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Social Compliance Audit Report

Audit ID #: SHCJ12346-01 Audit Report Date: November 7, 2011

Factory Information

Factory ID No. W615-4872-5

Factory Name: Wuyi Shunfeng Stainless Steel Products Co., Ltd.

Street Address Line 1: No. 2, Wujin Avenue, Tongqin Industrial Zone, Wuyi County, Zhejiang Province, China

Street Address Line 2: ---

City: Wuyi County State/Province: Zhejiang Province

Zip Code: 321201 Country: China

Contact Person Name: Mr. Chen Qiang Telephone: 86-579-8767 1488

Contact Person Title: Vice General Manager Fax: 86-579-8767 2488

Compliance Audit Report

Document Completed By: Audit Entered By

(Name):

Title:

Date Audit Entered:

(MM/DD/YYYY)

Factory Audited By: Audit Conducted By

(Name):

Davy Zhou, Richard Li

Audit

Organization:

Date Audit

Conducted:

(MM/DD/YYYY)

October 31, 2011

Audit Type:

(Initial or 1st/2nd/3rd Follow Up)

Initial Audit

Tentative Audit Date:

(MM/DD/YYYY)

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Compliance Audit Report (Continued)

Number of Factory

Workers:

Unable to Determine

1-50

51-100

101-250

251-500

501-1000

1001-2500

2501-5000

Over 5000

Audit Report Date: November 7, 2011

Overall Rating: Needs Improvement Acceptable

Agreed to and

signed Corrective

Action Plan

Acknowledgement

Report (CAPAR):

Yes No

Mr. Chen Qiang / Vice General Manager

Access to Facility:

If denied, explain:

Accepted Denied

Partial Access

Denied?:

Yes No

Percentage of the

Factory’s capacity

devoted to

production of

Disney Products:

0%

1-10%

11-20%

21-30%

31-40%

41-50%

51-60%

61-70%

71-80%

81-90%

91-100%

Overall

Assessment:

Special Findings

None observed

Assessment Process

Assessment Type (Spot Check, Unannounced, Announced, GIFW, Observed Assessment): Announced Specify Code of Conduct Assessed (ex. Disney, ICTI or SA8000): Disney Monitoring Firm: Intertek Testing Services Number of Monitors (ex. Due to the schedule conflict/limited manpower resources, the auditors from the audit team of the previous audit cannot conduct this follow-up audit): A team of 2 auditors Name and Title of Others Present (ex. translators, observers, trainees):Nil Status of Disney’s Ethics Policy (Presented and explained, Signature Block Completed): Signature Block Completed Number of Testing: 10 Months of Work Attendance Records Reviewed: 12 months and 30 days’ (from October 1, 2010 to October 30, 2011) timecard attendance records were reviewed. Months of Payroll Ledgers Reviewed: 12 months’ (from October 2010 to September 2011) payroll records were reviewed. Number of Employees Interviewed: 10

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Number of Employees/Group Interviewed: 4 employees in one group Signing of the Confidentiality Agreement (Y / N): Y Resources Received from Facility (i.e. transportation, meals): The facility provided free lunch in canteen and free transportation from facility to bus station Report Disney approved or not approved deviations from the ILS Audit Scope and Procedures and who, what, and why details (ex. number of auditors, different auditors assigned from previous audit, different number of testing from the requirement, and different number of interviews from the requirement, etc): None Facility Overview Information

Facility Address: No. 2, Wujin Avenue, Tongqin Industrial Zone, Wuyi County, Zhejiang Province, China Contact Person: Mr. Chen Qiang Month and Year of Establishment: October 2001 Numbers and Purpose (Administrative / Production / Dormitory) of Buildings: In view of the facility, the facility consists of one 2-storey building and one flat building for production and warehouse area, 1/F to 3/F of one 5-storey building for office, 4/F to 5/F of one 5-storey building for dormitory, one flat building for kitchen and canteen. Product Type: Travel Mugs Production Processes: Metalworking, pressing, injection, polishing, printing, assembly, inspection and packing Current / Normal Employee Size by Employee Type: Totally 96 employees. Current / Past Percentage of Disney Production: 10% Other Brands Present: Wal-mart 10% etc. Peak / Low Production Months: The peak month is not obvious. Facility Regular Hours / Shift: 3 shifts for injection workshop: 7:00-15:00, 15:00-23:00, 23:00-7:00, 1 shift for other workshop and office: 7:30 to 17:00 with 1.5 hours’ (from 11:30 to 13:00) lunch break Pay Date: On or before 10th of every month Name of the Licensee / Vendor: Uncas (H.K.) Co., Ltd. / Amax Enterprises (HK) Limited (Tel: 852-2428 0202; Fax: 852-2428 0070; Contact person: Mr. Jacky Cheng [email protected]) Violations Categories: Health & Safety.

Comments / Observations: None observed

Communicated

Findings with:

Discussions regarding the Corrective Action Plan occurred with Mr. Chen Qiang / Vice General Manager

Child Labor: Acceptable Needs Improvement N/A Unable to Verify

None observed

Current Child Labor:

Acceptable Needs Improvement N/A Unable to Verify

None observed

Young Worker:


None observed

Other:


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None observed`

Involuntary Labor: Acceptable Needs Improvement N/A Unable to Verify

None observed

Prison, Bonded, Indentured, Forced Labor:


None observed

Mandatory Overtime:


None observed

Other:


None observed

Coercion and

Harassment:


None observed

Physical Abuse or Sexual Harassment:


None observed

Other:


None observed

Non-

Discrimination:


None observed

Association: Acceptable Needs Improvement N/A Unable to Verify

None observed

Minimum Wage: Acceptable Needs Improvement N/A Unable to Verify

None observed Remark: 1. The local minimum wages was set at RMB 900 per month equivalent to

RMB 5.17 (900/21.75/8) per hour before April 1, 2011 and RMB 1060 per month equivalent to RMB 6.09 (1060/21.75/8) per hour since April 1, 2011.

2. 12 months’ (from October 2010 to September 2011) payroll records were reviewed.

Overtime Wage: Acceptable Needs Improvement N/A Unable to Verify None observed

Overtime Hours: Acceptable Needs Improvement N/A Unable to Verify None observed Remark: 1. 12 months and 30 days’ (from October 1, 2010 to October 30, 2011)

timecard attendance records were reviewed.

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2. According to the attendance records provided by the facility. a. For September 2011 (current month), the maximum weekly working

hours per week were 44 hours (all 10 selected samples). The maximum monthly overtime were 32 hours per month (all 10 samples).

b. For June 2011 (random month), the maximum weekly working hours per week were 44 hours (all 5 selected samples). The maximum monthly overtime were 32 hours per month (all 5 samples).

c. For January 2011 (random month), the maximum weekly working hours per week were 46 hours (all 5 selected samples). The maximum monthly overtime were 32 hours per month (all 5 samples).

3. Through employee interview, all the employees stated that they worked overtime on voluntary basis.

Social Benefits: Acceptable Needs Improvement N/A Unable to Verify None observed

Other

Compensation:


None observed

Monitoring and

Compliance:


None observed

Transparency:


None observed

Ethics:


None observed

Insufficient or Inadequate Records:


None observed

Other:


None observed

Health and Safety: Acceptable Needs Improvement N/A Unable to Verify

Refer to relevant sub-section

Medical & First Aid:


None observed

Personal Protective Equipment (PPE):


None observed

Fire & Emergency Safety:


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None observed

Machine & Electrical Safety:


None observed

Hazardous Material:


1. PRC Law of Prevention and Control of Occupational Diseases article 32, the

employer shall conduct regular occupational health examination for those

laborers who are engaged in using or contacting noxious articles in their

working process as required by medical administrative department under the

State Council. The occupational health examination should be conducted

before laborers start to take work post, in the course of the work post and

after leave the work post and employer should inform the laborers of the

result of the occupational health examinations. The expense of the

occupational health examination should be borne by employers.

Employer should not arrange laborers without the occupational health

examination to be engaged in the work with using or contacting noxious

articles, or laborers with any occupational prohibitions to be engaged in the

prohibited work from them.

Once the occupational health examination indicates that employee is

suffering from the occupational disease in relation to his or her occupation,

the employer shall transfer such a laborer out of his or her original work

post, and allocate him or her in a proper way. Employer should not rescind or

terminate the contracts signed with those employees without the

occupational health examination at time of leaving the work post.

The occupational health examination should be conducted by the medical

organizations authorized by the medical administrative department above

province-level.

Auditor noted that only one screen printing employee (contacting ink) of the

facility has not ever conducted occupational health examination since he has

joined the facility.

Please ensure that the facility shall conduct regular occupational health examination for those laborers who are engaged in using or contacting noxious articles in their working process.

Sanitation:


None observed

Other:


None observed

Dormitories: Acceptable Needs Improvement N/A Unable to Verify

None observed

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Protection of the

Environment:


None observed

Subcontracting: Acceptable Needs Improvement N/A Unable to Verify

Not applicable

Remark: No Disney products subcontracting activity was observed during

facility tour and the facility representative claimed that no Disney production

was subcontracted to outside subcontractor.

Other Laws (if

applicable):


None observed

Labor Contract:


None observed

Other:


None observed

Publication: Acceptable Needs Improvement N/A Unable to Verify

None observed

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.”

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