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child labor forced labor health and safety freedom of association non-discrimination disciplinary practices sexual and moral harassment pay working time relations with sub-contractors and suppliers
LOREAL General terms and conditions and with the ILO conventions and local laws
Freedom of Association
ILO Conventions 87 et 98 + laws and regulations of the country ILO Conventions 100 et 111 + laws and regulations of the country
Disciplinary practices, harassment and abuse, hours of work, wages and primes, sub-contractor.
Process Flow
Initiation of Audit Request
Audit Window Audit
Satisfactory Needs Improvement Needs Major Improvement Zero Tolerance
Audit Report
Day + 7
LOral
Sends Audit request to Intertek
Intertek
Provides LOral and site with audit window
Intertek
Intertek
Contact Intertek Local Office
Supplier facility
Prepares documentation & available management resource for audit day
LOral
Logs in on the Web Platform to check audit results
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LORAL
Audit Process
Documentary Review
Facility Tour
Employee Interviews
Pre-Closing Meeting
Opening Meeting
Explain
The aim and scope of the audit, The standards and policies against which the facility will be audited, The audit procedure, The agenda of the audit, Learn about the facility, The site Manager, a health and safety manager and a human resources manager should be present at the opening meeting.
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Facility Tour
11
Documentation Review
A
Personnel recruitment file and contract Working Hours recording system for normal/OT hours Payslip records Social Security payment Proof of salary payment Health and safety records & certificates Fire protection records and SOP Health & Safety Management systems Minimum Wages, OT hourly rate Paper/money deposits Salary Payment delay Unauthorized deductions/fines Clarification on normal/OT working hours Rest days, leaves Health & Safety and other local regulations
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Interviewing Employees
Key Elements of the employee interview : Without Management or site representatives Only upon acceptance of the employee itself Confidentiality of the interview and source of information ensured Informal way to ensure efficiency Interview in 1 by 1 (or group) Random Selection of the personnel list, based on facility ratio (Women/Men, Packaging/ admin dept..) Also employees identified during the facility tour
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Clarify and cross check information & issues found Clarify and Debate among themselves if necessary Write down the Non conformities in the Corrective Action Plan Quote the Local laws to address the findings
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Closing Meeting
A
meeting with the management representatives to: Present the Best Practices /Observations/ Non Conformities Clarify and Debate necessary issues Explain and find an agreement on the Corrective Action Plan A copy of the Corrective Action Plan is provided to the management representatives at the end of the audit
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Reporting
The
A photo report (whenever possible) on main non conformities & best practices,
The audit report itself with details of the findings, objective evidence and details of local laws if applicable A copy of the Corrective Action Plan (CAP) in English that will help the requestor to follow up with the supplier
A copy of the signed CAP in the local language to get the proof that it has been signed by the facility representatives
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OVERALL RATING:
Zero Tolerance
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result by section(1/2)
Compliance Level Best Practices NIL Non Conformity Summary
Themes
Child Labor
Satisfactory Satisfactory
NIL
NIL
1.
2.
No ventilation system was equipped to expel the foul air at the raw material department. No belt guard was equipped to two Sponge Grinding machines in Pen making department.
Satisfactory Satisfactory
NIL
NIL
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NIL
NIL
NIL
1.The factory had not signed labor contracts with 11 out of 16 interviewees. Hours of Work could not be verified during this audit due to: 1)The factory only provided the manual attendance records of January 2006, which issued by department supervisor, and no detailed working hours and overtime hours were registered on the records. The manual attendance records for 2005 were not maintained as the factory had finished the yearend sum-up.
Hours of Work
NIL
10
Subcontracting
Satisfactory
NIL
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Number of Record reviewed & review period: 16 Last period paid: January 2006 Peak period: N/A Random Period: December 2005 and October 2005 Peak Months of the Facility: N/A
Communicated Findings with (Facility Manager): Mr. XXX / Vice General Manager Agreed to and signed Corrective Action Plan (CAP): Yes
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Access Denied
Subject : Labour contract Law:In accordance with the PRC Labor Law article 16, a labour contract shall be concluded where a labour relationship is to be established. Finding/Objective evidence: It was noted that the factory had not signed labor contracts with 11 out of 16 interviewees. Management response: During the audit, the factory provided one copy of <Labor Services Agreement>, signed between the audit factory and Kunshan XXX Due to the factory could not provide the original version of the <Agreement> and there were several unclear points on it, the copy was not accepted during this audit. The factory explained that XXX., Ltd. exported the 8 out of 11 interviewees who did not sign labor contracts with the factory. And the rest 3 were new workers and their labor contracts were in process. Proposed corrective action: It is recommended that the factory should sign labor contracts with all workers.
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Immediate for workers not trained yet and training plan for others.
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Argentina Bolivia Brazil Chili Colombia Dominican Republic Ecuador Honduras Mexico Nicaragua Paraguay Peru Uruguay Venezuela Guatemala
Dubai Egypt Ghana Israel Kenya Lesotho Mauritius Morocco South Africa Swaziland
Bangladesh Brunei Cambodia China Hong Kong India Indonesia Macau Malaysia Pakistan Philippines South Korea Sri Lanka Taiwan Thailand Singapore Vietnam
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