total fashion ltd. · total fashion ltd. sedex company reference: s 000000047203 sedex site...

Audit company: Global Sustainable Certification Services Report reference: GSCS-BD-01-00104-04 Date: 26 April, 2012 1

Supplier name: Total Fashion Ltd.

Site country: Bangladesh

Site name: Total Fashion Ltd.


Audit Company Name: Global Sustainable Certification Services

Client: Total Fashion Ltd.

Sedex Company Reference: S 000000047203

Sedex Site Reference: P 000000099618

Audit Conducted By

Commercial Purchaser

NGO Retailer

Trade Union Brand Owner

Multi-stakeholder Combined Audit (delete all that don’t apply)

Auditor Reference Number:

(If applicable) GSCS01

SMETA Declaration

I declare that the audit underpinning the following report was conducted in accordance with SMETA best practice guidance. Any exceptions to this are recorded here: Auditor Name: Md. Abdul Mottaleb (Lead Auditor), Md. Abdul Alim (Auditor), Md. Bodiuzzaman (Auditor) Role: Lead Auditor/Auditor Date: 26th April, 2012


Audit Details

Audit Details

Report #: GSCS-BD-01-00104-04

Date of audit: 26-27 April 2012

Time in and time out:

Time in: 26/04/2012-10:00 and 27/02/2012-10:30 Time out: 27/04/2012-17:05 and 27/02/2012-14:30

Number of Auditor Days Used 3 (Three)

Audit type:

Full Initial Full Re-audit Partial Follow-Up Partial Other - Define

Was the audit announced?

Announced Semi – announced Unannounced

Was the Sedex SAQ reviewed?

Yes No

If no, why not?

Previous audit date: N/A

Previous audit type:

Full Initial Full Re-audit Partial Follow-Up Partial Other - Define

Auditor name(s) and role(s): Md. Abdul Mottaleb (Lead Auditor), Md. Abdul Alim (Auditor), Md. Bodiuzzaman (Auditor)

Report written by: Md. Abdul Mottaleb

Report reviewed by: Md. Abdul Alim

Report issue date: 27

th April 2012

Supplier name: Total Fashion Ltd.

Site country: Bangladesh

Site name: Total Fashion Ltd.

Site contact and job title: Ataul Haque Jinnah, Director (Admin)

Site address:

Kamtal, Barpara, Narayonganj, Bangladesh


Applicable business and other legally required licence numbers:

for example, liability insurance

Factory Licence 13760/Dhaka, Fire Licence Dhaka/20685/07, Boiler Licence BAB 5280, Import Registration Certificate BA 0184155 , Export Registration certificate RA0084822, EPB:5010, TIN 175-201-6667/c0-16, VAT 9191006672/90602, BGMEA 4464, VAT 5011071248/50101, BOI:1068 , Group Insurance: 242649, BERC: BERC/Power/LWC-0092/0177, Certificate of Incorporation: C-59573(1579)/05, Environmental Clearance: ENV/DD/14873/Clearance 1914

Site phone: +88-02-8954995,8959473

Site fax: +88-02-8954140

Site e-mail: [email protected]

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

Product: Knitted top items (T-Shairt, Polo Shirt, Tank top, sweat shirt, Jogging wear, children wear, sports wear Process: Knitting, dyeing, Cutting, Sewing and Finishing of knit Garments

Audit results reviewed with site management? Yes

Who signed and agreed CAPR (Name and job title) Ataul Haque Jinnah, Director (Admin)

mailto:[email protected]


Audit Scope

Local Law Bangladesh Labor Law 2006

Standard work week (total hours): 48 hrs

Maximum allowed overtime hours (per day, week, month):

2 hrs per day, 12 hrs per week and 48-52 hrs per month depends on total working day, Note that, 4 hours of overtime work will be allowed from September 2011 to April 2012 through a gazette notification of Bangladesh Government. But factory did not utilize this facility.

Minimum work age: 18 years

Minimum wage for standard hours: Tk. 3000/-

Minimum overtime wage: 200% of the basic salary

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

ETI Base Code (if partial audit, please detail which base code items were used):

A: Entitlement to Work and Immigration

B: Sub-Contracting and Homeworking

Additional Requirements

C: Environment

Note: The main focus of this ethical audit is on the ETI Base Code and local law. The additional elements A,B,C,D 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.


Non-Compliance Table

Issue

Area of Non-Conformity (Only check box when there is a non-

conformity)

Rating (Currently only to be

completed as a specific client requirement)

ETI Base Code

Local Law Additional Elements

0 Management systems and code implementation

1 Employment Freely Chosen

2 Freedom of Association

3 Safety and Hygienic Conditions

4 Child Labour

5 Wages and Benefits

6 Working Hours

7 Discrimination

8 Regular Employment

8A Sub-Contracting and Home working

9 Harsh or Inhumane Treatment

A Entitlement to Work

B Environment


Audit Overview

Audit Overview

Audit attendance Senior management Worker representatives/ Union representatives

Present at the opening meeting? Yes No Yes No

Present at the audit? Yes No Yes No

Present at the closing meeting? Yes No Yes No

If Worker/Union Representatives not present please explain reasons why

Not Applicable

Site description: (Include size, location, age, structure, number of buildings)

Total Fashion Ltd is located at, Kamtal, Bandar, Narayangonj in

Bangladesh. It is 30 KM far from Capital City. The factory has started its operation in 2008 with only the Textile unit and in 2010, factory has started it's Garments unit under the same legal business entity.

Factory is producing all types of knit T-Shirt, Polo Shirt, Trouser, Shorts for Mens, Womens and Kids. The total number of workers are working is 580, out of that 260 are famale employees who are mostly working in garments section.

Textile Unit is operating in three shifts with one hour break for lunch and prayer as the employees wish by rotation during the 8 hour working time with no overtime works. Garments section is operating with a single shift starting from 08.00 am to 05.00 pm with one hour break from 13.00 to 14.00. and if required the work extra 2 hours and pay at premium rate for the extra 2 hours.

The total land area of the facility is 79,200 square feet. The are 2 production building (01 is textile and another is Garments), 01 small utility building, 01 small shed of pre-fabricated steel structure for dining and canteen Facility. factory was found with a fully operated ETP with capacity of 40 m3 per hour. The facility was nice to see

with management efforts to create a greener atmosphire. Facility has enough space and marked assembly area in front of the factory.

The facility process layout plan is as follows:

Textile Building: Dyeing, Dyeing Finishing, Batch, Dyeing chemical store

Garments Building: 3 storey garments Building

Ground Floor: Adminitrative office, Sample section, Merchandising office, Grey fabric Store, Knitting, Finish Goods Store, Accessories store, Bonded Warehouse , Doctors room, Child care centre.

1st Floor: Cutting and Finishing

2nd floor: Sewing section


Pre-fabricated steel structure-01: Bonded warehouse, Dining, Canteen, Prayer room.

Tin Shed-1: Solid Waste management

Tin Shed-2: ETP Chemical Store

Tin shed-3 (Outside of the main facility): ETP sludge storage

Utility Building: Generator, Sub-station, Boiler

Pay period is from first to last day of every month and salary paid in cash and within 7 working days after completion of wage period.

Audit team has arrived the factory at 9.15 am and conduct an opening meeting with the management. Mr. A.H. Jinnah was present in the opening meeting along with the other mid level management personnel. In the opening meeting, lead auditor has deliver thanks to the facility amangement and describe the audit process, confirm

guides for facility tour and guaranteed facility management regarding the confidentiality of the information shared by the factory during the audit. Lead Auditor also has taken the Declaration of consent with sign from The Director of the company.

During 2 days long audit, audit team has conducted a detail facility tour, worker interview with a 25 worker sample, sample based document review and has done payroll of 25 sample workers.

At the end of last day of audit, audit team has conducted a closing meeting Mr. A. H Jinnah and other mid management personnel. Lead auditor has explained the result of the audit. once again lead auditor has assured the facility management about the confidentiality of the information. Lead auditor has closed the audit by delivering thanks to facility management.

Site function: Agent Factory Processing/Manufacturer Finished Product Supplier Grower Homeworker Labour Provider Pack House Primary Producer Service Provider Sub-Contractor

Month(s) of peak season: (if applicable) Peak season- November to July and Off Peak season from August to October

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

Products: Knitted top garments


Main process includes Knitting, dyeing, Cutting, Sewing, Finishing and Packing of woven Garments. The main equipments are used by the factory are: Knitting M/C- 10, Plain Machine: 100, Pegasus model over lock machine 60, interlock machine – 20, flatbed interlock – 16, Feed of the Arm M/c- 02, Double chain stitch M/C- 02, lockstitch button hole M/C- 02, lockstitch button sewer M/C- 02, Bartek M/C- 04, Snap fastening – 02, Thread suction M/C- 02, Vacum iron table- 15, Collar and cuff stitch M/C- 3, Dyeing – 12, Dyer – 01, Squeezer M/C- 02, heat setting – 01, compactor -1, boiler – 1, gas generator – 01, WTP- 1, other- 25.

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 are found aware about their rights and organizational practices and happy with the management approach as they are getting on time salary, medical facility, child care facility, attendance bonus, festival bonus, paid leave and other statutory benefits. They are happy with the behaviour of management. No negative comments came in the interview from the workers.

Attitude of managers:

(Include attitude to audit, and audit process. Both positive and negative information should be included)

Top and middle Managements are well aware about the legal requirements of social compliance. During the audit it was found that manager‟s intension is positive and cooperative towards this audit and they have taken all the observations very positively and committed to take action against the observations.

Summary of main findings: (positive and negative)

Understanding and communication between management and workers was found good. Management were committed to comply with the entire requirement and workers are happy with Management attitude. Managers are aware about the social compliance requirements and very much positive about the requirements. During the interview no negative comments found from the workers. Following observations were noted during the audit. 1. It was noted during management interview and document review that factory did not conduct noise

level assessment for sensitive areas especially for boiler, Generator, knitting section.

2. During Management interview and document review, it was noted that the factory did not conduct social audits of the suppliers based on either ETI requirements nor their own checklist.


Key Information

Key Information

Do all workers (including migrant workers) have contracts of employment?

Yes No

Were appropriate records available to verify hours of work and wages?

Yes No

Were any inconsistencies found?

(if yes describe nature) Yes Poor record keeping No Isolated incident

Repeated occurrence

For the lowest paid production worker, are wages paid for standard hours below or above the legal minimum?

Below legal minimum 0 %age Meet 100%age Above 50 %age

% of piece rate workers:

(if applicable) N/A

Combined hours (regular and overtime) over 60 per week found?

Yes No

Are the correct overtime premiums paid? Yes No

Is there any night production work at the site? Yes (Factory using 3 shift for knitting and dyeing section but met the legal requirements)

No

% of workers living in site provided accommodation (if applicable):

Not Applicable

Age of youngest worker found: 18 years

Workers under 18 subject to hazardous work assignments?

Yes Company Policy is not to employ workers under 18 year and No during audit no worker was found below age of 18 years.

What form of worker representation is there on site?

Union Worker Participation Committee Other (specify)

Are there any External Processes? Sub-Contracting (Facility has no printing and embroidery facility in-house, they are using sub-contracting for mentioned process. They have legal agreement They also have conducted social audits of the suppliers based on their own checklist.)

Home working Other External Process (detail)


Worker Analysis

Worker Analysis

Local

Migrant

Permanent Temporary Agency Permanent Temporary Agency Homeworkers

Worker numbers – male

328 N/A N/A N/A N/A N/A N/A

Worker numbers –female


Total 611 N/A N/A N/A N/A N/A N/A

Total Workers at this Site:

Number of Workers interviewed


Migrant Workers:

Originating Locations/Countries: Not Applicable

Work undertaken by migrant workers: Not Applicable

Were migrant workers recruited through an agency?

Not Applicable

If yes, is there a contract with the agency? Provide details of agencies and contractual arrangements

Not Applicable

Percentage of migrant workers in company provided accommodation:

Not Applicable


Audit Results by Clause

0: Management systems and code implementation:

0.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code. 0.2 Suppliers shall appoint a senior member of management who shall be responsible for compliance with the

Code. 0.3 Suppliers are expected to communicate this Code to all employees and to their suppliers.

0.4 Suppliers should, where reasonably practicable, extend the principles of this ethical code through their supply chain.

Evidence of Compliance and Current Status

Factory has defined their own code of conduct including all Terms of ETI Code. The code is displayed in local language on company notice boards. Company appointed a member of senior management Mr. Ataul Haque Jinnah, Director, who is responsible for compliance with the code. Company has communicated the code with suppliers by providing the copy of this code and collect their consent of reasonably practice of the code and extend of this ethical code through their supply chain. But they did not conduct social audit to their supplier.

Non-compliance:

Description of non-compliance: None None Local law or ETI requirement: Not Applicable Not Applicable Recommended corrective action: Not Applicable Not Applicable

Objective evidence observed: Not Applicable

Observation

Description of observation During Management interview and document review, it was noted that the factory did not conduct social audits of the suppliers based on either ETI requirements nor their own checklist. Local law or ETI requirement: ETI

Objective evidence observed: Management interview and document review


To comply with ETI requirement, suppliers should, where reasonably practicable, extend the principles of this ethical code through their supply chain. Recommended corrective action: Factory shall conduct

Good Examples observed:

Description of Good Example ( GE) None


1: Employment is Freely Chosen

ETI 1.1 There is no forced, bonded or involuntary prison labour.

1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.


Company has defined “Policy Force On labour” stated that company has not appointed any Forced, bonded and involuntary prison labour and it is strictly prohibited in the company. It was noted through management interview, worker interview and document review that company is not keeping deposits or their identity papers of employees. Company has defined a Termination policy which clearly states that workers are free to leave with reasonable notice which fully compliant with Bangladesh Labor law 2006. Company has provided Job contract to every employees which states that any employees are free to leave with a reasonable notice as per the conditions of employment of Bangladesh Labor Law 2006.

Over Time is also voluntary and workers are free to leave once the regular shift hours are complete. This was verified during worker interview and found compliant.


Non-compliance:

Description of non-compliance: None None Local law or ETI requirement: Not Applicable Not Applicable Recommended corrective action: Not Applicable Not Applicable


Observation

Description of observation None Local law or ETI requirement: Not Applicable Recommended corrective action: Not Applicable






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

ETI 2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain

collectively. 2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.

2.3 Workers‟ representatives are not discriminated against and have access to carry out their representative functions in the workplace.

2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and

bargaining.


“Freedom of Association Policy” clearly states that the workers are free to join or form union of their own choice. Since the workers have not formed any union in the factory, the company has formed a Worker Participation Committee as per law. The Worker Participation Committee has 16 members (11 workers and 5 management staff). The Worker Participation Committee meets once in every two month and minutes of the meeting are displayed on company notice board. Last Worker Participation Committee meeting was conducted on 24

th March 2012.

“Freedom of Association Policy” clearly states that workers representatives are not discriminated and have the access to carry out their activities in the workplace.

Non-compliance:

Description of non-compliance: None Local law or ETI requirement: Not Applicable Recommended corrective action: Not Applicable



Observation



Name of union and union representative, if applicable:

N/A

If no union what is parallel means of consultation with workers?

Workers Participation Committee

The percentage of workers at the site covered by collective bargaining with one or more recognised trade unions

N/A

The percentage of workers at the site covered by negotiation with workers’ representatives who are NOT members of one or more recognised trade unions

100%

Does the Collective Bargaining Agreement (CBA) include rates of pay

Yes Not Applicable No





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 and 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 and safety to a senior management representative.


Company has defined a detail policy for health and safety. There is a committee named Health and Safety committee is continuously monitoring the operation level. Company has provided training on health, safety and hygiene and found records of the trainings during the documents review. They also provided induction training for the new workers and repeated training for the reassigned workers. Company has gone through a test of drinking water based on WHO and Bangladesh standard of Drinking water. Company has not provided any Accommodation/Dormitory Facility Mr. Aminur Islam Bhuiyan is assigned as the Health and Safety representative

Non-compliance:

Non-compliance:

Description of non-compliance:

None Local law or ETI requirement:

Not Applicable Recommended corrective action: Not applicable

Objective evidence observed: Plant Visit/Physical Observation

Observation

Description of observation

Objective evidence observed:


None Local law or ETI requirement: ETI Not Applicable Recommended corrective action: Not Applicable

Not Applicable



Objective Evidence Observed: Not Applicable

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.


Company has well defined policy for child labour conforming local and ILO standards what describes that they are not employing any child labour. During the audit no child labour found or suspected. They are going through an age verification test by the registered doctor before employing any worker and the proof of age are keeping in the personal file. From the establishment of the company no child labour found or recorded. As per the local law anyone under 18 years of age is child and they are not employing any child at any circumstances. No child found during the audit. Also factory has child labour remediation action procedure for suspected child if mistakenly requited by management in future.


Non-compliance:



Observation




Description of Good Example ( GE)

Objective Evidence Observed:


5: Living Wages are Paid

ETI 5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and

to provide some discretionary income. 5.2 All workers shall be provided with written and understandable information about their employment conditions in

respect of 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.


Company is providing wages and benefits as per the national legal standards. 50% of workers are exceeding minimum legal wage level and rests who are unskilled new workers are also meeting the minimum legal standards. Based on last month March 2012 payroll, highest paid salary BDT. 10755, minimum wage BDT. 3707 and average wage BDT. 4909 including overtime payment. Company is providing Appointment letter with all the particulars of wages in local language. Company is maintaining wage sheet for each pay period but not providing pay slip with all particulars of each pay period. Company has defined Disciplinary action policy, wage and benefit policy and Deduction policy. Both are in line with the national law.

Non-compliance:

Description of non-compliance: None Local law or ETI requirement: N/A Recommended corrective action: N/A.

Objective evidence observed: N/A

Observation

Description of observation



None Local law or ETI requirement: Not Applicable Recommended corrective action: Not Applicable

Not Applicable


Description of Good Example ( GE) Company is paying festival bonus though festival bonus is not mandated by law.

Objective Evidence Observed: Payroll Record

Wages analysis:

Sample size (number of wages checked and which weeks or months):

32 workers (32 payroll records from each month was reviewed from January 2012, March 2012 and August 2011. The payroll sample were randomly selected.

Legal minimum wage for standard time: Tk. 3000/-

What deductions are required by law, and have all of these been made:

Deduction for unauthorised absent

Industry norm for this region: Same as specified by local labor law

Legal overtime premium for weekdays: 200% of the basic salary

Legal overtime premium for rest days: 200% of the basic salary

Legal overtime premium for holidays: Not specified by law

Were collective bargaining agreements reached on the wages stated below?

Yes-No collective bargaining agent has yet been formed. No


Worker Type Process Operator (Highest paid)

Process Operator (Average paid)

Process Operator (Lowest paid)

This is not so relevant in farms where most workers are paid the same, or are of the same „Worker type‟. Also many farms in SA use a combination of piece and hourly rate which is impossible to capture on this form.

Select one worker’s records from each “Worker Type” and populate the boxes:

Pay period (pm/week) March 2012 March 2012 March 2012

Employee identification/ Staff ID#/Dept

10755/ ID Card # 201/ Dept. Finishing (Including OT)

4910 /Sewing (Including OT)

4000 /Sewing (Including OT)

Employee Gender Male Male Female

Contract monthly/daily Monthly contract-Tk. 10760.00

Monthly contract-Tk. 4800.00

Monthly contract-Tk. 3000.00

Regular working hours 48 hrs per week 48 Hrs per week 48 Hrs per week

Regular work pay rate Tk.347.09/day Tk. 154.83/day Tk.96.77/day

Regular day overtime (hour) Maximum 2 hrs in a day Maximum 2 hrs in a day Maximum 2 hrs in a day

Regular day overtime (wage) Tk.51.73/- per hour Tk. 23.08/-per hour Tk. 14.42/-per hour

Rest day overtime (hour) Not Applicable Not Applicable Not Applicable

Rest day overtime (wage) Not Applicable Not Applicable Not Applicable

Statutory Holiday overtime (hour)

Not Applicable Not Applicable Not Applicable

Statutory holiday OT (wage) Not Applicable Not Applicable Not Applicable

Total overtime hours 0 hrs in March 2012 40 hrs in March 2012 52 hrs in March 2012

Incentives/Bonus/ Allowances etc.

Attendance Bonus 400/-

None

Attendance Bonus 400/-

Gross wages Tk. 10760/- Tk. 4910/- Tk. 4000/-

Social insurance and other deductions

Revenue Stamp: 5/-

Revenue Stamp: 5/-

Revenue Stamp: 5/-

Actual wage paid after deduction

Tk. 10755/- Tk. 4905/- Tk. 3995/-

Comments:

(Please state here any specific reasons/circumstances that explain the lowest and highest gross wages)


Above wage was calculated basing on the provided documents

Is there a defined living wage: Yes No (add notes into guidance for auditors)

Please specify amount/time period:

Is there evidence that equal rates are being paid for equal work:

Yes No

Details: All workers are being promoted and increment is being provided basing on workers performance.

How are workers paid: Cash Cheque BACS

If not explain:

1. Contracted overtime premium for…

Weekdays: 200% of the basic salary

Rest days: 200% of the basic salary

Holidays: Not Specified by Local Law

2. Actual overtime premium paid in sample for…

Weekdays: Double the basic

Rest days: Factory did not work on any rest day

Holidays: Factory did not work on any holiday

3. Average wage paid to operators: Tk. 4905/- For Fixed Monthly Salaried workers (Based on the sample)


6: Working Hours are not Excessive

ETI 6.1 Working hours comply with national laws and benchmark industry standards, whichever affords greater

protection. 6.2 In any event, workers shall not on a regular basis be required to work in excess of 48 hours per week and shall be provided with at least one day off for every seven day period on average. Overtime shall be voluntary, shall not

exceed 12 hours per week, shall not be demanded on a regular basis and shall always be compensated at a premium rate.


Company has defined policy on working hours and communicated to the workers through awareness program. Company policy conform the both local laws and industry standards in terms of working hours. The policy has clearly defined that the overtime work is completely voluntary and any worker can leave the premises after regular working hours without prior permission. Local law allows 48 hours regular work in a week and maximum 12 hours over time weekly. It was verified through Worker Interview and Document review (Payroll and Working hour Testing) Company is providing one day off after every six consecutive days. The company‟s regular weekend is Friday. No holiday or rest day work found during the verification of documents.

Non-compliance:



Observation

Description of observation None



Local law or ETI requirement: Not Applicable Recommended corrective action: Not Applicable




Working hours analysis

What timekeeping systems are used: time card etc.

Attendance and work timings (including OT) are recorded through manual time card.

Sample size checked (number of workers): 32 workers (32 payroll records was reviewed from every 3 sample months August 2011, January 2012 and March 2012.

Legal standard work week (hours): 48 hrs

1. Contracted standard work week this site (hours):

48 hrs

2. Actual standard work week averaged over sample (hours):

46 hrs

3. Lowest basic hours worked: 48 hrs in a week

4. Highest basic hours worked: 48 hrs in a week

Legal permitted overtime hours: 12 hrs per week

Any local waivers for this site: Not Applicable

Comments:

(Please state here any specific reasons/circumstances that explain the highest working hours)

Above working hours calculation is done basing on the provided documents

1. Actual overtime hours: (averaged over sample)

Total Sample: 32 Average Over time per month 52.00 hrs and 11.00 Hrs in a week.


2. Range of overtime hours over all workers: (quote highest and lowest)

Highest 12.00 hours and lowest 10.00 hours in a week (out of 32 sample in March 2012)

3. Peak seasons: Peak season- November to July and Off Peak season from August to October.

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.


They have defined a policy of non-discrimination in hiring, compensation, promotion, termination, access to training, increment based on race, caste, national origin, religion, age, gender, gender, marital status, sexual orientation or membership in any union or political affiliation. This policy is well communicated through the notice board. Company has system in place to complaint against any discriminatory behaviour in confidential manner and have the system to handle the grievances if occurred. During the worker interview no such comments raised related to discrimination.

Non-compliance:



Observation

Description of observation None



Local law or ETI requirement: Not Applicable Recommended corrective action: Not Applicable

Not Applicable




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 homeworking 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.


Company is employing workers as permanent basis. No contractual workers employed in the company. Company is providing appointment letter as the job contract and keeping the duplicate copy of that appointment letter in the personal file.


Non-compliance:

Description of non-compliance:

None Local law or ETI requirement: Not Applicable Recommended corrective action:

Not Applicable


Observation







8A: Sub-Contracting and Home working:

8a.1 There should be no sub-contracting unless previously agreed with the main client. 8a.2 Home-working should be properly managed.

Note to auditor on home working:

Report on whether it is direct or via agents. How many workers, relationship with site and what control systems are in place.


No home working is in practice Company is not using any sub contractors but they using the supplier for their printing and embroidery facility as they have no in-house facility. Factory provided the supplier appointment policy and procedure but they have no agreement with them as well as they did not conduct social audit to them.

Non-compliance:

Description of non-compliance: It was noted that factory did not make any agreement with supplier as well as they did not conduct social audit to them. Local law or ETI requirement: To comply with ETI requirement 8A.1: There should be no sub-contracting unless previously agreed with the main client Recommended corrective action: Factory shall make agreement with supplier as well as they shall to conduct social audit to them.


Observation







Summary of sub-contracting

1. Number of sub-contractors/agents used Two supplier using for printing and embroidery facility

2. Is there a site policy on sub-contracting? Yes No

3. What checks are in place to ensure no child labour is being used and work is safe?

N/A

4. What processes are sub-contracted? Printing and embroidery

Summary of homeworking

1. Number of homeworkers Male: N/A Female: N/A Total: N/A

2. Are homeworkers employed direct or through agents?

Yes N/A No

3. If through agents, number of agents N/A

4. Is there a site policy on home working? Yes N/A No

5. How does site ensure worker hours and pay meet local laws for home workers?

N/A

6. What processes are carried out by home workers?

N/A

7. Are written agreements in place for home workers that include regular employment?

Yes N/A No

8. Are full records available at the site? Yes N/A No


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.


Company has policy against harassment and abuse what clearly described that none is allowed to physical abuse, sexual or any other harassment or verbal abuse to any other employees. Company has system in place to confidentially complaint against any harassment or abuse without any threats of retaliatory action. Company is providing awareness on regular basis on the company policy of harassment and abuse

Non-compliance:



Observation







Other Issue areas: A: Entitlement to Work and Immigration

Additional Retailer Specific Elements A1 Only workers with a legal right to work shall be employed or used by the supplier.

A2 All workers, including employment agency staff, must be validated by the supplier for their legal right to work by reviewing original documentation.

A3 Employment agencies must only supply workers registered with them. A4 The supplier shall implement processes to enable adequate control over agencies with regards to the above

points and related legislation.


No immigrant worker was found recruited by factory.

Non-compliance:




Observation



Good examples observed:



Other issue areas B: Environment

B.1 Suppliers shall seek to make continuous improvements in their environmental performance and, as a minimum, comply with the requirements of local and international laws and regulations.

B.2 The supplier shall be aware of and comply with their end clients‟ environmental requirements.


Not audited as Company did not want to include Environment in the audit scope


Non-compliance:

Description of non-compliance: It was noted that factory did not conduct air emission and noise level assessment from any outside recognized authority. But factory assessed noise level internally. Local law or ETI requirement:

In accordance with Bangladesh Environment Conservation Rules 1997 - Factory should conduct noise level assessment and air emission test for sensitive areas especially for boiler, Generator, knitting section

Recommended corrective action:

The factory should conduct noise assessment and air emission test


Observation


Objective evidence observed: Not applicable

Good examples observed:




Worker Interview Summary Worker Interview Summary

Were workers aware of the audit? Yes No

Were workers aware of the code? Yes No

Number of group interviews 4 Group of 4 each

Number of individual interviews Male: 8 Female: 8

Number of interviewed workers Male: 18 Female: 14

Interviews were done in private and the confidentiality of the interview process was communicated to the workers?

Yes No

In general, what was the attitude of the workers towards their workplace?

Favourable Non-favourable Indifferent

What was the most common worker complaint?

No complaint raised by the worker in the interview process

What did the workers like the most about working at this site?

In time salary Good behaviour of supervisors Flexible Leave policy Good and Clean working environment

Any additional comment(s) regarding interviews:

During the interview it was noted that the workers of the factory are happy to the management. They have a good communication between workers and management through workers participation committee.

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

Number of agencies used (average): Not Applicable And names if available:

Were agency workers’ age/pay/hours included within scope of this audit

Yes N/A No


Other findings

Other Findings Outside the Scope of the Audit

No other finding was observed.

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

Adding Images To help keep the size of the Report as small as possible for ease of sending and

saving the document we recommend that you use Microsoft Paint to resize your photos. To do so please follow these instructions: 1) To start Microsoft Paint, click 'Start', 'Programs', 'Accessories', then 'Paint'. 2) Open the image file you wish to edit. 3) Click the 'Image' Menu at the top and select "Stretch/Skew Image”. 4) Choose a percentage figure to resize the image: to avoid distortion, choose the same percentage for

horizontal and vertical stretch. Click OK. 5) Once you have the desired size, click File > Save As… (To prevent overwriting the original image). Save As jpeg (this provides compression to make the file smaller).

Factory Outside View ETP Plant Chemical storage

Dyeing section Knitting section Cutting section


Sewing section Finishing section Sample section

Boiler room Fire hose rill Fire extinguisher

Generator Boned warehouse Child care room

Doctor‟s room Canteen Dinning

Drinking water Workers using PPE Public announcement


Awareness poster Notice board Fire equipment

Spot removing room First aid box Fire fighter

Smoke detector First aider Temperature meter

total fashion ltd. · total fashion ltd. sedex company reference: s 000000047203 sedex site...

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