alliance for water stewardship Conformity assessment reporta4ws.org/wp-content/uploads/2019/03/AWS-Conformity-Assessment … · Flexium provided most of the requested supporting documentation

Alliance for Water Stewardship Comformity Assessment Report

Prepared for Flexium Interconnect (Kunshan), Inc.

(AWS-010-INT-CAB-00-08-00015-0075)

Prepared by: SGS

SGS Ref.: CN/SZH

Version: 1

Date: Dec. 8, 2018

This is a controlled document, which is subject to SGS document control procedures.

It may not be reproduced in whole or in part without the express permission of SGS China

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REPORT DETAILS

REFERENCE

CLIENT REFERENCE Jason Chang-Chien

REPORT TITLE ALLIANCE FOR WATER STEWARDSHIP CONFORMITY ASSESSMENT REPORT

DATE SUBMITTED: Dec. 8, 2018

CLIENT: Jason Chang-Chien

Facility Manager, Flexium Interconnect (Kunshan), Inc.

T +86 0512 5777 5599 Ext. 1273

No.1399, Hanpu Road, Yushan Town, Kunshan City, Jiangsu Province, P. R. China

http://www.flexium.com.cn/

[email protected]

PREPARED BY: Scott Liao Jiansong Chang

SGS-CSTC Standards Technical Services Co., Ltd. Suzhou Branch

4st floor, D Building, Ascendas Industry Park, No.5 Xinghan Street, SIP Suzhou, P. R. China. 215021

Tel: +86 (0) 512 6299 0222

E-mail: [email protected]

SIGNED: Scott Liao Signed:

TECHNICAL SIGNATORY

Francesca Cerchia Signed:

STATUS FINAL DRAFT

NOTICE This document is issued by SGS under its General Conditions of Service accessible at http://www.sgs.com/terms_and_conditions.htm. Attention is drawn to the limitation of liability, indemnification and jurisdiction issues defined therein.

Any holder of this document is advised that information contained hereon reflects SGS’s findings at the time of its intervention only and within the limits of Client’s instructions, if any. SGS’s sole responsibility is to its Client and this document does not exonerate parties to a transaction from exercising all their rights and obligations under the transaction documents. Any unauthorised alteration, forgery or falsification of the content or appearance of this document is unlawful and offenders may be prosecuted to the fullest extent of the law.

http://www.flexium.com.cn/

mailto:[email protected]

http://www.sgs.com/terms_and_conditions.htm

December 8, 2018 [ALLIANCE FOR WATER STEWARDSHIP CONFORMITY ASSESSMENT REPORT]

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TABLE OF CONTENT

REPORT DETAILS ................................................................................................................ 2

1 EXECUTIVE SUMMARY ................................................................................................. 4

2 SCOPE OF ASSESSMENT ............................................................................................ 5

3 STAKEHOLDER ANNOUNCEMENT AND CONSULTATION ........................................ 8

4 DESCRIPTION OF CATCHMENT ................................................................................. 11

5 SUMMARY OF SHARED WATER CHALLENGES ....................................................... 18

6 INDICATORS CHECKLIST ........................................................................................... 20

7 AUDIT FINDINGS ......................................................................................................... 36

8 SUMMARY .................................................................................................................... 40

9 OPPORTUNITIES FOR IMPROVEMENT...................................................................... 41

10 CONCLUSIONS AND RECOMMANDATIONS ............................................................. 42

11 REFERENCES .............................................................................................................. 43

APPENDIX 1 SGS AUDIT CHECKLIST............................................................................... 47

APPENDIX 2 FLEXIUM ACTION PLANS RESPONSE TO FINDINGS ................................ 48


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1 EXECUTIVE SUMMARY

The scope of services covers the conformity assessment of water use in compliance with the

AWS International Water Stewardship Standard (Version 1.0) for Flexium Interconnect

(Kunshan), Inc. (hereinafter referred to as “Flexium” or “the site”) located at No. 1399, Hanpu

Road, Yushan Town, Kunshan City, Jiangsu Province, P. R. China. The assessment has been

completed in compliance with the AWS Certification requirements, Version 1.0 dated July

2015.

Flexium started operating in 2000, and it manufactures and assembles flexible printed circuit

boards.

On Nov. 7-8, 2018, SGS-CSTC Standards Technical Services Co., Ltd. (hereinafter referred

to as “SGS”) conducted the on-site conformity assessment for Flexium’s facilities and activities

with regard to certification to the AWS Standard. A total of five findings were raised during the

course of the audit process and they were all categorized as minor non-conformities.

Flexium responded to the findings raised with root cause analysis and action plans. Our review

confirmed that all corrective action plans are acceptable.

Given the review of evidence provided and the site visit performed at Flexium, SGS

recommends that Flexium be awarded the AWS Gold Certified status with a surveillance audit

interval of annual frequency.


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2 SCOPE OF ASSESSMENT

The scope of services covers the conformity assessment of water use in compliance with the

AWS International Water Stewardship Standard (Version 1.0) for Flexium Interconnect

(Kunshan), Inc. (hereinafter referred to as “Flexium”) located at No. 1399, Hanpu Road,

Yushan Town, Kunshan City, Jiangsu Province, P. R. China. The assessment has been

completed in compliance with the AWS Certification requirements, Version 1.0 dated July

2015.

A pre-assessment for Flexium’s facilities and activities with regard to certification to the AWS

Standard was performed by Scott Liao and Jiansong Chang, the AWS certified auditors from

SGS-CSTC Standards Technical Services Co., Ltd. (hereinafter referred to as “SGS”) on Sep.

17-18, 2018. During the pre-assessment, SGS conducted an on-site audit that covered water

supply facilities, electroplating workshop, chemical warehouse, hazardous waste storage,

wastewater treatment facilities, online monitoring devices installed for treated effluent,

employees’ canteen and dormitories, personnel interviews and document reviews. A total of

ten findings were raised during the pre-assessment process. Flexium responded that

corrective actions will be taken to successfully close all findings raised at pre-assessment

stage and before commencement of conformity assessment.

On Nov. 7-8, 2018, SGS conducted the conformity assessment on-site visit of Flexium’s

facilities and activities with regard to certification to the AWS Standard. Table 2.1 includes

details on SGS audit team. The audit plan is attached as a separate document.

Table 2.1 SGS Audit Team

Audit Team Qualifications/Experience

Scott Liao Team Leader

AWS certified auditor, with more than 15 years experience

in pollution control, environmental impact assessment,

ISO14001 audit and training.

Jiansong Chang Team Member

AWS certified auditor, with more than 23 years experience

in environmental impact assessment (EIA), treatment of

wastewater, solid waste and hazardous waste, more than 5

years experience in performing environmental and social

risk assessment in line with the IFC E&S, FSC FM and

RTRS soy bean production standards.

Donglin Zhu Technical Expert

Dr. Donglin Zhu, senior engineer, WWF’s special advisor of

water stewardship, and external tutor of graduate student

of Environmental College, Fudan University. A key expert

to develop the state master plan for controlling Tai Lake


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contamination, and to be responsible for the study of 13th

Five-Year Plan for water environmental governance of Tai

Lake catchment.

During the conformity assessment, the team spent 0.5 day on stakeholder consultation

meetings and 1.5 days inspecting Flexium’s installations and reviewing activities and

documents. Inteviews with personell were also carried out.

Flexium provided most of the requested supporting documentation as evidence whilst on site.

SGS provided initial feedback on the gaps between Flexium’s current management and the

level required by the standard during the closing meeting of the conformity assessment on

Nov. 8, 2018.

Table 2.2 includes pictures taken while on-site.

Table 2.2 Photos from Flexium Site Assessment

Rain water collection pool

Online monitoring devices installed for treated

effluent

Rain water discharge

Treated effluent discharge


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Waste water treatment pool

Chemical warehouse

Kuilei Lake (one of Kunshan’s drinking water

sources)

Poster of water related education for local school

Water related education for local school students

Bottled drinking water provided for local fire

brigade


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3 STAKEHOLDER ANNOUNCEMENT AND CONSULTATION

Following the AWS Certification Requirements, before the on-site conformity assessment,

SGS prepared a stakeholder announcement on Oct. 5, 2018, which stated Flexium’s intention

to pursue AWS certification. Besides submitting to AWS for publication on the AWS website,

the stakeholder announcement was also posted on the information disclosure bulletin board

respectively installed at Flexium’s cateen, local environmental protection authority and

surrounding comminties, and displayed on Flexium’s website:

http://www.flexium.com.cn/big5/green_aws.asp

SGS received no feedback information since the release of the stakeholder announcement.

Photo 3.1 Information Disclosure Bulletin

Board Installed at Flexium’ Cateen

Photo 3.2 Information Disclosure Bulletin

Board Installed at local environmental protection

authority

Photo 3.3 Information Disclosure

Bulletin Board Installed at Peilvyuan Community


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Photo 3.4 Screen Shot of Stakeholder Announcement Displayed on Flexium’s Website

During the conformity assessment, SGS held a stakeholder consultation meeting. Table 3.1

presents the personnel interviewed.

Table 3.1 Personnel Interviewed during Stakeholder Consultation Meeting

Organization Personnel Interviewed

Local environmental protection authority Mr. Sichen MEI

Surrounding comminity

Mr. JIANG, director of Peilvyuan Community

Ms. XING, director of Maose Community

Supplier

Ms. Xiaoxia CHEN, manager of XINGRONG

Mr. Qnlin XIA, business director of MAIDER

Mr. Guozhong HE, business director of KEBOXI

Neighbouring factory Mr. Boru LIN, general manager of XINMAO

Mr. Xin YIN, director of TONGTAI

AWS

Ms. Zhenzhen Xu, chief representative of Greater

China

Ms. Chang Ge, official of Greater China


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Based on the interviews with local stakeholders, there was overall satisfaction with Flexium’s

water stewardship initiative. The official from the local environmental protection authority said

that Flexium has become a good example in the hi-tech development zone because of its good

environmental performance. Representatives of Flexium’s suppliers and neighbouring

factories mentioned they also developed water stewardship plans under the influence of

Flexium’s promotion of AWS certification. According to the directors from surrounding

communities, it is the first time for them to learn that the AWS standard requires a factory to

make contribution to the protection of a catchment, beyond the factory boundaries.

Surrounding communities have expressed the desire to cooperate with Flexium to protect the

local water environment. In addition, all stakeholders confirmed that the Wusongjiang

catchment is not a water scarce catchment.

Photo 3.5 and 3.6 show the stakeholders’ consultation meeting.

Photo 3.5 SGS Auditor Introducing the

Requirements of AWS Standard

Photo 3.6 Stakeholders Participating

in the Consultation Meeting


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4 DESCRIPTION OF CATCHMENT

Flexium’s domestic and production water is supplied by Kunshan Waterworks Group, which

has three water supply plants and two water sources including the Kuilei Lake and the Yangtze

River. According to the public information of Kunshan Waterworks Group, its tap water supply

has covered the whole Kunshan city with the total area of 927km2, and the daily maximum

water supply is 1,102,100m3. In addition, according to Kunshan municipal plan, the control

target of water consumption in 2020 will be 7.85x108m3. Since the total water consumption of

Kunshan in 2017 is 4.3128x108m3, no water scarcity will happen in Kunshan in the next two

years.

Flexium has built a wastewater treatment station which covers the process of denitrification,

dephosphorization and removal of heavy metal (Ni). After being treatd, effluents are

discharged into the municipal sewage pipeline network and then treated by the Chengbei

Wastewater Treatment Plant. The treated effluent is discharged into the Loujiang River,

through Zhangjiagang and Qingyanggang, and finally flows into the Wusongjiang River. Based

on the location of the water source and final destination of effluent, the external boundary for

the water stewardship of the factory is determined as the Wusongjiang River Catchment in

Kunshan City.

The Wusongjiang River catchment belongs to a sub-catchment of the Taihu Lake Catchment.

The Wusongjiang River originates from the Taihu Lake. It flows through Wujiang, Suzhou,

Kunshan and Shanghai's Qingpu, Jiading, Minhang, Putuo, Changning, Jing'an, Hongkou and

Huangpu districts, and then enters into the Huangpu River at the Waibaidu Bridge. With the

Bei Xinjing as the boundary, the upper reaches of the Wusongjiang River are called

Wusongjiang River by local people, and the lower reaches of the Wusongjiang River are

located in the east of the Bei Xinjing. After entering into the Shanghai area, it is called the

Suzhou River by Shanghainese. It is 125 km long, including 53.1 km long in the territory of

Shanghai. Wusongjiang River is 40km long from west to east in Kunshan. It enters into

Kunshan from Suzhou Industrial Park (where the Jianglizhuang monitoring section controlled

by Jiangsu province is installed) and flows into Shanghai (where the Shipu monitoring section

controlled by the state is installed) after passing through Kunshan. With the total land area of

735.6 km2, and the total water area of 43.5 km2, the Wusongjiang River catchment covers

Bacheng Town, Zhoushi Town, High-tech Zone, Development Zone, Lujia Town, Huaqiao

Town, Zhangpu Town and Qiandeng Town. There are 1,917 rivers and 8 provincial key lakes

in the catchment.

Figure 4.1, 4.2 and 4.3 respectively show the catchment of Tai Lake, the catchment of

Wusongjiang River, and the water system in the catchment of Wusongjiang River.


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Figure 4.1 The Catchment of Tai Lake

Tai Lake

Yangtze River

Shanghai Suzhou

Wusongjiang River

Catchment


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Figure 4.2 The Catchment of Wusongjiang River

Flexium


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Figure 4.3 The Water System in the Catchment of Wusongjiang River

In addition, to protect drinking water sources and the ecological environment, Kunshan has

demarcated the drinking water protected areas and the ecological protection red lines. Figure

4.4 and 4.5 respectively present the conservation areas of drinking water and the map of

ecological conservation red lines.

Yangcheng Lake

Kuilei Lake

Loujiang River

Qingyanggang River

Wusongjiang River

Wusongjiang River

Kunshan

Suzhou Industrial

Park

Shanghai Qingpu District

Shanghai Jiading District

Flexium


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Figure 4.4 Kunshan Conservation Areas of Drinking Water

Yangcheng Lake

Kuilei Lake

Legend:

First-grade protection zone

Second-grade protection zone

Prospective protection zone

Water intake

Miaojinghe Water Supply Plant


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Figure 4.5 Distribution Map of Kunshan Ecological Conservation Red Lines

Legend:

Red: First-grade control area

Green: Second-grade control area

Yangcheng

Lake

Kuilei

Lake

Wetland of

Dianshan Lake

Drinking Water

Conservation Area

Conservation Area for Chinese Mitten Crab

Conservation Area

for Culter Ablurnus

Bailewsky

Miaojinghe

Drinking Water

Conservation Area


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Figure 4.6 shows Flexium’s water supply and wastewater discharge.

Figure 4.6 Flexium’s Water Supply and Wastewater Discharge (Blue: Water Supply; Orange: Wastewater)

Kuilei

Lake

Yangtze

River

Wusongjiang River

Qingyanggang

River

Taicangtang

River

Hanputang

River

Kunshan North

District Wastewater

Treatment Plant

Flexium


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5 SUMMARY OF SHARED WATER CHALLENGES

Flexium has identified general shared challenges in the catchment and these are listed in Table 5.1.

Table 5.1.Detailed Shared Water Challenges for Flexium

No. Water Challenge Associated Government Authority initiative/Plan*

Relevant/Rationale for Stakeholders Relevant/Rationale for Site Priority (1-4) Rationale for Prioritization

1 Potentially increased levels of water shortage

Rational use of existing water resources and protection of water sources

Increase the imbalance between drinking water supply and demand, result in the rising of water costs

Increase the imbalance between drinking water supply and demand, result in the rising of water costs

2 1: Basically not concerned and affected 2: Occasionally concerned with small influence 3: Concerned but not very often. The scope of influence is controllable, and the results are not serious. 4: Frequently concerned with high attention. The scope of influence is wide, and the results are serious.

2 Insufficient water treatment infrastructure

New sewage treatment facilities may be built to collect and treat domestic sewage

Increase the safety risks of local communities’ drinking water

Insufficient water treatment facilities, and noncompliance of water quality in the catchment may result in the production restriction, suspension or even shutdown of a factory.

2

3 Groundwater and surface water pollution risk

Conduct groundwater and surface water quality surveys, introduce relevant policies and regulations, and incorporate environmental protection supervision system in environmental management

The health of community residents may be affected; and

Residents may complain to the local government or environmental protection authority if they discover water pollution.

Production restriction, suspension or even shutdown may be required for enterprises in the catchment.

3

4 Water price Raising water price Resulting in the higher living costs for local residents and affecting their life quality

Factory manufacturing costs increase and its competitiveness declines

2

5 More difficult to obtain water license

The priority is to meet the water use of local residents,and ensure the normal production water of enterprises.

Affect local communities’ obtaining of daily domestic water

Affecting an enterprise’s normal productionand its competitiveness

2

6 More stringent requirements for water efficiency and wastewater discharge

Setting higher water efficiency rate and more stringent wastewater discharge standards

Residents will be less affected by water pollution; and

Residents may cooperate with local governments and environmental protection agencies to set more stringent standards so as to reduce the discharge of water pollutants.

Increase the company’s cost of water treatment such as the costs for chemical agents; and

The company may need to invest more for improving the efficiency of its water treatment facilities.

4


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No. Water Challenge Associated Government Authority initiative/Plan*

Relevant/Rationale for Stakeholders Relevant/Rationale for Site Priority (1-4) Rationale for Prioritization

7 Inadequate legal and regulatory supervision

Enhance supervision because the existing regulations are not fully and strictly enforced.

The living environment of residents is degraded and their health is affected. If residents discover environmental violations, they may complain to local governments or environmental protection agencies.

The company shall manage its activities according to relevant environmental regulations; and

The company shall conduct more stringent management according to the requirements of customers or international standards. Some requirements may be more stringent than laws and regulations.

4

8 Policy uncertainty Specify relevant policies and meet the requirements of the public

Influencing residents, causing their complaints to local governments or environmental agencies

The company shall manage its activities according to relevant environmental regulations; and

The company shall conduct more strict management according to the requirements of customers or international standards. Some requirements may be more stringent than laws and regulations.

4

9 Increased incidence of water-related diseases

Strengthen pollution control and reduce risk factors

Influencing residents, causing their complaints to local governments or environmental agencies

The surrounding residents will conduct environmental supervision on the enterprise;

The company must meet pollution discharge standards and take social responsibility; and

The enterprise must publicize its relevant data of water environment management.

4

* Associated Government Authorities including national and local People’s Governments, national and local environmental protection departments, national and local water affairs departments, etc.


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6 INDICATORS CHECKLIST

6.1 CORE AWS INDICATORS

As per the requirement set out in the Section 2.11.3.1 of the AWS Certification Requirements, the following table 6.1 presents all the CORE

AWS indicators with the relevant reviewed evidence provided by Flexium.

Table 6.1 Evidence Reviewed by SGS Against Each CORE AWS Indicator

Indicator Details (Core) Evidence Reviewed/Document Reference

1 Leadership (core)

1.1 Leadership commitment on water stewardship As Flexium’s parent company, Flexium Interconnect, Inc. (Flexium Group) provides the leadership commitment on water stewardship for Flexium in Kunshan. Flexium Group’s CEO has signed both the “Water Stewardship Policy” and the “Water Stewardship Commitment” developed for Flexium in Kunshan, which are made public on Flexium Group’s website. Please refer to the following website:


REF001: Water Stewardship Policy

REF002: Water Stewardship Commitment

1.1.1 Has the organisation signed and published a statement related to his water stewardship commitment that includes all of the elements listed in core criteria 1.1?

A water stewardship commitment to follow all the AWS core criteria has been signed by the CEO of Flexium Group, the factory manager of Flexium in Kunshan and the CSR management representative of Flexium Group. This commitment has been displayed on the website of Flexium Group:


and posted on the bulletin board respectively installed at Flexium Kunshan factory, local environmental protection authority (EPA) and nearby community (Lvpeiyuan Community).

REF003: Bulletin Board Installed at Employees’ Canteen of Flexium

REF004: Bulletin Board Installed at Local Environmental Protection Authority




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REF005: Bulletin Board Installed at Lvpeiyuan Community

1.2.1 Has the organisation elaborated, agreed upon and discloses a water stewardship policy?

A water stewardship policy has been signed by the CEO of Flexium Group and made public on the following website:

http://www.flexium.com.cn/big5/green_aws.asp.


2 Water challenges (core)

2.1.1 Site boundaries (map) REF006: Layout of Flexium Factory

2.1.2 Name and location of sources of water (immediate and ultimate) REF007: Map of Water Supply and Wastewater Discharge

2.1.3 Name and location of effluent discharges REF007: Map of Water Supply and Wastewater Discharge

REF008: Map of Water System in the Catchment of Wusongjiang River

2.1.4 Description or map of catchment (s) REF009: Catchment of Tai Lake

REF010: Catchment of Wusongjiang River

2.2.1 Identification of stakeholders and their water challenges (list of stakeholders, prior engagement and their water challenges)

REF011: List of Stakeholders

2.2.2 Site sphere of influence (how the stakeholders are within the sphere of influence).

REF012: EIA Report developed for Flexium’s construction project dated in August 2018 (Page 10 and 15: description of project impact on water environment)

2.3.1 Catchment data (catchment plan, public initiatives and/or public goals for the site)

REF013: List of Catchment Plans, Scenarios and Notifications updated in 2018

REF014: Response to Finding 01MINCAR

2.3.2 Water governance for the catchment: Water legal and regulatory requirements, including water and water use rights

REF015: List of national and local applicable laws, regulations and standards related to water and water use rights updated in 2018



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2.3.3 Water balance for the catchment (surface water, ground water, other)

REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.2: Water balance for the catchment)

2.3.4 Appropriate and credibly measured data to represent the physical, chemical and biological status of the site’s water source(s) by temporally relevant time unit, and commentary on any anticipated future changes in water quality

REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.3: Water quality for the catchment)

2.3.5 Water related areas for the catchment: identification of the areas and description of current status and trends

REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.4: Water related areas for the catchment)

REF018: Conservation Plan for Ecological Red Line Areas of Jiangsu Province

REF019: Implementation Plan for Ecological Red Line Areas of Kunshan City

REF020: Distribution Map of Kunshan Ecological Conservation Red Lines

EEF021: Kunshan Conservation Areas of Drinking Water

2.3.6 Infrastructure for the catchment: available information on current and projected sufficiency of water to meet the needs of the catchment

REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.5: Infrastructure for the catchment )

2.4.1 Water data for the site: water stewardship and incident response plan

REF022: Water Stewardship Plan

REF023: Emergency Response Plan for Water Interruption, Water Resources Contamination and Water Pipeline Frozen

REF024: Emergency Response Plan for environmental emergencies registered in local environmental protection authority

2.4.2 Water data for the site: water balance (volumetric balance of water input and output)

REF025: Water Balance-Flexium Kunshan-2017-1st-Half-Year

REF026: Water Balance-Flexium Kunshan-2017-2nd-Half-Year



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RFE028: Water Balance Test Report

REF029: Evaluation Report for Recycle Ratio of Industrial Water

2.4.3 Water data for the site: water quality (direct and outsourced water effluent and also possible pollution sources)

REF030: Pictures of online monitoring devices

REF031: Test report for treated effluent in July 2018

REF032: Test report for treated effluent in August 2018

REF033: Test report for treated effluent in October 2018

2.4.4 Water data for the site: water quality (inventory of chemicals stored on site that are possible causes of water pollution)

REF034: List of chemicals

REF035: Emergency response plan for chemical leakage and hazardous waste

2.4.5 Water data for the site: On-site identified water related. Documentation identifying existing, or historic, onsite Important Water-Related Areas, including a description of their status

REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges (Section 3.4: Water related areas for the catchment)





2.4.6 Water data for the site: water related costs, revenues and quantification of social, environmental and economic value generated by the site to the catchment

REF036: Water-related costs

REF037: Pictures for providing water-related education for local schools

REF038: Pictures for providing bottled drinking water for local fire brigade

2.5.1 Indirect water use: list primary inputs with their associated (annual) water use and, if possible, the origin of the water

REF039: List of suppliers of raw materials and customers, their water use, wastewater discharge and associated water risk

2.5.2 Indirect water use: list of outsourced services that consume or affect water quality. List estimated annual withdrawals and quality data.




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2.6.1 List of shared water challenges that affect the catchment REF041: List of Shared Water Challenges in the Catchment

2.7.1 Site risks and opportunities: list of site water related risks and actions to address the challenges

REF042: Flexium Water Risk Profile and Water-Related Opportunities

2.7.2 Site risks and opportunities: list water related opportunities REF042: Flexium Water Risk Profile and Water-Related Opportunities

2.7.3 Site risks and opportunities: analysis of potential savings/value creation that could result from actions to address the challenges. Look at the actions in the context of water quality, water related areas, water governance, etc.


3 Stewardship strategy and plan (core)

3.1.1 Evidence of a system that periodically evaluates compliance with legal and regulatory requirements in criteria 2.3, together with names of those responsible.

REF015: List of national and local applicable laws, regulations and standards related to water and water use rights updated in 2018

REF043: Procedure for Identification of Laws, Regulations and Other Requirements and Compliance Assessment

3.2.1 Stewardship strategy that contains water challenges within the catchment and risks for the site together with the site responses

REF044: Flexium CSR Report Progress

3.2.2 Stewardship plan that contains:

a) List of targets (as per criteria 2.7) and how continuous improvement and best practice are achieved. The targets need to be SMART


REF045: Tragets for water use and wastewater discharge in 2018

b) Proposed actions to achieve the targets and names of individuals responsible for each


c) A budget for the proposed actions with a cost benefit analysis REF022: Water Stewardship Plan


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d) Links to the desired results in terms of risks/opportunities, water stewardship outcome and shared water challenges


3.3.1 Evidence of responsiveness and resilience to water related risks embedded in the site’s incident response plan

REF023: Emergency Response Plan for Water Interruption, Water Resources Contamination and Water Pipeline Frozen

REF024: Emergency Response Plan for environmental emergencies registered in local environmental protection authority

3.4.1 Evidence of notification to relevant catchment authority of the intention of the site to contribute to the objectives of the catchment plan


4 Implementation of the water stewardship plan

4.1.1 Evidence of compliance legal and regulatory requirements with regards to water balance, water management and Important Water related areas

REF046: Approvas of local environmental protection authority regarding Flexium projects

REF047: Pollutant discharge permit




4.1.2 Evidence of efforts to provide safe drinking water and sanitation where stakeholders have an unmet human right

REF048: Test report for drinking water quality of secondary water supply in July 2018

4.2.1 and 4.2.2

Evidence that the site water balance targets are met. If in a water scarcity situation, also evidence that there is a continuous decrease in water withdrawals

REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges



4.2.3 Only in scarcity situations, evidence of no net increase in water scarcity

It is not a water scares catchment.


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REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and Challenges

4.3.1 Evidence that shows that water quality targets are met REF048: Test report for drinking water quality of secondary water supply in July 2018

4.3.2 For water quality stressed catchments only: evidence of continual improvement or best practice

It is not a water quality stressed catchment.

4.3.3 For water quality stressed catchments only and where the site wishes to increase effluent levels of water quality parameters: evidence of no net degradation in water quality in the catchment

It is not a water quality stressed catchment.

4.4.1 Evidence that targets for the Important Water related Areas have been met

Although the ecological red line areas of Jiangsu Province and Kunshan City had defined in the catchment, Flexium is located at the downstream of the ecological red line areas. Therefore, it has little influence on the water related areas for the catchment.

4.4.2 Where Important Water Related Areas is a shared water challenge, evidence that best practice are met.

Please refer to the indicator 4.4.1.

4.5.1 Evidence of the site’s on-going efforts to contribute to good catchment governance (evidence of coordination and cooperation with catchment management authorities)

REF049: Contact List of Local Catchment Management Authorities

RFE050: Records of communication with local government authorities including water-related departments

REF051: Test report for water quality of Hanputang River in 2018

REF052: Test report for water quality of Taicangtang River in 2017

REF053: Test report for sediment of Hanputang River in 2018

REF054: Test report for sediment of Taicangtang River in 2017

4.5.2 Only for weak water governance catchments: evidence of continual improvement/best practice

To control and mitigate environmental pollution, the central government established an environmental protection supervision committee in 2016, which is responsible for promoting environmental protection supervision in China including the check of local environmental protection authorities’ supervision work. Kunshan environmental protection authority started environmental protection supervision in 2017. To meet national and local


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environmental requirements, Flexium has taken a series of measures to continually improve its water stewardship including the “zero” discharge of nitrogen and phosphorus and increase the recycle ratio of industrial water to 91.35%.





4.6.1 Evidence that site product suppliers and water related service providers have been contacted and are taking actions to contribute to the water stewardship outcomes


RFE055: Training records for suppliers of raw materials and customers

REF056: Training materials for suppliers of raw materials and customers

REF056: Water Stewardship Improvement Plan of Baoli Electronic (Kunshan) Co., Ltd. in 2018

REF057: Water Stewardship Improvement Plan of Dongoyuyue (Suzhou) Electronic Technology and New Materials Co., Ltd. in 2018

REF058: Water Stewardship Improvement Plan of Hengmingda Electronic Technology Co., Ltd. in 2018

REF059: Water Stewardship Improvement Plan of Keboxi Electronic Material (Zhang Jiagang) Co., Ltd. in 2018

REF060: Water Stewardship Improvement Plan of Luchang Fine Chemical (Kunshan) Co., Ltd. in 2018

REF061: Water Stewardship Improvement Plan of Jingying Electronic Co., Ltd. in 2018

REF062: Water Stewardship Improvement Plan of Luchang Fine Chemical (Kunshan) Co., Ltd. in 2018

REF063: Water Stewardship Improvement Plan of Suzhou Tianlida Adhensives Co., Ltd. in 2018


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4.7.1 List of actions to ensure WASH on site REF065:Pictures of Employees’ Dormitoriy

REF066:Test report for water quality of employees’ canteen

REF067: Test report for water quality of employees’ drinking water dispenser

4.8.1 Evidence and list of key owners of the water infrastructure and content of message that has been conveyed related to the site risks and shared water challenges



RFE050: Records of communication with local government authorities including water-related departments

5 Evaluation (core) “against the actions taken in the implementation of the plan”. Expectation of such an evaluation at least annually. For the first implementation, look for evidence that these indicators are included in the plan.

5.1.1 Post implementation data and discussion on performance (water risk)


REF068: Review Report of Water Stewardship in 2018

REF069: Attendee list of water stewardship review meeting

5.1.2 Total amount of water related costs, cost saving and value creation with regards to the actions of criteria 3.2




5.1.3 Updated data for indicator 2.4.7 on catchment shared value creation

This is the initial assessment.

5.2.1 Evidence of evaluation of water related emergencies and extreme events (effectiveness of preventive and corrective measures) and inclusion of lessons learnt in the updated action plan



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5.3.1 Feedback and commentaries from stakeholders on the site water stewardship performance and factor input in the updated action plan

REF071: Form of satisfaction survey


5.4.1 Update of the plan with the inputs from indicators 5.1.1, 5.1.2, 5.2.1, 5.3.1. Update does not apply for the first implementation/audit

This is the initial assessment.

6 Disclosure and communication of performance (core)

6.1.1

Disclosure and public availability of summary related to the general governance structure of the site’s management with names of those accountable for compliance with water related laws and regulations





6.2.1 Disclosure of summary of site’s water stewardship results against the targets






6.3.1

Disclosure and public availability of efforts to address shared challenges and report on actions taken to help address these challenges and engage stakeholders, including public sector agencies




6.4.1 Document and make available a list any site water compliance violation together with the corrective action implemented to prevent further occurrence.

No regulatory violations occurred at Flexium to date


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6.5.1 Evidence of awareness related initiatives at site level with dates of communications and, if possible, level of awareness

REF073: Attendance list for training of water stewardship

REF074: On-site traing pictures

REF075: Flexium water stewardship training materials

6.2 ADVANCED-LEVEL AWS INDICATORS

SGS also conducted a benchmarking exercise for Flexium’s performance against the AWS Advanced-Level Criteria. The evaluation results are

presented in the following Table 6.2.

Table 6.2 Evidence Reviewed by SGS Against Advanced-Level AWS Criteria

Indicator Details (Advanced-Level) Evidence Reviewed/Document Reference Score

1 Leadership

1.3 Has the organisation initiated any action to further the AWS?

Flexium actively pursues the Alliance for Water Stewardship certification, and has officially registered AWS as seeking certification to the AWS standard.

http://a4ws.org/

REF076: Screenshot of Flexium registered at AWS for certification

3

1.5 Is there a water stewardship commitment from the most senior executive of the organisation?

A water stewardship commitment to follow all the AWS core criteria has been signed by the CEO of Flexium Group. This commitment has been displayed on the website of Flexium Group:


and posted on the bulletin board respectively installed at Flexium Kunshan factory, local environmental protection authority (EPA) and nearby community (Lvpeiyuan Community).


1

http://a4ws.org/



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1.6 Is there a commitment to assist with community water needs in time of stress?

A commitment to directly assisting with community water needs in times of scarcity has been signed by the CEO of Flexium Group, the factory manager of Flexium in Kunshan and the CSR management representative of Flexium Group. The commitment explicitly covers all AWS requirements. It has been publicly disclosed at the bulletin board respectively installed at Flexium Kunshan factory, local environmental protection authority (EPA) and nearby community (Lvpeiyuan Community). The commitment is also displayed at Flexium Group’s website.


According to the commitment, Flexium respects the rights of local communities. When the basic water demand of the communities cannot be met, it commits to continuously improving its water use, prioritizing the needs of the communities, and providing each of the stakeholders with daily access to water of 20 litres until their basic water needs are restored.





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2 Water challenges

2.9 Evidence of water data gathering beyond the standard requirements, especially in highly data deficient environments.

To help the local environmental protection authority to fully know surface water quality in the catchment and make up the data deficient for some water bodies, Flexium has voluntarily entrusted China Test (Jiangsu) Testing Technology Co., Ltd., a third-party with the qualification of China Metrology Accreditation to monitor the water quality and sediment of Hanputang River and Taicangtang River on a yearly basis since 2016. The testing parameters of water include TN and TP. The testing parameters of sediment consist of Hg, Ni, Cr, Cd, As, Se, Pb, Cu, Sb,

3



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Ba, cyanide, benzene, toluene, xylene and trichloromethane. We randomly reviewed the testing reports in 2017 and 2018 during site visit.





2.12 Site contribution to groundwater recharge and/or environmental flows restoration in coordination with relevant governmental agencies.

Although Flexium does not extract groundwater or directly recharge groundwater, cooperating with local environmental protection authority, it has drilled 10 permanent wells at the site to monitor groundwater quality on a yearly basis. Jiansu Yuanyuan Testing Technology Co., Ltd., a third-party with the qualification of China Metrology Accreditation is entrusted to perform the testing of groundwater quality. The testing parameters include pH, TPH, TVOCs, SVOCs, Sb, As, Be, Cd, Cr, Cu, Hg, Pb, Ni, Sn, Ag, Tl and Zn. The testing results are disclosed on Jiangsu environmental monitoring information platform. We reviewed the testing report in 2018 during site visit.

REF077: Test report for groundwater quality in 2018

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4 Implementation of the water stewardship plan

4.9.1 Evidence of quantified improvements in water balance from site-set baseline date.

According to the “Norm of Water Intake for industries, services and Livelihood” issued by Jiangsu Provincial Administration of Quality and Technology Supervision in 2015, the quantity of water intake for unit product of double-sided PCB is 1.08 m3/m2. To achieve this target, Flexium has taken a series of actions to improve its water balance. Based on the Water Balance Testing Report developed for Flexium by Suzhou Zhongjiexun Inspection and Testing Co., Ltd., a qualified third-party in June 2018, Flexium’s quantity of water intake for unit product of double-sided PCB in 2016 is 1.46 m3/m2, which is higher than the baseline standard. In 2017, the quantity of water intake for unit product of double-sided PCB is 0.63 m3/m2, which is lower than the baseline. Currently, Flexium’s quantity of water intake for unit product of double-sided PCB is about 0.62 m3/m2 (statistical data from January to June 2018).


8


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4.9.2 Evidence showing that actions meet best practice expectations

Besides the quantity of water intake for unit product of double-sided PCB (about 0.62 m3/m2) is far lower than the standard (1.08 m3/m2) defined by Jiangsu Provincial Administration of Quality and Technology Supervision, Flexium has also obtained a great achievement in water recycle. According to the “Cleaner Production Standard for Printed Circuit Board Manufacturing (HJ-450-2008)” issued by the Ministry of Environmental Protection, the recycle ratio of industrial water for PCB manufacturing is defined as three levels. The first level (ratio≥55%) represents the advanced international level, the second level (ratio≥45%) represents advanced domestic level, and the third level (ratio≥30%) means the average domestic level. Based on the “Evaluation Report for Recycle Ratio of Industrial Water” developed by Suzhou Zhongjiexun Inspection and Testing Co., Ltd., a qualified third-party in June 2018, Flexium’s recycle ratio of industrial water is 91.35%, which is far higher than 55%, the first level defined by the Ministry of Environmental Protection. The report demonstrates Flexium’s good water stewardship.



4.10.1 Evidence that targets have been met with regards to site water quality

Through technical renovation for its wastewater treatment, Flexium has realized the “zero” discharge of nitrogen and phosphorus. By employing the technology of low-temperature dewatering, the generation of sludge containing copper is greatly reduced. The technology used for treating wastewater containing nickle ensures the nickle concentration is lower than its detection limit. Both the review of testing reports and the on-site observation of online monitoring devices further confirmed the above information.





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4.10.2 Evidence that best practice has been achieved with respect to the site’s water quality targets as informed by stakeholders or industry benchmark. (8 points for both 4.10.1 and 4.10.2)

The practices implemented by Flexium to ensure the “zero” discharge of nitrogen and phosphorus, the reduction of sludge containing copper and the undetected level of nickle discharge have been accepted by local environmental protection authority and Apple, the purchaser of Flexium. The interviews with an official from local environmental protection


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authority and the water stewardship officer of Apple showed that they all give a high appraisal to Flexium with respect to its water quality targets.

REF078: Pictures of stakeholder consultation meeting

4.13.1 List of efforts to contribute to the development of regional industrial water related benchmarking and spreading best practice (3 points)

Because Flexium’s best practices in the respects of wastewater treatment mentioned in indicator 4.10.1, Apple has taken Flexium’s best practices as case studies and integrated them into the Apple’s Supplier Responsibility Report in 2017 and the Highlights of Outstanding EHS Projects and Tips of Apple’s Supplier in 2017 to spread Flexium’s best practices in Apple’s suppliers.

REF079: Apple’s Supplier Responsibility Report in 2017

REF080: Highlights of Outstanding EHS Projects and Tips of Apple’s Supplier in 2017

3

4.18.1 List actions taken in the context of WASH (5 points)

Flexium has established a “Flexium Warm Heart Fund”. By using this fund, Flexium provides bottled water and other foodstuff to local fire brigade every year. Flexium also provides water-related training to local primary schools to enhance the children’s knowledge of drinking water safety and their awareness of protecting water environment and saving water. Relevant records, photos and videos were reviewed during site visit.


REF081: Pictures of implementing water-related education programme in local school

REF082: Video of implementing water-related education programme in local school

5

5 Evaluation “against the actions taken in the implementation of the plan”

5.5.1 Review of the site water stewardship performance with executive team or board and provide evidence of meeting through minutes

Flexium has established an AWS executive team that is responsible for evaluating the site water stewardship performance. The factory manager is the team leader, and the team members consist of all department managers. A management meeting regarding water stewardship was held on 5 September 2018. Through the management meeting, Flexium identified water resources challenges in the catchment, water risks and water-related opportunities. A documented water stewardship plan in 2018 was developed. In addition, a water stewardship training was provided to employees on 7 September 2018.

3


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6 Disclosure and communication of performance

6.7.1 Evidence of implementation of a programme for water education at catchment level and description of the programme

Flexium has organized and implemented a water-related education programme in local schools aiming to promote water-related knowledge and raise students’ awareness of water conservation. Tips of saving water in daily life were lectured to students. Related documents and pictures were kept by Flexium.

REF081: Pictures of implementing water-related education programme in local school

REF082: Video of implementing water-related education programme in local school

4

Total 56


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7 AUDIT FINDINGS

Five minor non-conformities were raised during the audit process. They were considered partially meeting the AWS Core criterion requirement,

and some small adjustments were requested to make to the documentation in order to be considered fully compliant. The following table 7.1

shows the details of the minor non-conformities and required new information.

Table 7.1 Minor Non-Conformities Raised during the AWS Audit Process

No. Type Ref. Details Response by Flexium Relevant References

1 Minor Non-Conformance

01MINCAR Indicator 2.3.1 Catchment data (catchment plan, public initiatives and/or public goals for the site).

Flexium has established an update list of catchment plans, scenarios and notifications has been established which consists of 6 national-level catchment plans, 4 provincial-level catchment plans and 15 Kunshan City-level catchment plans. However, no aspects of the catchment plans related to Flexium’s water stewardship were identified.

On 8 December 2018, Flexium provided a corrective action plan for 01MINCAR, which consisted of:

Root analysis: because of insufficient understanding of the AWS standard requirement, only the catchment plans, scenarios and notifications were collected without identifying relevant articles.

Corrective actions: identify relevant articles of the catchment plans, scenarios and notifications, and take the relevant requirements into full consideration when developing the company’s water stewardship targets in the future.

Responsible person: Xunrong Huang, Safety & Environmental Protection Department

Implementation deadline:31 May 2019. Based on our review, the corrective action plan is acceptable.



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02MINCAR Indicator 2.3.2 Water governance for the catchment: Water legal and regulatory requirements, including water and water use rights

Flexium has established an update list of water-related laws and regulations. However, no relevant articles of national and local water-related laws and regulations that are applicable to Flexium’s water stewardship have been identified.


Root analysis: because of insufficient understanding of the AWS standard requirement, only the water-related laws and regulations were collected without identifying relevant articles.

Corrective actions: identify relevant articles of the water-related laws and regulations, and update the related information at least once a year.

Responsible person: Bo Cao, Safety & Environmental Protection Department

Implementation deadline: 30 June 2019.

Based on our review, the corrective action plan is acceptable.



03MINCAR Indicator 2.5.2 Indirect water use: list of outsourced services that consume or affect water quality. List estimated annual withdrawals and quality data.

Flexium has collected the indirect water use and wastewater discharge of its main suppliers of raw materials and customers. However, no test report of wastewater discharge is collected by Flexium regarding its main suppliers of raw materials and customers.


Root analysis: because of insufficient understanding of the AWS standard requirement, only the indirect water use and wastewater discharge of main



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suppliers were collected without collecting their water quality data.

Corrective actions: Further collect the water quality data of main suppliers, and conduct statistics and analysis.

Responsible person: Yunfang Xia, Purchasing Department

Implementation deadline: 31 March 2018.



04MINCAR Indicator 5.2.1 Evidence of evaluation of water related emergencies and extreme events (effectiveness of preventive and corrective measures) and inclusion of lessons learnt in the updated action plan

At present, water quality monitoring sections have been established for main rivers by the national and local environmental protection authorities in the catachment. If the deterioration of water quality at the river sections is monitored, the national or local environmental protection authorities will launch their emergency response plans, which may result in the production restriction, suspension or even shutdown of a factory in the catachment to reduce effluent discharge. However, Flexium fails to evaluate this water related emergencies and develop its response plan.


Root analysis:failed to integrate the government authorties’ emergency measures into the company’s emergency response plan.

Corrective actions: Fully analyse the water related emergencies, develop relevant response plan and integrate the plan into the company’s wastewater management procedure (PU4602).

Responsible person: Jason Zhang, Safety & Environmental Protection Department



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05MINCAR Indicator 5.3.1 Feedback and commentaries from stakeholders on the site water stewardship performance and factor input in the updated action plan

Flexium conducted a satisfaction survey regarding its water stewardship in September 2018, and relevant stakeholders including employees, local residents, suppliers and customers were involved. However, no summarized analysis was conducted regarding the stakeholders’ feedback.


Root analysis: because of insufficient understanding of the AWS standard requirement, although a satisfaction survey was performed, no summarized analysis was conducted.

Corrective actions: Conduct a satisfaction survey on a yearly basis, analyse the stakeholders’ feedback, and consider their inputs when updating the company’s action plan.

Responsible person: Xue Tian, Quality Sssurance Department.





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8 SUMMARY

Based on the review of documents presented by Flexium, the interview with Flexium’s

managers and employees, the interview with local stakeholders, and the site reconnaissance,

Flexium has paid great attention to its water stewardship. A considerable quantity of effort and

work has been put into the preparation for the audit of AWS certification.

Five minor non-conformities were raised during the audit process. They were considered

partially meeting the AWS Core criterion requirement, and some small adjustments were

requested to make to the documentation in order to be considered fully compliant. Flexium has

provided SGS acceptable corrective action plans to address all minor non-conformities. We

will further ascertain their compliance to the AWS Standard when performing the surveillance

assessement in 2019.

In addition, according to the conformity assessment of Flexium’s performance against the AWS

advanced-level criteria, the total of Flexium’s cumulative advanced-level criteria scores is 56,

which is up to the AWS Gold level.


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9 OPPORTUNITIES FOR IMPROVEMENT

This is the initial conformity assessment for Flexium against the AWS Standard, and more

attention is paid to the documented plan and implementation to date. Less focus was placed

on the evaluation of Flexium’s performance against the indicators as this was the first year of

operation under the intention of conformity to the AWS Standard. Therefore, it allows for many

areas for improvement going forward.

Besides the follow-up of implementation of corrective action plans to address all minor non-

conformities, the future audits will additionally evaluate Flexium’s performance against the

AWS Standard indicators and how this is monitored and presented as compliance. Thus, SGS

recommends that Flexium develop practicable ways to monitor its performance against the

AWS Standard indicators, and keep relevant records in anticipation of future audits.


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10 CONCLUSIONS AND RECOMMANDATIONS

Given the review of evidence presented and the site reconnaissance performed at Flexium,

SGS recommends that Flexium be awarded the AWS Gold Certified status with a surveillance

audit interval of annual frequency.


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11 REFERENCES






REF006: Layout of Flexium Factory

REF007: Map of Water Supply and Wastewater Discharge

REF008: Map of Water System in the Catchment of Wusongjiang River

REF009: Catchment of Tai Lake

REF010: Catchment of Wusongjiang River

REF011: List of Stakeholders

REF012: EIA Report developed for Flexium’s construction project in August 2018

REF013: List of Catchment Plans, Scenarios and Notifications updated in 2018


REF015: List of national and local applicable laws, regulations and standards related to

water and water use rights updated in 2018


REF017: Report of Background Information for Flexium’s Water Risks, Opportunities and

Challenges






REF023: Emergency Response Plan for Water Interruption, Water Resources Contamination

and Water Pipeline Frozen


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REF024: Emergency Response Plan for environmental emergencies registered in local

environmental protection authority


REF026: Water Balance-Flexium Kunshan-2017-2nd-Half-Year








REF034: List of chemicals

REF035: Emergency response plan for chemical leakage and hazardous waste

REF036: Water-related costs

REF037: Pictures for providing water-related education for local schools


REF039: List of suppliers of raw materials and customers, their water use, wastewater

discharge and associated water risk


REF041: List of Shared Water Challenges in the Catchment




REF044: Procedure for Identification of Laws, Regulations and Other Requirements and

Compliance Assessment

REF045: Tragets for water use and wastewater discharge in 2018

REF046: Approvals of local environmental protection authority regarding Flexium projects

REF047: Pollutant discharge permit


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REF048: Test report for drinking water quality of secondary water supply in July 2018

REF049: Contact List of Local Catchment Management Authorities

RFE050: Records of communication with local government authorities including water-

related departments





RFE055: Training records for suppliers of raw materials and customers

REF056: Training materials for suppliers of raw materials and customers

REF057: Water Stewardship Improvement Plan of Baoli Electronic (Kunshan) Co., Ltd. in

2018

REF058: Water Stewardship Improvement Plan of Dongoyuyue (Suzhou) Electronic

Technology and New Materials Co., Ltd. in 2018

REF059: Water Stewardship Improvement Plan of Hengmingda Electronic Technology Co.,

Ltd. in 2018

REF060: Water Stewardship Improvement Plan of Keboxi Electronic Material (Zhang

Jiagang) Co., Ltd. in 2018

REF061: Water Stewardship Improvement Plan of Luchang Fine Chemical (Kunshan) Co.,

Ltd. in 2018

REF062: Water Stewardship Improvement Plan of Jingying Electronic Co., Ltd. in 2018

REF063: Water Stewardship Improvement Plan of Luchang Fine Chemical (Kunshan) Co.,

Ltd. in 2018

REF064: Water Stewardship Improvement Plan of Suzhou Tianlida Adhensives Co., Ltd. in

2018

REF065:Pictures of Employees’ Dormitoriy

REF066:Test report for water quality of employees’ canteen

REF067: Test report for water quality of employees’ drinking water dispenser



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REF071: Form of satisfaction survey





REF076: Screenshot of Flexium registered at AWS for certification

REF077: Test report for groundwater quality in 2018

REF078: Pictures of stakeholder consultation meeting

REF079: Apple’s Supplier Responsibility Report in 2017

REF080: Highlights of Outstanding EHS Projects and Tips of Apple’s Supplier in 2017

REF081: Pictures of implementing water-related education programme in local schools

REF082: Video of implementing water-related education programme in local schools


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APPENDIX 1 SGS AUDIT CHECKLIST


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APPENDIX 2 FLEXIUM ACTION PLANS RESPONSE TO FINDINGS

Documents

alliance for water stewardship Conformity assessment reporta4ws.org/wp-content/uploads/2019/03/AWS-Conformity-Assessment … · Flexium provided most of the requested supporting documentation