental management system.
Facility maintain a detailed plan for handling accidental release or discharge of environmentally dangerous
materials.
There is no process in the factory that would generate any harmful releases.
Facility‟s environmental management system addresses where and how solid, chemical, sanitary, and
wastewater substances are disposed of. Separate segregated space available for waste. Written agreement
available with M Rahman Enterprise/Ms. Mozibe & Brothers for proper disposal of waste.
 Noise, Air Emission, Temperature monitoring system found in place.

 Environmental Policy
 Local and national laws and regulation displayed
 Waste policy
 Waste disposal record and
 Training record
Non–compliance:


numbers)
Local law and/or ETI/Additional Elements requirement:
Observation:
Local law or ETI/additional elements requirement:
Comments:

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 Instruction to Audit Company: fill in the relevant
constitute minimum and not maximum standards, clauses from the Customer Supplier Code - where
and this code should not be used to prevent applicable.
companies from exceeding these standards.
Companies applying the ETI Base Code are
expected to comply with national and other
applicable law and, where the provisions of law
and the ETI Base Code address the same subject,
to apply that provision which affords the greater
protection.
ETI Code / Additional Elements Customer's Supplier Code equivalent
0.A. Universal Rights covering UNGP 0.A. Universal Rights covering UNGP
0.A. Guidance for Observations

0.A.1 Businesses should have a policy, endorsed at
the highest level, covering human rights impacts
and issues, and ensure it is communicated to all
0.A.2 Businesses should have a designated person
responsible for implementing standards
concerning Human rights
0.A.3 Businesses shall identify their stakeholders
and salient issues.
0.A.4 Businesses shall measure their direct, indirect,
and potential impacts on stakeholders (rights
holders) human rights.
0.A.5 Where businesses have an adverse impact
on human rights within any of their stakeholders,
they shall address these issues and enable
effective remediation.
0.A.6 Businesses shall have a transparent system in
place for confidentially reporting, and dealing
with human rights impacts without fear of reprisals
towards the reporter.
0.B. Management Systems & Code 0.B. Management Systems & Code
Implementation 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.
ETI 1. Forced Labour ETI 1. Forced Labour
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.
ETI 2. Freedom of association and the right to ETI 2. Freedom of association and the right to
collective bargaining are respected collective bargaining are respected
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.
ETI 3. Working conditions are safe and hygienic ETI 3. Working conditions are safe and hygienic
3.1 A safe and hygienic working environment shall

be provided, bearing in mind the prevailing
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 & 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.
ETI 4. Child labour shall not be used ETI 4. Child labour shall not be used
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.
ETI 5. Living wages are paid ETI 5. Living wages are paid
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.
ETI 6. Working Hours are not excessive ETI 6. Working Hours are not excessive
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 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 ETI 7. No discrimination is practised
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.
ETI 8. Regular employment is provided ETI 8. Regular employment is provided
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.
Additional Elements: Responsible Recruitment

8.3 Suppliers have full understanding of the entire
recruitment process and assess all labour recruiters
and intermediaries against legal and/or ethical
requirements.
8.4 There are effective management systems in
place to identify and monitor the hiring and
management of all migrant workers, contract
workers, agency workers, temporary or casual
labour The supplier shall implement processes to
enable adequate control over agencies with
regards the above points and related legislation.
8.5 Employment agencies must only supply
workers registered with them.
8.6 Workers pay no recruitment fee at any stage
of the recruitment process.
8.7 Worker contracts accurately reflect the
agreed payment and terms in the recruitment
process and are understood and signed by
workers.
8A: Sub–Contracting and Homeworking 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.
ETI 9. No harsh or inhumane treatment is allowed ETI 9. No harsh or inhumane treatment is allowed
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.
Additional elements:
9.2 companies should provide access to a
confidential grievance mechanism for all workers
10. Other Issue areas: 10A: Entitlement to Work and

Immigration
Additional Elements
10A.1 Only workers with a legal right to work shall
be employed or used by the supplier.
10A.2 All workers, including employment agency
staff, must be validated by the supplier for their
legal right to work by reviewing original

documentation.
10. Other issue areas 10B2: Environment 2–Pillar
10B2.1 Suppliers must comply with the

requirements of local and international laws and
regulations including having necessary permits.
10B2.2 The supplier should be aware of and
comply with their end clients‟ environmental
requirements.
Note for auditors and readers, this is not a full
environmental assessment but a check on basic
systems and management approach.
SMETA Extra Sections for 4 Pillar Audit: SMETA Extra Sections for 4 Pillar Audit:
Environment Section Environment Section
B.4. Compliance Requirements

10B4.1 Businesses as a minimum must meet the
requirements of local and national laws related to
environmental standards.
10B4.2 Where it is a legal requirement, businesses
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 Businesses shall be aware of their end
client‟s environmental standards/code
requirements
10B4.4 Suppliers should have an environmental
policy, covering their environmental impact,
which is communicated to all appropriate parties,
including its own suppliers.
10B4.5 Suppliers shall be aware of the significant
environmental impact of their site and its
processes.
10B4.6 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).
10B4.7 Businesses shall make continuous
improvements in their environmental
performance.
10B4.8 Businesses shall have available for review
any environmental certifications or any
environmental management systems
documentation
10B4.9 Businesses should have a nominated
individual responsible for co–ordinating the site‟s
efforts to improve environmental performance.
B4. Guidance for Observations
10B4.10 Suppliers should have completed the

appropriate section of the SAQ and made it

available to the auditor.
10B4.11 Has the site recently been subject to (or
pending) any fines/prosecutions for
noncompliance to environmental regulations.
Business Practices Section
10C. Compliance Requirements

10C.1 Businesses shall conduct their business
ethically without bribery, corruption, or any type of
fraudulent Business Practice.
10C.2 Businesses as a minimum must meet the
requirements of local and national laws related to
bribery, corruption, or any type of fraudulent
Business Practices.
10C.3 Where it is a legal requirement,
businesses must be able to demonstrate
that they comply with all fiscal legislative
requirements.
10C.4 Businesses shall have access to a
transparent system in place for confidentially
reporting, and dealing with unethical Business
Ethics without fear of reprisals towards the
reporter.
10C.5 Businesses should have a Business Ethics
policy, covering bribery, corruption, or any type of
fraudulent Business Practice,
10C.6 Businesses should have a designated person
responsible for implementing standards
concerning Business Ethics
10C.7 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.
10C. Guidance for Observations
10C.8 Businesses should communicate their

Business Ethics policy, covering bribery, corruption,
or any type of fraudulent Business Practice to all
10C.9 Has the site recently been subject to (or
pending) any fines/prosecutions for non-
compliance to Business Ethics regulations. If so is
there evidence that sustainable corrective actions
have been implemented.

Photo Form
Gate View Outside View Building View
Cutting Cutting Cutting
Sewing Sewing Sewing

Sewing Sewing Sewing
Finishing Section Finishing Section Iron Section
Accessories Store First Aid Responder PC Members

Frist Aid Box Fire Hose Pipe Fire Alarm Switch
Power Box Power Box (interior) Grievance Box
Arrow marked with exit singe Arrow marked with exit singe Arrow marked with exit singe

Roof Top Fire Hose Pressure Safety Committee Member
Display of MSDS Secondary Containment Smoke Detector
Worker‟s Attend system Fog Light P A System

Prayer Room Fire Extinguisher Visual Fire call point
Use of Personal protective Use of Personal protective Equipment Use of Personal protective Equipment
Equipment
Risk Assessment COC for Buyers Evacuation Map

Child Care Room Doctor‟s Room First Aid Box
Thread Sucker Machine Spot Removing Room Fire Fighting Equipment‟s
Generator Room DB Box Room Boiler Room

Assembling Point Canteen Dining Hall
Stair Case Stair Case Stair Case
Sharp Tools Station Needle Issue Station Drinking Water Station
Non-compliance Picture

Arrow & Aisles marked faded Arrow & Aisles marked faded Arrow & Aisles marked faded
Arrow & Aisles marked faded Arrow & Aisles marked faded Arrow & Aisles marked faded
NA
Arrow & Aisles marked faded In canteen food supply is not NA

adequate

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valuable. It will help to make improvements to future versions.
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Version 6.

Business name Jamuna Fashion Wears Ltd.

Audit Company Name & Logo:

Report Owner (payer):

Affiliate Audit Purchaser

Brand owner NGO Trade Union

Multi– Combined Audit (select all that apply)

Audit company:Accordia Global Compliance GroupReport reference:JFWL17082020Date:17.08.2020 2

Audit company:Accordia Global Compliance GroupReport reference:JFWL17082020Date:17.08.2020 3

Auditor Team (s) (please list all including all interviewers):

Interviewers: Shimul Kar APSCA number: ASCA21704639

Report writer: Md. Ripon Uddin

Date of declaration: 17th August, 2020

Audit company:Accordia Global Compliance GroupReport reference:JFWL17082020Date:17.08.2020 4

0A Universal Rights covering UNGP 01 00  During the documentation review and

 Summary of Good Example None

0B Management systems and 01 00 01  During documentation review and

 The facility has an internal audit team to

 Summary of Observation: None

1. Freely chosen Employment 00 00 00  Summary of Non-Compliance: None

Audit company:Accordia Global Compliance GroupReport reference:JFWL17082020Date:17.08.2020 5

 Summary of Good Example: None

 Summary of Observation: None

2 Freedom of Association 00 00 00  Summary of Non-Compliance: None

 Summary of Good Example: None

 Summary of Observation: None

3 Safety and Hygienic Conditions 05 00 00

 It was noted through document review

 Interviewed fire fighters were not

Audit company:Accordia Global Compliance GroupReport reference:JFWL17082020Date:17.08.2020 6

 During the facility tour it was noted that

 During the facility tour aisles marking &

 Summary of Observation: None

4 Child Labour 00 00 00  Summary of Non-Compliance: None

 Summary of Good Example: None

 Summary of Observation: None

5 Living Wages and Benefits 00 00 01  The facility is giving attendance bonus

 Summary of Observation: None

6 Working Hours 00 00 00  Summary of Non-Compliance: None

 Summary of Good Example: None

 Summary of Observation: None

7 Discrimination 00 00 00  Summary of Non-Compliance: None

 Summary of Good Example: None

Audit company:Accordia Global Compliance GroupReport reference:JFWL17082020Date:17.08.2020 7

 Summary of Observation: None

8 Regular Employment 00 00 00  Summary of Non-Compliance: None

 Summary of Good Example: None

 Summary of Observation: None

8A Sub–Contracting and 00 00 00  Summary of Non-Compliance: None

 Summary of Observation: None

9 Harsh or Inhumane Treatment 00 00 01  Summary of Non-Compliance: None

 Summary of Good Example: None

 Summary of Observation: None

10A Entitlement to Work 00 00 00  Summary of Non-Compliance: None

 Summary of Good Example: None

 Summary of Observation: None

10B2 Environment 2-Pillar 00 00 00  Summary of Non-Compliance: None