smeta audit type: 2–pillar 4–pillar - · pdf filei declare that the audit...

Audit Company: Intertek Report reference: IDA–13266-01 Date: 01-02/03/2016 1

Supplier name: Exotic Fruits Pvt Ltd.

Site country: India

Site name: Exotic Fruits Pvt Ltd.

Parent Company name (of the site): Exotic Fruits Pvt Ltd.

SMETA Audit Type: 2–Pillar 4–Pillar

Date of Audit March 1st & 2nd , 2016


Audit Company Name:

IntertekReport Owner (payee):

Exotic Fruits Pvt Ltd.

Sedex Company Reference:(only available on Sedex System) Not registered on sedex

Sedex Site Reference:(only available on Sedex System) Not registered on sedex

Audit Conducted By

Commercial Purchaser

NGO Retailer

Trade Union Brand Owner

Multi–stakeholder Combined Audit (select all that apply)

Auditor Reference Number:(If applicable) Not applicable

SMETA DeclarationI declare that the audit underpinning the following report was conducted in accordance withSMETA Best Practice Guidance and SMETA Measurement Criteria.

Any exceptions to this must be recorded here (e.g. different sample size): None

Auditor Name(s) (please list all including all interviewers):Lead auditor: Veerakumar STeam auditor: Not applicableInterviewers: Veerakumar S

Date: March 1- 2 2016


Non–Compliance Table

Issue(please click on the issue title to go direct to

the appropriate audit results by clause)

Area of Non–Conformity(Only check box when there is a non–conformity,and only in the box/es where the non–conformity

can be found)

Record the numberof issues by line*:

ETI BaseCode Local Law

AdditionalElements

(i.e. not partof ETI code )

NC Obs GE

0 Management systems and codeimplementation

Nil Nil Nil

1 Employment Freely Chosen Nil Nil Nil

2 Freedom of Association Nil Nil Nil

3 Safety and Hygienic Conditions Nil Nil Nil

4 Child Labour Nil Nil Nil

5 Wages and Benefits Nil Nil Nil

6 Working Hours Nil Nil Nil

7 Discrimination Nil Nil Nil

8 Regular Employment Nil Nil Nil

8A Sub–Contracting andHomeworking

Nil Nil Nil

9 Harsh or Inhumane Treatment Nil Nil Nil

10A Entitlement to Work Nil Nil Nil

10B2 Environment 2–Pillar NA NA NA

10B4 Environment 4–Pillar Nil Nil Nil

10C Business Ethics Nil Nil

*Please note the table above records the total number of Non compliances (NC), Observations (Obs) and GoodExamples (GE). This gives the reviewer an indication of problem areas but does not detail severities of each issue –Reviewers need to check audit results by clause.


Summary of FindingsSummary of main findings: (positive and negative)(Please give a short summary of the main findings per clause)

Audit process :

This initial audit was conducted by Intertek India Private Limited. One (1) auditor in Two (2) day assessed / verified thefacility’s operations against the ETI Base Code and local legislations on a sampling basis.

Auditors entered the facility at 09.15am on March 01, 2016 and conducted an opening meeting with facility managementaccording to the ETI Base Code. Mr. Ajay Sortee - DGM - Quality Assurance was present in the meeting and assuredfull co-operation to this audit.

10 attendance records and payroll records for January 2016 (Current month), 10 attendance records and payroll recordsfor June 2015 (Peak month) and 10 attendance records and payroll records for March 2015 (Non peak month) werereviewed in this audit.

Positive observations:Below observations are based on the tour of the facility, review of records, interaction with employees andinteraction with facility management:

1. The facility premise was well maintained and the general working conditions were found to be good andoverall general working conditions of the facility was found to be in order.

2. There is no evidence of child labour.3. There is no evidence of any discrimination, harassment and abuse or unfair disciplinary practices.4. The facility was very concern about the health and safety aspect and facility was well equipped with all the

safety equipment.

Negative observations:

No non-compliance observed on the audit days.

Observations:None

Auditor Notes:None


Audit DetailsAudit Details

A: Report #: IDA-13266-01

B: Time in and time out(SMETA Best Practice Guidance andMeasurement Criteria recommends 9.00–17.00hrs. if any different please state why in theSMETA declaration )

Day 1 Time in: 09:15AMDay 1 Time out:05:30 PM

Day 2 Time in: 09:30AMDay 2 Time out:06:30 PM

Day 3 Time in: NADay 3 Time out:NA

C: Number of Auditor Days Used:(number of auditor x number of days)

1.5 Man days (01 Auditors in 02 day)

D: Audit type: Full InitialPeriodicFull Follow–upPartial Follow–UpPartial Other – Define

E: Was the audit announced? (AAGrecommends a window of three weeks for semi–announced, this gives optimum results)

AnnouncedSemi – announced: Window detail: weeksUnannounced

F: Was the Sedex SAQ available forreview?

YesNo

If No, why not?(Examples would be, site has not completedSAQ, site has not been asked to complete theSAQ.)

Not yet registered.

G: Any conflicting information SAQ/Pre-Audit Info to Audit findings?

YesNo

Not applicableIf Yes, please capture detail in appropriate audit by clause

H: Auditor name(s) and role(s): Veerakumar S Lead Auditor

I: Report written by: Veerakumar S

J: Report reviewed by: Gargi Banerjee

K: Report issue date: 18 March 2016

L: Supplier name: Exotic Fruits Pvt Ltd.

M: Site name: Exotic Fruits Pvt Ltd.


N: Site country: India

O: Site contact and job title: Mr. Ajay Sortee - DGM - Quality Assurance

P: Site address:(Please include full address)

SF NO. 263/1, Bargur Tirupattur Road, Thallabanda Village, SigaralapalliP.O. Bargur Tk, Krishnagiri Dist., Tamil Nadu State – 635 004, India

Site phone: +91-7373012441

Site fax: Not available

Site e–mail: [email protected]

Q: Applicable business and other legallyrequired licence numbers:for example, business license no, andliability insurance

Factory License No - KG 871 valid till 31 Dec 2016

R: Products/Activities at site, for example,garment manufacture, electricals, toys,grower

Processing of Pulp and Concentrates of Mango, Guava, Papaya andTomato

S: Audit results reviewed with sitemanagement?

Yes

T: Who signed and agreed CAPR(Name and job title)

Mr. Ajay Sortee - DGM - Quality Assurance

U: Did the person who signed the CAPRhave authority to implement changes?

Yes

V: Present at closing meeting (Please statename and position, including anyworkers/union reps/worker reps):

Mr. Ajay Sortee - DGM - Quality AssuranceMr. Jitender Singh – General ManagerMr. C. Kasi – Senior Manger – operationsMr. Anil Shinde – DGM – Operation planningMr. K Senthilkumar – Manager Admins

W: What form of worker representation /union is there on site?

Union (name)Worker CommitteeOther (Grievance Committee)None

X: Are any workers covered by CollectiveBargaining Agreement (CBA)

Yes NoNo CBA in the facility

Y: Previous audit date: Not applicable

Z: Previous audit type: SMETA 2–pillar

SMETA 4–pillar

Other

Full Initial


Periodic

Full Follow–UpAudit

Partial Follow–Up

Partial Other*

*If other, please define:


Audit Scope/Actual ResultsCriteria Local Law

(Please state legalrequirement)

Actual at theSite

(Record site resultsagainst the law)

Is this part of aCollectiveBargaining

Agreement?

A: Standard/Contracted work hours:(Maximum legal and actual required working hours excludingovertime, please state if possible per day, week and month)

Legal maximum:08 hours per day/ 48 hours perweek

08 hours per day/ 48 hours perweek

YesNo

Not Applicable

B: Legal Overtime hours:(Maximum legal and actual overtime hours, please state ifpossible per day, week and month)

Legalmaximum:02hours per day /12 hours perweek / 50 hoursper quarter

No overtimehours performedby facility.

YesNo

Not Applicable

C: Legal age of employment:(Minimum legal and actual minimum age at site)

Legal minimum:14 Years foryoung employeesand 18 years forAdult workers

18 Years

D: Legal minimum wage for standard/contracted hours:(Minimum legal and actual minimum wage at site, please stateif possible per hr, day, week and month)

Legal minimum:INR 160 per day

INR 248.00 perday

YesNo

Not Applicable

E: Legal minimum overtime wage:(Minimum legal and actual minimum overtime wage at site,please state if possible per hr ,day, week and month)

Legal minimum:200% of normalrate of wages

200% of normalrate of wages

YesNo

Not Applicable

Audit Scope(Please select the code and additional requirements that were audited against during this audit)

2–Pillar Audit

10B4: Environment 4–Pillar

10C: Business Ethics

All groups of workers are included in the scope of this audit such as; Direct employees, Casualand agency workers, Workers employed by service providers such as security and catering staffas well as workers supplied by other contractors.

Note: The main focus of this ethical audit is on the ETI Base Code and local law. The additional elements will not be audited in suchdepth 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 conductedon the above date only and does not officially confirm or certify compliance with any legal regulations or industry standards. Thesocial 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 auditprocess is a sampling exercise only and does not guarantee that the audited site prior, during or post–audit, are in full compliancewith the Code being audited against. The provisions of this Code constitute minimum and not maximum standards and this Codeshould not be used to prevent companies from exceeding these standards. Companies applying this Code are expected to complywith national and other applicable laws and where the provisions of law and this Code address the same subject, to apply thatprovision which affords the greater protection. The ownership of this report remains with the party who has paid for the audit.Release permission must be provided by the owner prior to release to any third parties.

Audit OverviewAudit Overview

Management Worker Representatives

Audit attendance Senior management Worker Committeerepresentatives

Union representatives

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

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

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

D: If Worker Representatives were notpresent please explain reasons why(only complete if no worker reps present)

Worker Representative was busy in production.

E: If Union Representatives were notpresent please explain reasons why:(only complete if no union reps present)

No union exist in the facility.


F: Site description:(Include size, location and age of site. Alsoinclude structure and number of buildings)

Exotic Fruits Pvt Ltd is located SF NO. 263/1, Bargur Tirupattur Road,Thallabanda Village, Sigaralapalli P.O. Bargur Tk, Krishnagiri Dist., TamilNadu State – 635 004, India. The total land area occupied by the facility isabout 63 acres. And the production area is about 13432 square meters.They have started their operations at this existing location since 2012.

ProductionBuilding no

Description Remark, if any

Building 1 Ground floor :Administration block

None

Building 2 Ground floor :Process

None

Building 3 Ground floor : Boilersection

None

Building 4 Ground floor :Generator block

None

Building 5 Ground floor , Firstfloor and secondfloor : Dormitorysection

None

Building 6 Ground floor andFirst floor : Staffdormitory

None

Is this a sharedbuilding? No NA

G: Site function: AgentFactory Processing/ManufacturerFinished Product SupplierGrowerHomeworkerLabour ProviderPack HousePrimary ProducerService ProviderSub–Contractor

H: Month(s) of peak season:(if applicable)

Peak seasons from May to July.

I: Process overview:(Include products being produced, main operations, number of production lines, main equipment used)

The facility is involved in the process of Pulp and Concentrates of Mango, Guava, Papaya and Tomato.

The main production processes are listed as follows:

Raw material – Ripening – Fruit washing – Extraction – Filling – Storage – Dispatch.

A total of 85 employees are currently working in the facility, which included 78 production employees and 07 nonproduction employees. Out of 85 employees, 66 are male and 19 are female employees. Out of 85 employees 40


employees are directly engaged by the company and 45 employees are engaged through 3 contractors. The facilityhad not employed any foreign nationals. Employee paid on Monthly basis on every month on or before of 7th. Theemployees work 6 days a week in single shift.

The working hours are as under:

General ShiftNormal Working Hours : 09.00 am to 5.30 pmMorning tea break : 15 min staggeredLunch break : 1.00 pm to 01.30 pmEvening tea break : 15 min staggeredWeekly Holiday : Sunday

First ShiftNormal Working Hours : 07.00 am to 3.00 pmMorning tea break : 15 min staggeredLunch break : 12.30 pm to 01.00 pmEvening tea break : 15 min staggeredWeekly Holiday : Sunday

Second ShiftNormal Working Hours : 03.00 pm to 11.00 pmMorning tea break : 15 min staggeredLunch break : 09.00 pm to 09.30 pmEvening tea break : 15 min staggeredWeekly Holiday : Sunday

Third ShiftNormal Working Hours : 11.00 pm to 09.00 amMorning tea break : 15 min staggeredLunch break : 02.30 pm to 03.00 pmEvening tea break : 15 min staggeredWeekly Holiday : Sunday

A total of 10 employees were interviewed and the same numbers of records were reviewed for the months of January2016 (Current month), June 2015 (Peak month) and March 2015 (Non peak month).

J: Attitude of workers:(Include their attitude to management, workplace and the interview process. Both positive and negative information should beincluded) Note: Do not document any information that could put workers at risk

Based from interview with employees, it was noted that all employees were satisfied with the facility management andno negative comments were received.

K: Attitude of workers committee/union reps:(Include their attitude to management, workplace and the interview process. Both positive and negative information should beincluded) Note: Do not document any information that could put workers at risk

Based from interview with Works committee Representative, it was noted that all employees were satisfied with thefacility management and no negative comments were received.

L: Attitude of managers:(Include attitude to audit, and audit process. Both positive and negative information should be included)


The facility management was cooperative throughout the audit; all documents were made available for review on time.At the end of the audit the management accepted to correct all the findings raised.


Key InformationKey Information

(click on the key information title to go to appropriate section of the report)

A: Do all workers (including migrant workers)have contracts of employment/employmentagreements?(Go to clause 8 – Regular Employment)

YesNo

B: Are maximum standard/contractedworking hours clearly defined incontract/employment agreements?(Go to clause 8 – Regular Employment)

YesNo

C: Were appropriate records available toverify hours of work and wages?(Go to clause 5 – Living Wage)

YesNo

D: Were any inconsistencies found?(if yes describe nature)(Go to Wages Table)

Yes Poor record keepingNo Isolated incident

Repeated occurrence

E: For the lowest paid production workers,are wages paid for standard/contractedhours (excluding overtime) below or abovethe legal minimum?(Go to clause 5 – Living Wage)

Wages found: Please indicate the breakdown of workforceaccording to earnings:

Below legalmin

MeetAbove

____% of workforce earning under min wage100___% of workforce earning min wage

% of workforce earning above min wage

F: % of piece rate workers:(if applicable)

0%. Piece rate work is not engaged in the facility.

G: Do the standard/contracted hours statedin a contract/employment agreement exceedthe law or 48 hours per week?(Go to clause 6 – Working hours)

YesNo

H: If yes, what are the standard/contractedhours per week as stated in thecontract/employment agreement?(Go to clause 6 – Working hours)

NA - hrs/week Approx. _NA___% of ALL workers on thesecontacted hours

I: Combined hours (standard/contracted plusovertime = total hours) over 60 per weekfound?(Go to Working Hours Analysis)

YesNo

J: Are workers provided with 1 day off inevery 7-day-period, or 2 in 14-day-period(where the law allows)?

YesNo

If ‘No’, please explain:


K: Are the correct legal overtime premiumspaid?(Go to Wages Table)

YesNoN/A – there is no legal requirement to OT premium

L: Please state what actual OT is paid.(As a percentage of the workers standard rate)(Go to Working Hours Analysis)

Please give details of overtime premium as a % of standard wages:0%1% – 115%116% – 124%125% – 199%200%+

Please give details: It was noted through review of records and auditprocess that facility has paid the overtime wages at a rate of 200%from normal rate of wages.

M: Is there any night production work at thesite?

YesNo

N: % of workers living in site providedaccommodation (if applicable):

Not applicableFacility does not provide accommodation to its workers further; it is nota legal requirement.

O: Age of youngest worker found:(Go to clause 4 – Child labour)

18 Years

P: Workers under 18 subject to hazardouswork assignments?(Go to clause 3 – Health and Safety)

YesNo

NA

% of under 18’s at this site (of total workers) 0%

Q: What form of worker representation/unionis there on site?(Go to clause 2 – Freedom of Association)

Union (name)Worker CommitteeOther (Grievance committee)None

R: Is it a legal requirement to have a union?(Go to clause 2 – Freedom of Association)

YesNo

S: Is It a legal requirement to have a workerscommittee?(Go to clause 2 – Freedom of Association)

YesNo

T: Is there any other form of effectiveworker/management communicationchannel? (Other than union/worker committee)(Go to clause 2 – Freedom of Association)

YesNo

Describe: Suggestion Box provided

U: Are there any External Processes?(Go to clause 8A – Sub–contracting and Homeworking)

Sub–ContractingHomeworkingOther External ProcessNo external processes


Management SystemsManagement Systems:

A: Nationality of Management Indian

B: Gender breakdown of Management +Supervisors (Include as one combined group)

Male : 77 %Female : 33 %

C: Majority nationality of workers 100% of the workers are Indians.

D: Number of workers leaving in last 12months as a % of average total number ofworkers on site over the year (annual workerturnover)

1 %

E: Were accurate records shown at the firstrequest?

YesNo

F: If No, why not? NA

G: In the last 12 months, has the site beensubject to any fines/prosecutions for non–compliance to any regulations?

YesNo

Please describe: No such fine imposed on the site till date..

H: Do policies and/or procedures exist thatreduce the risk of forced labour, child labour,discrimination, harassment & abuse?

YesNo

Please describe: The facility has established the policies andprocedure with respect to social compliance.

I: If Yes, is there evidence (an indication) ofeffective implementation? Please givedetails.

Facility has formed harassment & abuse committee and the meetingwas conducted on monthly basis, last meeting dated on December 14,2015. Facility has displayed child labor policy and all employees wereaware on the same.

J: Have managers and workers receivedtraining in the standards for forced labour,child labour, discrimination, harassment &abuse?

YesNo

Please describe: Facility has trained all the employees on ETI basecode and last such training was conducted on 5th February 2016.

K: If yes, is there evidence (an indication)that training has been effective e.g. trainingrecords etc.? Please give details

All interviewed employees conformed that they are aware about all 09codes mentioned in ETI base code.

L: Are there published, anonymous and/oropen channels available for reporting anyviolations of Labour standards and H&S orany other grievances to a 3rd party?

YesNo

Please describe: Health & Safety, Grievance committee andPrevention of Sexual Harassment Committee and Suggestion Box.

M: If yes, are workers aware of thesechannels? Please give details.

Yes. Workers are aware about Health & Safety, Grievance committeeand Prevention of Sexual Harassment Committee established in thefacility and its committee members, further workers are also aware


about Suggestion box and its purpose.

N: Have health and safety risks beenidentified e.g. through internal audits, formalrisk analysis process, worker involvementetc.?

YesNo

Please describe: Facility has formed health & safety committee and themeeting was conducted on monthly basis, last meeting dated onDecember 16, 2015.

O: If yes, has effective action been taken toreduce or eliminate these risks?

Yes.

P: Are accidents recorded? YesNo

Please describe: Accidents records available at the facility however noaccidents were happened in the facility.

Q: Has the auditor made a simple calculationto compare capacity with workers’ work loadin order to identify possible unrecorded workhours?

YesNo

Please describe: Auditor has cross verified Production records andbroken needle records.

R: Does the site have all required land rightslicenses and permissions (see SMETAMeasurement Criteria)?

Facility has obtained all the legal statutory licenses and approvals torun the facility.

S; Does the site have any internationallyrecognised system certifications e.g. ISO9000, 14000, OHSAS 18000, SA8000 (orother social audits).Please detail (Number and date).

None.

T: Is there a Human Resourcesmanager/department?If Yes, please detail.

YesNo

Please describe: Facility has Human Resource Department staffheaded by Mr. K Senthil kumar


Worker Analysis

Worker Analysis

Local MigrantTotal

Permanent Temporary Agency Permanent Temporary Agency Homeworkers

Worker numbers –male 39 00 27 00 00 00 00 66

Worker numbers –female 01 00 18 00 00 00 00 19

Total 40 00 45 00 00 00 00 85

Number of Workersinterviewed 04 00 06 00 00 00 00 10

Contractors:(Individuals supplying workers to site with the workers paid by contractors, not by site)

A: Any contractors on site? YesNo

B: If Yes, how many workers supplied bycontractors 45 employees are engaged through 3 contractors.

C: Are all contractor workers paid accordingto law?

YesNo

If Yes, Please give evidence for contractorworkers being paid according to law:

As per the review of wage paid records and time records, it was notedthat all the employees are paid as per the legal requirement.

Migrant Workers:(Please see SMETA Best Practice Guidance and Measurement Criteria for definitions of migrant workers)

D: OriginatingLocations/Countries:

All employees working in the facility are Indian Nationals and no Migrantemployees engaged.

E: Type of work undertaken bymigrant workers :

Not Applicable

F: Were migrant workersrecruited through an agency?If yes, please give details.

YesNo

Please describe: Not applicable


If Yes, is there a contract withthe agency? Provide details ofagencies and contractualarrangements including any feeslodged during the recruitmentprocess.

Not applicable

G: Does the site have a systemfor checking labour standards ofagencies?If yes, please give details.

YesNo

Please describe: Not applicable

H: Percentage of migrantworkers in company providedaccommodation:

Not applicable


Audit Results by Clause0: Management systems and Code Implementation

0: Managements system and Code Implementation(click here to return to NC Table)

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 theprinciples of this Ethical Code through their supply chain.

Current Systems and Evidence ExaminedTo complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, tounderstand, 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 anydocumentary or verbal evidence shown to support the systems.

Current systems:

1. Based from facility tour and review of records, facility has implemented the ETI base code and the code has beendisplayed in notice board and communicated to all the employees during induction training.2. Mr. Ajay Sortee - DGM - Quality Assurance is responsible for compliance with the code.3. Based from review of records and interaction with management facility has communicated the ETI base code totheir suppliers and sub-contractors and obtained a commitment from them to comply with this code requirement.4. Facility has obtained certified standing order from Labor commissioner.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):

Standing Order dated 11th May 2015. Facility Policy and Procedures. Facility License valid till 31st December 2016. ETI base code. Interaction with Management and Interview with employees.

Non–compliance:

Description of non-compliance:NC against ETI NC against Local Law:

None observed

Local law or ETI requirementNot applicable

Recommended corrective action:Not applicable

Objective evidenceobserved:Not applicable


Observation:

Description of observation:None Observed

Local law or ETI requirement:Not Applicable

Comments:Not Applicable

Objective evidenceobserved:

Not Applicable

Good Examples observed:

Description of Good Example (GE):None Observed

Objective EvidenceObserved:Not Applicable


1: Employment is Freely Chosen

1: Employment is Freely Chosen(Click here to return to NC–table)

ETI1.1 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 toleave their employer after reasonable notice.

Current Systems and Evidence ExaminedTo complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, andrecord what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, whois/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:1. Based from employees’ interview, the facility does not require any deposit or deposit of employee’s identificationsuch as education certificates and passport.2. Based from employee’s interview, the facility does not limit the employee’s freedom in any way.3. Based from the facility tour and interview with employees, there are no evidences of involuntary labor.4. Based from employee’s interview, all are free to leave their employment by giving reasonable notice.


Facility Policy and Procedures. Standing Order dated 11th May 2015. Appointment Letter of 10 out of 10 selected samples and Payroll records. Interaction with Management and Interview with employees.

Non–compliance:

1. Description of non–compliance:NC against ETI NC against Local Law:

None Observed

Local law or ETI requirementNot Applicable

Recommended corrective action:Not Applicable

Objective evidenceobserved:Not Applicable


Observation:




Objective evidenceNot Applicable

Not Applicable





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 NC–table)

(Click here to return to Key Information)

ETI2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargaincollectively.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 representativefunctions in the workplace.2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employerfacilitates, and does not hinder, the development of parallel means for independent and free association andbargaining.



Current systems:1. Based from employee’s interview, employees can approach top management directly to report their grievancesand necessary corrective action is taken by the management.2. Facility has formed a Grievance Committee and conducted meetings on monthly basis and the minutes ofmeetings are recorded for verification and future reference.3. Based from employee’s interview, the facility does not restrict employees from organizing trade unions and hasan open mind approach towards the activities of trade unions and their organizational activities.


Facility Policy and Procedures. Suggestion Box registers. Grievance committee dated 04th February 2016. Interaction with Management and Interview with employees.

Non–compliance:


None observed





Observation:





Not Applicable

A: Name of union and unionrepresentative, if applicable:

No union in this facility Is there evidence of free elections?Yes No N/A

B: If no union what is parallel means ofconsultation with workers e.g. workercommittees?

Worker Committee andGrievance Redressal Committee.

Is there evidence of free elections?Yes No N/A

C: Were worker representatives/unionrepresentatives interviewed

Yes NoIf Yes, please state how many:02

D: State any evidence thatunion/workers committee is effective?Specify date of last meeting; topics covered;how minutes were communicated etc.

Facility has formed a Workers Committee and conducted meetings onmonthly basis and the minutes of meetings are recorded for verificationand future reference. Last Works Committee meeting was conducted on14th February 2016. Last grievance committee dated 04th February 2016

E: Are any workers covered byCollective Bargaining Agreement (CBA)

Yes NoNot applicable :No CBA

F: If Yes what percentage by tradeUnion/worker representation

_Nil_% workers covered byUnion CBA

_Nil_% workers covered by workerrep CBA

G: If Yes, does the CollectiveBargaining Agreement (CBA) includerates of pay

YesNo

Not applicable





3: Working Conditions are Safe and Hygienic

3: Working Conditions are Safe and Hygienic(Click here to return to NC–table)


ETI3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of theindustry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to healtharising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonablypracticable, 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 fornew or reassigned workers.3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shallbe 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 managementrepresentative.



Current systems:1. Mr. Ajay Sortee - DGM - Quality Assurance is responsible for Health and Safety.2. Based from facility tour, the facility has provided 20 toilets for male and 10 toilets for female and this complieswith legal requirement.3. Based from facility tour and review of training records, the facility has trained 22 employees for the use of fireextinguishers on 22nd February 2016 and provided 86 fire extinguishers, in facility which found sufficient. Facilityhas marked all the exits and emergency exits in a language understood by majority of the employees.4. Based from facility tour and review of records, the facility has provided well equipped 36 first aid boxes and alsotrained 34 no’s through St.Johns Ambulance for First Aid activities on 18th April 2015 and maintains records forsame.5. Based from facility tour and employees interview, the facility has provided purified drinking water facility to all theemployees free of cost.6. Based from the facility tour, the facility was well ventilated and the facility area was kept clean both inside andoutside7. Based on training record review, facility gives periodic occupational health & safety training to their employeesonce in a month.9. Based on record review and from employees interview facility has conducted Fire Evacuation drill once in 02months and last drill conducted on 22nd February 2016.


Factory License – Valid till 31st December 2016. Fire License valid for 01 year from 13th January 2016. Approved Building Plan dated 24th July 2015. Stability Certificate dated 02nd March 2015 and it is valid for 03 years from the date of issue. Sanitation Certificate dated 20th May 2015.


Generator Installation Certificate for 02 no’s (700 KVA & 125 KVA). Industrial accident records – Updated till February 2016. Health & Safety Committee meeting minutes dated 14th February 2016. Fire fighting Training records dated 22nd February 2016. Fire Evacuation drill records dated 22nd February 2016. First Aid Training records dated 18th April 2015. Drinking Water Test report dated 16th February 2016. Interaction with Management and Interview with employees.

Non–compliance:


None observed




Observation:





Not Applicable





4: Child Labour Shall Not Be Used

4: Child Labour Shall Not Be Used(Click here to return to NC–table)


ETI4.1 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 thetransition of any child found to be performing child labour to enable her or him to attend and remain in qualityeducation 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:1. Based from interaction with HR manager, all employees are hired by the Human Resource Department only.2. Based from review of hiring policy documents, employee’s ID for age proof such as Voter ID, Dental certificate &School transfer certificate was checked by HR department prior to hiring. The employees without valid IDcertificates are not being hired.3. Based from the policy review, the minimum hiring age of the facility is 18 years old.4. Based from employees’ interview, any suspect of child labor can be reported to facility management.5. Based on the employee interviews, review of facility’s Anti Child Labor & Hiring Policy and age proof documents,the facility has complied with ILO Standards for Child Labor.6. Based on record review facility has maintained valid Age proof records for 10 out of 10 selected employees.


Child Labor and Child Labor Remediation Policy. Age Proof records of 10 out of 10 selected samples. Interaction with Management and Interview with employees.

Non–compliance:


None observed





Observation:





Not Applicable





5: Living Wages are paid

5: Living Wages are Paid(Click here to return to NC–table)

(Click here to return to Key information)

ETI5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industrybenchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs andto provide some discretionary income.5.2 All workers shall be provided with written and understandable information about their employment conditions inrespect to wages before they enter employment and about the particulars of their wages for the pay periodconcerned each time that they are paid.5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wagesnot provided for by national law be permitted without the expressed permission of the worker concerned. Alldisciplinary measures should be recorded.



Current systems:1. A total of 26 employees were interviewed and the same numbers of records were reviewed for the month ofJanuary 2016, June 2015 and March 2015.2. Based from review of wage records, the facility has paid the applicable minimum wages to all the employees.3. Based from employee’s interview, wages are paid on monthly basis on or before 07th day after the end of wageperiod.4. Based from employee’s interview, wage slips are provided to all the employees and employees are aware oftheir wage calculations.5. Based from wage record review, all employees are covered under social security benefits of Employeesprovident fund & Employees State Insurance.6. Deductions from wages as a disciplinary measure and any other illegal deductions are not permitted as per thefacility rules.7. Based on employee’s interview and record review all the employees are received appointment letter with writtenand understandable information about their employment conditions in respect to wages.8. Based on record review and from employees interview overtime hours are compensated at 200% of the normalrate of wages for all employees.


Facility Policy. Salary register, Pay slip and Time records for 10 selected samples for 10 Random months. Employees Provident Fund & Employees State Insurance challans. Leave with wage records (Form No: 15) and Leave encashment records. Bonus paid records. Settlement paid records. List of National and Festival Holidays. Interaction with management and Employees.


Non–compliance:

Description of non-compliance:

NC against ETI NC against Local Law:

None Observed.

Local law or ETI requirement

Not applicable

Recommended corrective action:

Not applicable


Based on the documentReview.

Observation:





Not Applicable




Wages analysis:


Wages analysis:(Click here to return to Key Information)

A: Sample Size Checked(State number of worker records checked and fromwhich weeks/months – should be current, peak andrandom/low. Please see SMETA Best PracticeGuidance and Measurement Criteria)

A total of 10 employees were interviewed For the Current monthJanuary 2016, Peak month June 2015 and Non peak monthMarch 2015 .

B: Are there different legal minimum wagegrades? If Yes, please specify all.

YesNo

If Yes, please give details:Facility does notcome under any prescribed minimum wages ofthe scheduled industries; hence National floorlevel minimum wages INR 160 per day isapplicable to facility.:

C: If there are different legal minimum grades,are all workers graded correctly?

YesNoN/A

If No, please give Not applicable:

D: What deductions are required by law e.g.social insurance? Please state all types:

Employee Provident Fund & Employees State Insurance isrequired by Law and the prescribed amounts are deducted fromthe employee’s wages.

E: Have all of these deductions been made?Please list all deductions that have/have notbeen made.

YesNo

If Yes, Please list all deductions that have beenmade: Employee Provident Fund & EmployeesState Insurance.

If No, please give details on any deductionswhich have not been made:

F: Industry norm for this region:(please include time period e.g. hour/week/month)

In accordance with Minimum Wages Act 1948, Section 12

Wages table


Wages table(Click here to return to Key information)

Worker Type Process Operator(Lowest paid)

Process Operator(Average paid)

Process Operator(Highest paid)

Select from individual worker records one worker from, lowest, average and highest wages and populate theboxes. Ensure comparison is made for same pay period and only uses full–time workers. See SMETA Best

Practice Guidance and Measurement Criteria for completing this:

A: Pay period:(State month selected)

January 2016 January 2016 January 2016

B: Anonymous EmployeeReference/Dept. Production worker Production worker Production worker

C: Employee Gender Male Female Female

D: Contracted/Standardworking hours:(excluding OT – please includetime period e.g.hour/week/month)

120 Hours per month 160 Hours per month 184 Hours per month

E: Contracted /Standardwork pay rate:(excluding OT – please includetime period e.g.hour/week/month)

INR 261 per day INR 261 per day INR 261 per day

F: Standard day overtime –hours:(please include time period e.g.hour/week/month)

No overtime Performed No overtime Performed No overtime Performed

G: Standard day overtime –wage:(please include time period e.g.hour/week/month)

Not applicable Not applicable Not applicable

H: Rest day overtime –hours: (please include timeperiod e.g. hour/week/month)


I: Rest day overtime – wage:(please include time period e.g.hour/week/month)

Not applicable Not applicable Not applicable

J: Statutory Holiday overtime– hours:(please include time period e.g.hour/week/month)

No overtime performed No overtime performed No overtime performed


K: Statutory holiday OT –wages:(please include time period e.g.hour/week/month)

Not Applicable Not Applicable Not Applicable

L: Total overtime hours:(please include time period e.g.hour/week/month)


M: Incentives/Bonus/Allowances etc.:(please include time period e.g.hour/week/month)

Not Applicable Not Applicable Not Applicable

N: Gross wages:(please include time period e.g.hour/week/month)

INR 3915 per month INR 5220 per month INR 6003 per month

O: Social insurance andother deductions; please listwhich and amount.

INR 446 per month –Provident fund

INR 595 per month-Provident fund

INR 684 per month -Provident fund

P: Actual wage paid afterdeduction:(please include time period e.g.hour/week/month)

INR 3469 per month INR 4625 per month INR 5319 per month

Comments:This section could not be verified due to non availability of time records for any of the employees .wages)

The lowest and highest gross wages were depend on total number of hours worked by the employees. There areno other specific things that influence the gross wages.

Q: Is there a defined living wage:This is not normally minimum legalwage. If answered Yes please stateamount and source of info:Please see SMETA Best PracticeGuidance and Measurement Criteria.

YesNo. However facility is paying more than National Floor level Minimum

wages.Please specify amount/time period: Not applicable

R: Are workers paid in a timelymanner in line with local law?

YesNo

S: Is there evidence that equal ratesare being paid for equal work:

YesNo

Details:

T: How are workers paid: Cash – 10 %ChequeBank Transfer – 90 %Other

If other explain: Not applicable


6: Working Hours are not Excessive

6: Working Hours are not Excessive(Click here to return to NC–table)


ETI6.1 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 labourstandards.

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: theextent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used toreplace regular employment. Overtime shall always be compensated at a premium rate, which is recommended tobe 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 6.5below.

6.5 Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all of thefollowing are met:

– this is allowed by national law;– this is allowed by a collective agreement freely negotiated with a workers’ organisation representing asignificant 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 productionpeaks, 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, 2days off in every 14 day period.



Current systems:

1. A total of 10 employees were interviewed and the same numbers of records were reviewed for the month ofJanuary 2016, June 2015 and March 2015.2. Based from facility tour, working hours including breaks and weekly rest day are displayed on notice board.3. The facility has Bio-metric finger print time recording system to record all the employees IN/OUT time. Basedfrom the review of time records, employees are observed to be working 08 hours per day and 48 hours per week,and facility has not engaged any of the employees for overtime work in sampled months.4. Based from record review and interview with employees 01 day of week off is provided to all employees on everySunday.

5. Working hours analysis as follows, For January 2016 (current month), the average working hours of 10 selected samples were 37.23


hours/week. Maximum working hours per week were 48 hours (10 out of 10 selected samples).

For June 2015 (Peak month), the average working hours of 10 selected samples were 41.72 hours/week.Maximum working hours per week were 48 hours (10 out of 10 selected samples).

For March 2015 (Non peak month), the average working hours of 10 selected samples were 18.00hours/week. Maximum working hours per week were 48 hours (10 out of 10 selected samples).


Facility Policy. In/Out time records and Salary register for 10 selected samples for 03 Random months. Interaction with management and Employees.

Facility working hours details.

Non–compliance:

Description of non-compliance:NC against ETI NC against Local Law

None observed

Local law or ETI requirement:Not applicable



Observation:





Not Applicable





Working hours analysis

Working hours analysisPlease include time period e.g. hour/week/month

(Go back to Key information)

Systems & Processes

A. What timekeeping systems areused: time card etc.

Bio-metric finger print time recording system

B: Sample Size Checked(State number of worker recordschecked and from whichweeks/months and type – should becurrent, peak and random/low: SeeSMETA Best Practice Guidance andMeasurement Criteria)

A total of 10 employees were interviewed and the same numbers ofrecords were reviewed for the month of January 2016, June 2015 andMarch 2015.

C: Do ALL workers havecontracts/employment agreements?

YesNo

If NO, state which type of workers do NOT havecontracts/employment agreements: Facility notmaintained the records.

D: Are standard/contracted workinghours defined in allcontracts/employment agreements?

YesNo

If NO, please state which type of workers NOT standardhours have define in contracts/employment agreements.

E: Are there any other types ofcontracts/employment agreementsused?

YesNo

If YES, Please complete as appropriate:

0 hrs Part time Variable hrs Other

If “Other”, Please define:

Standard/Contracted Hours worked

F: Do standard/contracted standardhours ever exceed the law or 48hours per week?

YesNo

If YES give details and comparison (local law/48 hrsweek)

G: What are the actualstandard/contracted hours worked insample (State per week/month)

Highest hours: 44.06 Hours per week in the month of January 201648.00 Hours per week in the month of June 201518.00 Hours per week in the month of March 2015

Lowest hours: 30.00 Hours per week in the month of January 201638.00 Hours per week in the month of June 2015


18.00 Hours per week in the month of March 2015

H: Any local waivers/local law orpermissions which allowaveraging/annualised hours for thissite?

YesNo

If YES, Please give details

Not applicable

Overtime Hours

I: Actual overtime hours worked insample (State per day/week/month)

Highest OThours:

No overtime performed

Lowest OThours:


J: Range of overtime hours over allworkers/or as large a sample aspossible. (State per week/month anddetails)


K: Approximate percentage ofworkers on highest overtime hours

NA - No overtime performed

L: Is overtime voluntary? YesNoConflicting

Information

Please detail evidence e.g. Wording ofcontract/employment agreement/handbook/workerinterviews/refusal arrangements:


Overtime Premiums

M: Is overtime paid at a premium? YesNo

Please give details of normal day overtime premium as a% of standard wages:

0% 1 –115%

116 –124%

125 –149%

150 –199%

200%+

Any other comments: Facility has the policy ofcompensating all the overtime hours at 200% of thenormal rate of wages; however facility has not engagedany of the employees on overtime work in sampledmonths.

N: ETI Code requires a prevailingstandard to give greatest workerprotection.If a site pays less than 125% OTpremium and this is allowed underlocal law, are there other

NoConsolidated pay (May be standard wages above minimum legal wage, with

no/low overtime premium)Collective Bargaining agreementsOther: Not applicable.

Please explain any checked boxes in N above e.g. detail of consolidated


considerations? Please complete theboxes where relevant. Multi select ispossible.

pay CBA or Other.

Not applicable

Rest Days

O: Are workers provided with 1 dayoff in every 7–day–period, or 2 in 14–day–period (where the law allows)?

YesNo

Maximum number of days worked without a day off (insample):

Based on the interaction with management andemployees Workers were provided with 1 day off once inevery 6 continuous days.

Total Hours

P: Range of total hours:(Quote highest and lowest please includetime period e.g. hour/week/month)

Highest totalhours

44.06 Hours per week in the month of January 201648.00 Hours per week in the month of June 201518.00 Hours per week in the month of March 2015

Lowest totalhours

30.00 Hours per week in the month of January 201638.00 Hours per week in the month of June 201518.00 Hours per week in the month of March 2015

R: If more than 60 total hours perweek and this is legally allowed, arethere other considerations? Pleasecomplete the boxes where relevant.Multi select is possible.

Overtime is voluntaryOnsite Collective bargaining allows 60+ hours/weekSafeguards are in place to protect worker’s health and safetySite can demonstrate exceptional circumstancesOther reasons

Please explain any checked boxes in R above

Facility has restricted the total working hours to 48 hours per week.

Comments:(please state here any specific reasons/circumstances that explain the highest working hours)

Based on the review of time records for the sampled months, the highest working hours is 176.24 hours per monthand lowest working hours is 72.00 hours per month which is based on the employee’s interest to be present for theworkplace and it complies with local laws.


7: No Discrimination is practiced

7: No Discrimination is Practiced(Click here to return to NC–table)

ETI7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirementbased on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, unionmembership or political affiliation.



Current systems:1. Based from review of wage records and employees interview, no discrimination was noted in hiring,compensation, access to training, promotion, termination or retirement.2. Mr. Ajay Sortee - DGM - Quality Assurance is responsible for the investigation and disposal of discriminationcase.3. Based from wage records review, the facility provides the same pay for male/female employees for same work ofsimilar nature.


Facility Policy. Appointment letter with terms and conditions for 10 out 10 selected samples. Salary and other benefit records. Interaction with management and Employees.

Non–compliance:

1. Description of non–compliance:NC against ETI NC against Local Law

None Observed




Not Applicable


Observation:





Not Applicable





8: Regular Employment Is Provided

8: Regular Employment Is Provided(Click here to return to NC–table)


ETI8.1 To every extent possible work performed must be on the basis of recognised employment relationshipestablished through national law and practice.8.2 Obligations to employees under labour or social security laws and regulations arising from the regularemployment relationship shall not be avoided through the use of labour–only contracting, sub–contracting, orhome–working arrangements, or through apprenticeship schemes where there is no real intent to impart skills orprovide regular employment, nor shall any such obligations be avoided through the excessive use of fixed–termcontracts of employment.



Current systems:

1. Based on record review and employees interview Appointment letters issued to all 10 out of 10 selectedemployees.2. Based from interaction with the facility management, it was noted that all employees are employed on regularrolls of the facility and no apprentices or trainees were engaged.3. 45 employees are engaged through 3 contracts.


Facility Policy. Appointment letter with terms and conditions for 10 out 10 selected samples. Salary and other benefit records. Interaction with management and Employees.

Non–compliance:


None observed





Observation:





Not Applicable





8A: Sub–Contracting and Homeworking:

8A: Sub–Contracting and Home working(Click here to return to NC–table)


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 arein place.



Current systems:

Based from the interaction with the facility management and employees interview, the facility does not engage anyHome workers and subcontractors for any of their manufacturing process.


1. Facility Policy.2. Inward and out ward material register.3. Production records.4. Interaction with management.

If any processes are sub–contracted – please populate below boxesProcess Subcontracted Process 1 Process 2Name of factoryAddress

Process Subcontracted Process 3 Process 4Name of factoryAddress

Process Subcontracted Process 5 Process 6Name of factoryAddress


Non–compliance:

1. Description of non–compliance:NC against ETI/Additional Elements NC against Local Law

None Observed




Not Applicable

Observation:





Not Applicable





Summary of sub–contracting – if applicable

Summary of sub–contracting – if applicable

A: If sub–contractors are used, isthere evidence this has been agreedwith the main client?

YesNo

If Yes, summarise details:

NA – No Sub-contractors used.

B: Number of sub–contractors/agents used


C: Is there a site policy on sub–contracting?

YesNo

If yes, summarise details:


D: What checks are in place toensure no child labour is being usedand work is safe?


E: What processes are sub–contracted?


Summary of homeworking – if applicable

F: If homeworking is being used, isthere evidence this has been agreedwith the main client?

YesNo

If Yes, summarise details:NA – Facility is not using any Home workers

G: Number of homeworkers Male: Nil Female: Nil Total: Nil

H: Are homeworkers employed director through agents?

DirectlyThrough Agents

Not applicable

I: If through agents, number ofagents

Not applicable

J: Is there a site policy onhomeworking?

YesNo

Not applicable

K: How does site ensure workerhours and pay meet local laws forhomeworkers?

Not applicable

L: What processes are carried out byhomeworkers?

Not applicable


M: Are written agreements in placefor homeworkers that include regularemployment?

YesNo

Not applicable

N: Are full records available at thesite?

YesNo

Not applicable


9: No Harsh or Inhumane Treatment is allowed

9: No Harsh or Inhumane Treatment is Allowed(Click here to return to NC–table)

ETI9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse orother forms of intimidation shall be prohibited.

Current Systems and Evidence ExaminedTo complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and

record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to


Current systems:Based from the interaction with the facility management and employee’s interview, it is noted that no case of abuseor discipline has happened in the facility, and the facility has a written disciplinary procedure that is displayed in thenotice board of the facility.


Facility Policy. Standing Order dated 11th May 2015. Interaction with management and Employees.

Non–compliance:


None observed





Observation:





Not Applicable





10 A: Entitlement to Work and Immigration

10. Other Issue areas: 10 A: Entitlement to Work and Immigration(Click here to return to NC–table)

Additional Elements10A1 Only workers with a legal right to work shall be employed or used by the supplier.10A2 All workers, including employment agency staff, must be validated by the supplier for their legal right to workby reviewing original documentation.10A3 Employment agencies must only supply workers registered with them.10A4 The supplier shall implement processes to enable adequate control over agencies with regards the abovepoints and related legislation.



Current systems:1. The facility has not engaged any immigrant employees in the facility.2. Based from the review of employee attendance records and employee’s interview, the facility has not employedany foreign nationals.3. Based from the review of employee personal files, all the employees are holding the legal rights to work.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):Interaction with management and Employees..

Non–compliance:

1. Description of non–compliance:NC against ETI/Additional Elements NC against Local Law

None Observed




Not Applicable


Observation:





Not Applicable

Good examples observed:




10B4: Environment 4–Pillar

10. Other issue areas 10B4: Environment 4–Pillar(Click here to return to NC–table)

To be completed for a 4–Pillar SMETA Audit and remove the previous page which is 10B2 environment 2 pillar

B.4. Compliance Requirements10B4.1 Suppliers as a minimum must meet the requirements of local and national laws related to environmentalstandards.10B4.2.Where it is a legal requirement, suppliers must be able to demonstrate that they have the relevant validpermits including for use and disposal of resources e.g. water, waste etc.10B4.3. The supplier shall be aware of their end client’s environmental standards/code requirements and have asystem in place to monitor their performance against these.B4. Guidance for Observations10B4.4. Suppliers should have completed the appropriate section of the SAQ and made it available to the auditor.10B4.5. Suppliers should have an environmental policy, covering their environmental impact, which iscommunicated to all appropriate parties, including its own suppliers.10B4.6. Suppliers shall be aware of the significant environmental impact of their site and its processes.10B4.7. The site should measure its impacts, including continuous recording and regular reviews of use anddischarge of natural resources e.g. energy use, water use (see 4–pillar audit report and audit checks for details).10B4.8. Suppliers shall seek to make continuous improvements in their environmental performance.10B4.9. Suppliers shall have available for review any environmental certifications or any environmentalmanagement systems documentation10B4.10. Suppliers should have a nominated individual responsible for co–ordinating the site’s efforts to improveenvironmental performance.10B.4.11. Has the site recently been subject to (or pending) any fines/prosecutions for noncompliance toenvironmental regulations.

Note for auditors and readers. This environment section is intended to take not more than 0.25 auditor days. It is anassessment only and the main requirement is to establish whether a site is meeting applicable environmental lawsand/or has any certifications or environmental management systems in place. Following this assessment theclient/supplier may decide a full environmental audit is required (see also best practice guidance/environment andguidance for auditor)



Current systems:

Based on management interaction, facility and their suppliers are aware the environmental requirements


1. Facility Policy.2. Interaction with management and Employees.


Non–compliance:

Description of non-compliance:NC against ETI/Additional Elements NC against Local Law

None observed

Local law or ETI /Additional Elements requirement:Not applicable



Description of observation:None observed

Local law or ETI/Additional Elements requirement:Not applicable

Comments:Not applicable






Environmental Analysis

Environmental Analysis(Site declaration only – this has not been verified by auditor. Please state units in all cases below.)

A; Responsible for Environmental issues (Name andPosition):

Mr. Ajay Sortee - DGM - Quality Assurance

B: Does the site have a recognised environmentalsystem certification such as ISO 14000 or equivalent?Please detail.

Yes NoDetails:

C: Does the site have an Environmental policy?(For guidance, please see Measurement criteria )

Yes No

Does the site have a Biodiversity policy?(For guidance, please see Measurement criteria )

Yes No

E: Is there any other sustainability systems present suchas Chain of Custody, Forest Stewardship Council(FSC), Marine Stewardship Council (MSC) etc.?Please detail.(For guidance, please see Measurement criteria )

Yes NoDetails:

F: Have all legally required permits been shown?Please detail.

Yes NoDetails: Pollution consent

G: Is there a documentation process to recordhazardous chemicals used in the manufacturingprocess?

Yes No N/ADetails:

H: Is there a system for managing client’s requirementsand legislation in the destination countries regardingenvironmental and chemical issues?

Yes NoDetails:

Usage/Discharge analysis

Criteria Current year: Please state period:___2016____

Previous Year: Please state period:___2015_____

Electricity Usage:Kw/hrs 676000 units 685000 units

Renewable Energy Usage:Kw/hrs

Nil Nil

Gas Usage:Kw/hrs

Nil Nil

Has site completed any carbonFootprint Analysis?

Yes No

Nil

Yes No

Nil


If Yes, please state result

Water Sources:Please list all sources e.g. lake, river,and local water authority.

Bore well Bore well

Water Volume Used:(m³)

3000 Ltrs 3140 Ltr

Water Discharged:Please list all receiving waters/recipients.

Domestic water waste was disposedin the septic tank as per thePollution Control Board Consent

Domestic water waste was disposedin the septic tank as per thePollution Control Board Consent

Water Volume Discharged:(m³)

2676 2802

Water Volume Recycled:(m³)

Nil Nil

Total waste Produced(please state units)

2600 MTS 2702 MTS

Total hazardous waste Produced:(please state units)

Nil Nil

Waste to Recycling:(please state units)

Nil Nil

Waste to Landfill:(please state units)

Nil Nil

Total Product Produced(please state units)

6500 MT 6800 MT


10C: Business Ethics – 4–Pillar Audit

10C: Business Ethics – 4-Pillar Audit(Click here to return to NC–table)

To be completed for a 4–Pillar SMETA Audit

10C. Guidance for “Observations”10C.1. Suppliers should have completed the appropriate section of the SAQ and have made it available to theauditor.10C.2. The supplier should have received and acknowledged– preferably in writing – the Business Ethics policy ofthe auditor/audit company.10C.3. Suppliers shall seek to conduct their business ethically without bribery, corruption, or any type of fraudulentBusiness Practice.10C.4. Suppliers shall be aware of any applicable laws, their end client’s Business Ethics standards/coderequirements and have a system in place to monitor their performance against these.10C.5. Supplier should have a Business Ethics policy concerning bribery, corruption, or unethical BusinessPractice. This should be clearly communicated to all relevant parties.10C.6. Suppliers should have a designated person responsible for implementing standards concerning BusinessEthics10C.7. Suppliers should have a transparent system in place for confidentially reporting, and dealing with unethicalBusiness Ethics without fear of reprisals towards the reporter10C.8. Suppliers should ensure that the staff whose job roles carry a higher level of risk in the area of ethicalBusiness Practice e.g. sales, purchasing, logistics are trained on what action to take in the event of an issue arisingin their area.

Note for auditors and readers. This Business Ethics section is intended to take not more than 0.25 auditor days. Itis an assessment not an audit and the main requirement is to gather information on the relevant Business Ethicsissues in a supply chain. All findings will be recorded as observations not Non– Compliances and the data collectedwill allow the membership to define appropriate standards over time as part of a continuous review process.

Current Systems and Evidence ExaminedTo complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and

record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to


Current systems:1. Mr. Ajay Sortee - DGM - Quality Assurance is responsible for compliance.2. There is no current local legislation, based from the interaction with the facility management, The facility hascommunicated business code of conduct to all employees.3. The facility is of client’s policy of Business Integrity.4. The facility had received and acknowledged Integrity Policy & Procedure of the auditing company.5. The facility had established & maintained a system for reporting and dealing with unethical business practices.


1. Facility Policy.2. Interaction with management and Employees.


Observation

Description of observation:None observed

Local law or ETI/Additional Elements requirement:Not applicable

Comments:Not applicable


Not Applicable





Worker Interview SummaryWorker Interview Summary

Worker Interview Summary

A: Were workers aware of the audit? YesNo

B: Were workers aware of the code? YesNo

C: Number of group interviews:(Please specify number and size ofgroups. Please see SMETA BestPractice Guidance and MeasurementCriteria)

1 group of 4 employees.

D: Number of individual interviews(Please see SMETA Best PracticeGuidance and Measurement Criteria)

Male: 03 Female: 3

E: Total number of interviewedworkers(Please see SMETA Best Practice

Guidance and Measurement Criteria)

Male: 07 Female: 03

F: Interviews were done in privateand the confidentiality of theinterview process wascommunicated to the workers?

YesNo

G: In general, what was the attitudeof the workers towards theirworkplace?

FavourableNon–favourableIndifferent

H: What was the most commonworker complaint?

Employees do not have any complaints.

I: What did the workers like the mostabout working at this site?

Friendly management & On time wage payment.

J: Any additional comment(s)regarding interviews:

None

K: Attitude of workers to hoursworked:

Positive

Agency Workers

Agency Workers (if applicable)(workers sourced from a local agent who are not directly paid by the site)

A: Number of agencies used(average): And names if available: 45 employees engaged through 3 contractors


B: Were agency workers’age/pay/hours included within scopeof this audit

YesNo

C: Were sufficient documents foragency workers available for review?

YesNo


Other findingsOther Findings Outside the Scope of the Code

None

Community Benefits(Please list below any specific community benefits that the site management stated that they were involved in, for example, HIV

programme, education, sports facilities)

None


Photo Form

1. Facility Name Board 2. Facility gate view 3. Facility Overall view

4. Security at the gate 5. Notice board 6. no child labour board displayed

7.Working hour displayed 8.Evacuation plan 9.Fire extinguisher


10.First aid box provided 11.Fire alarm call point 12.Fire assembly point

13.Exit doors with markings 14.Path way marked 15.Eye wash station

16.Secondary containment provided 17.Fire hydrant 18.Dormitory view


19.Employees room 20.Emergency light 21.Policy and procedures

22.Production floor 23. Production floor 24. Production floor

25.Storage area 26. Production floor 27. Production floor


28.Storage area 29. Storage area 30. Production floor

Non-Compliance PhotosNone observed

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DISCLAIMER:

"This report is for the exclusive use of the client of Intertek named in this report (“Client”) and is provided pursuant to an agreement for services

between Intertek and Client (“Client Agreement”). This report provides a summary of the findings and other applicable information

found/gathered during the audit conducted at the specified facilities on the specified date only. Therefore, this report does not cover, and

Intertek accepts no responsibility for, other locations that may be used in the supply chain of the relevant product or service. Further, as the

audit process used by Intertek is a sampling exercise only, Intertek accepts no responsibility for any non-compliant issues that may be revealed

relating to the operations of the identified facility at any other date. Intertek's responsibility and liability are also limited in accordance to the

terms and conditions of the Client Agreement. Intertek assumes no liability to any party, for any loss, expense or damage occasioned by the


use of this information other than to the Client and in accordance with the Client Agreement and these disclaimers. The disclaimer should be

read in conjunction with the Terms and Conditions of Intertek.”

End of report.