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Workplace Conditions Assessment Report Measured Resulʦ······· Improved Performan Redacted GENERAL INFORMATION Report No: IAR_89371 Ci: Audit Date: Dec 22, 2017 Count: Last Audit: NA Auditors: Assessment Annual �Clllyp : Announced S.ervi.ce .Provid.er. : WORKPLACE PERFORMANCE INDEX AND SUMMARY 85-100% High Perrmance = Redacted China Primary: jene zhang condary: None Intertek Participating cilities: 26986 - Overall Facili Score : 89% •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• ••••••••••••••••••••••••• 71-84% Medium Perrmance 51-70% Low Perrmance Average Global Score: 78% Average Country Score: 76% Average lndusfry Seu re: 76% Overall 1 1 5 0-50% Ve low Performance - Labor W�es&HtttS Manement Systems Environment Si I I I SU •. ., .. 11.1a 72% 74% o trt� k This message contains inrmation, which is confidential and the copyright of lntertek. Alf rights res eed Total Quality. Assured. 3 1 2 1 Page1of14

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Page 1: Workplace Conditions Assessment Report Factory - Fair Labor Audit Decemb… · Workplace Conditions Assessment Report Nr. FJAR_89371 Redacted Wages and hours summary: 1. Through document

Workplace Conditions Assessment Report Measured Results······· Improved Performance

Redacted

GENERAL INFORMATION

Report No: IAR_89371 City: Audit Date: Dec 22, 2017 Country: Last Audit: NA Auditors: Assessment Annual

�Cl:l(;(llll(;'J'yp(; : Announced S.ervi.ce .. Provid.er.:

WORKPLACE PERFORMANCE INDEX AND SUMMARY

85-100% High Performance

= !!

Redacted China Primary: jene zhang Secondary: None Intertek

Participating facilities: 26986

-Overall Facility Score : 89% •••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••••• •••••••••••••••••••••••••••••••••

71-84% Medium Performance

51-70%Low Performance

Average Global Score: 78%

Average Country Score: 76%Average lndusfry Seu re: 76%

Overall 1 1 5

0-50% Very low Performance

-

Labor

W�es&HtJtttS

Management Systems

Environment

Si I I I SU

•.. , ..

11.1.1.1a

72%

74%

111 t(:':rt� k This message contains information, which is confidential and the copyright of lntertek. Alf rights resen;ed

Total Quality. Assured.

3

1 2

1

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Workplace Conditions Assessment Report Nr. FJAR_89371

Redacted

A. FACILITY PROFILE

Al. FACILI1Y INFORMATION

Facility Name:

Facility Legal Name:

Audit Location:

City:

Country:

Contact Name:

Contact Title:

Indust1y:

Building Description:

Redacted

Redacted

China

Mr. Yuan Changhua

General Manager

Accessories

Facility Legal Status:

Year facility began operations:

Located in special economic zone:

Person responsible for overall social compliance issues:

Valid certificate for social compliance certification program:

Vendor Name:

Security systems in place:

Privately owned

April 2002

Yes

Mr. Yuan Changhua

1SO9001: 2015, from August 17, 2017 to August 16, 2020. 15014001: 2015, from March 20, 2017 to March 19, 2020.

Redacted

Yes Security guards were used for controlling physical access of outsiders.

Special building type:

In view of the facilities, the facility consists of one flat (partial 2-storey) building for office, canteen, workshop and warehouse. No kitchen and dormitory were available in the facility. Total Land area was 1800 m2 and total structure area was 2000 m2. The facility used one food service provider out of the facility. Remark The facility had rented one flat (partial 2-storey) building from other facility named Redacted Factory used as warehouse, workshop, office and canteen. Through facility tour, document review and management interview, both two facilities have independent business license, management and production process. The employees of the facilities also would not be borrowed in any case which was also confirmed through employee interview. The facility had provided the lease contract and business license for review

NA

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Workplace Conditions Assessment Report Nr. FJAR_89371

A2. PRODUCTION INFORMATION

Products manufactured/ Plastic tableware and Molds Services

Production process/ Service elements:

Production capacity a week:

Total number of machines:

Main machine types:

Crushing,mixing,injection, inspection and packing

50 tons.

25 sets.

Injection machines, Crushing machines and etc.

Time record system( s) used:

Chemicals or hazardous materials on-site:

Current production/ Services for client:

Swipe Card system

Yes Such as lubricating oil, ethyl alcohol and etc.

NA

Shifts and Operating hours:

The normal workdays of office and package workshop were from Monday to F1iday in one shift from 8:00 to 17:00 with 1 hour's lunch time from 12:00 to 13:00. The normal workdays of other employees were from Monday to Friday in three shifts from 8:00 to 16:00, 16:00 to 00:00 and 00:00 to 8:00, they take turns for rest.

A3. EMPLOYEE INFORMATION

Range of total number of 0-100 employees employees at the facility:

Union name:

Employs juvenile workers:

Hires through employment agent:

None

None

No All employees were hired directly by the facility.

Female Employees:

Male Employees:

Mgmt Employees:

Production (Non­Management) Employees:

Local Employees:

Foreign/Migrant Employees:

47

15

3

59

20

42 Employee nationalities/ provinces:

No foreign employee was hired, and migrant employees mostly come from other provinces of China, such as redacted Province.

Languages spoken in the facility:

Mandarin

A4. SUBCONTRACTOR INFORMATION

No subcontractor information given

Management and employees speak same language :

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Yes

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Workplace Conditions Assessment Report Nr. FJAR_89371

AS. GENERAL INFORMATION

1. Attitude of workers: Interviewees were comfortable during interview. All employees were satisfied with the facility and no negative information was raised. They are satisfied with the working condition and management system.2. Attitude of management: The management showed a positive attitude to this audit during the whole process. All documentation requested for review was provided timely. Locked areas encountered during the audit were unlocked timely. At the end of the audit, all the findings were accepted by the facility management.3. Peak seasons were not obvious in the facility.4. The facility gives eveiybody equal opportunity and salmy.5. Auditor found that the facility had two production area.Site A: address: Redacted. main product: Plastic product; responsible person: Mr. Yuan Changhua/ General managerSite B: address: Redacted. main product: moldings; responsible person: Mr. Gu Linfu/ General managerBoth two facilities have independent management and production process. The employees of the facilities also would not be borrowed in any case which was also confirmed through employee interview. The facility management had provided a statement for review.Site A eveiy audit process can be carried out.Site B - eveiy audit process is denied as privacy policy.

Emergency Preparedness Summary

1. The facility provided fire safety equipment throughout the facility such as fire extinguishers, fire hydrant, fire alarmsand emergency lights, which were adequate for the nature of operations in terms of sufficient quantity, correct type andvalid and was inspected regularly by an internal inspector.2. Evacuation maps are also posted in the workshop with position of firefighting equipment, current location, emergencyexits, and routes of evacuation. Exit signs were also available for safety exits.3. Emergency routes are clearly marked on the floors which can lead employees to emergency exits.4. The facility provided the fire emergency plan (including responsible person, emergency measures, fire servicesinstallation, firefighting equipment, fire evacuation exit and route, fire assembly area) for review.5. The facility arranged the fire drills for employees in the facility quarterly. The last fire drills was conducted onNovember 17, 2017, which had been confirmed through employee interview.

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A6. AUDIT PROCESS

Audit pay period provided for review Employee interview sampling

Records From

12 Months Attendance 2016-12-01

Special Comments N / A

To

2017-11-30

2017-12-21

Individual

Group

Total interviewed

Payroll and attendance records sampling

Period

Current Period

Period 1

Period 2

Total

From

2017-11-01

2017-08-01

2017-03-01

Other records reviewed

Personnel records

Production records

Employment contracts

Social insurance documentation

Health examination records

To

2017-11-30

2017-08-31

2017-03-31

Peak Season

No

No

No

Secmity log book

Non-Production records

Legal Permits

Employee leave register

Machine maintenance records

Total 7 employees were interviewed individually including 2 male employees and 5 female employees

0

Total 7 employees were interviewed, which included 7 individuals and 0 group.

Records Reviewed

7

3

3

13

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B. KEY PERFORMANCE METRICS

B1. COMPARISON BENCHMARK

Current performance Global average, China average, Accessories average

Labor Wages & Hours Health & Safety Management Systems

100%

i \:if '),) '),) l};j

Ill iiiiii iiii iiiiii

•••• • 7J ;;; 7R 77 7r�

80%

60% ••••----

20%

0% iiii

, 69

iiiii 62

-

i

B2. PERFORMANCE TREND ANALYSIS

Current Last Section Name

(22-Dec-2017) (Not Applicable)

Labor 100 Not Applicable

Wages & Hours 100 Not Applicable

Health & Safety 95 Not Applicable

Management Systems 72 Not Applicable

Environment 74 Not Applicable

Overall Score 89 Not Applicahle

Advancers r.m:::: Constant �� Decliner

PERFORMANCE RATING

First

(Not Applicable)

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Change

I I I I

i i LJ

(Current-Last)

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Environment

f]() /(J 7(,

Change

(Current-First)

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Not Applicable

Low(51% 70}'.:) Medium (71 % 1141/) High (85% I Oil/)

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B3. WORKING HOURS AND WAGES

Average total hours worked weekly

Normal Work Hours

120 hrs

100 hrs

80 hrs

60 hrs

.tQ hrs

20 hrs

0 hrs

"""'Overtime Work Hours

''''''''''''''''''' u ''

2017-11-01 2017-JJ.:J0

Average

lnternaUonal Standard: 60 China average: 52

''''''''''''''''''' i) ''

2017-08-01 2017-08·3!

Average

::::::::::::::::::: g ·:,

2017-03-01 2017-03-31

Average

Highest hours this faciliry: 48

Average wages paid in local currency (RMB)

2500 R.,18 2,){l(l 2206

2051

,WOO R�vtB

1500 R'.v1B

'1000 R'.viB

500 R>1B

0 R\18 This Facifit;y Minimum Wuge Province Average Country Average

Special wage circumstances: The local minimum wage standard was RMB 1820 per month equivalent to RMB 10.46 [1820/21.75/8) per hour from January l, 2016 to June 30, 2017 and RMB 1940 per month equivalent to RMB RMB ll.15(1940/21.75/8) per hour since July l, 2017.

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Wages and hours summary: 1. Through document review, all the employees were paid above the minimum wage. Wages of all employees were calculated by hourly rated basis.The peak month was not obvious. 2. Through payroll records and employees interview, the facility paid the employee's overtime at200% of normal rate on rest days. No overtime hours were arranged on normal workdays andholidays.3. Through employee interview, all the employees stated that they worked overtime on voluntaiybasis and used electronic attendance system.4. Legal required benefit such as annual leave, sick leave, nursing leave, etc. had been provided forlegal employees and relevant leave records and policy records had been provided for review.5. 12 months and 11 days' production records such as daily production records, inspection records,material delivery records and etc were provided for review, no inconsistencies were found aftercrosschecked with provided attendance records.6. Based on documents provided by the facility, 1) For November 2017 [current month], the averagenumber of hours worked in a week for the 7 selected samples were 48 per week. Maximum workinghours per week were 48 (all 7 randomly selected samples). Maximum monthly overtime hours were32 [all 7 randomly selected samples), the maximum daily overtime hours was O hour [all 7 randomlyselected samples). 2) For August 2017 [random month], the average number of hours worked in aweek for the 3 selected samples were 48 hours per week. Maximum working hours per week were 48(all 3 randomly selected samples). Maximum monthly overtime hours were 32 (all 3 randomlyselected samples],the maximum daily overtime hours was O hour [all 3 randomly selected samples];3) For March 2017 [random month), the average number of hours worked in a week for the 3selected samples were 48 hours per week. Maximum working hours per week were 48 hours (all 3randomly selected samples). Maximum monthly overtime hours were 32 hours [all 3 randomlyselected samples),the maximum daily overtime hours was O hour (all 3 randomly selected samples).

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C. PERFORMANCE DETAILS

Current (22-Dec-2017)

Cl. Labor

!OU

l3(,.

60.

40 --

20 1111

o-

NA

!! • --

!!! NA

!! • --

!!! NA

C2. Wages & Hours

100

8(1 !!!

:I NA

0 -::;;r::cr LJst

PERFORMANCE RATING

!!!

I NA

\:,.'a/;.::, '--- �t'.-'! __ __,

fkr::li'.s

• • --

!!!!

Low(51% 70}'.:)

• • --

!!!

Medium (71 % 1141/)

• • --

!! NA

High (85% I Oil/)

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C3. Health & Safety

NA NA NA NA NA NA

l:JlT:'JCt cu·1c-1:;·

L'i,:'i'_J L inu;.,,; J L >,,r,t(.;(J LM h(v_J L •;;,;y _J L '''.:::°

' _J L D,w'.n. 1.u: _,EC -

'.".,c'i'L;· Prep;i!\:'(Ff;,';i 11\P'.'Y YJ:t::y ili!ZT'(>; )!·1;-n:nm M;<;,,.n;0],; C'.:;,-:�-�·-1

Sub Section: General Work Facility

• Minor 171.00 : Noise level at the facility is not acceptable 88%

Auditor's comment Testing result of occupational hazards factors exceeded standard. During facility tour, auditor found that crushing and mixing workshop with hazardous factors including noise. During document review, testing report indicated that the factors of occupational disease hazards in crushing workshop and mixing workshop exceeded the limit of national standard, which was 96.ldb-105.4db.

Sub Section: Occupational Injury

• Minor 211.00 : The facility does not conduct and/ or pay for regular occnpational health 73%

examinations for employees when applicable

Auditor's comment No occupational health examination was provided to employees engaged in posts with occupational disease hazards. During facility tour, auditor found that there were 2 employees working in crushing and mixing workshop with hazardous factors such as noise. However, no periodic occupational health examination reports which required by law for 1 out of 2 employees who engaged in hazardous posts were provided for review. People's Republic of China Law of Prevention and Control ofOccupational Diseases Article 36The employer shall conduct regular occupational health examination for those laborers who are engaged in using or contacting noxious articles in their working process as required by medical administrative department under the State Council. The occupational health examination should be conducted before laborers start to take work post, in the course of the work post and after leave the work post and employer should inform the laborers of the result of the occupational health examinations. The expense of the occupational health examination should be borne by employers. Employer should not arrange laborers without the occupational health examination to be engaged in the work with using or contacting noxious articles, or laborers with any occupational prohibitions to be engaged in the prohibited work from them. Once the occupational health examination indicates that employee is suffering from the occupational disease in relation to his or her occupation, the employer shall transfer such a laborer out of his or her original work post, and allocate him or her in a proper way. Employer should not rescind or terminate the contracts signed with those employees without the occupational health examination at time of leaving the work post The occupational health examination should be conducted by the medical organizations authorized by the medical administrative department above province�level.

PERFORMANCE RATING

Low(51% 70}'.:) Medium (71 % 1141/) High (85% I Oil/)

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Sub Section: Occupational Injury

• Minor 213.00 : The facility does not apply for testing of factors of occupational hazards at least once·ayear·andthereport·kept forreview

/lu_di(of';S (J0:fl1Jt1B:fl( '.f t;!Stin:g:1"(:!SUJt pf :OQCU:Pfltiomtl Qa:za:r(is :factqrn RX{;et2cle(i :Sta11(fa:rd:, :Ot1ri11g facility tour, auditor found that crushing and mixing workshop with hazardous factors including noise. During document review, testing report indicated that the factors of occupational disease hazards in crushing workshop and mixing workshop exceeded the limit of national standard, which was 96.ldb-105.4db, Provisions on the Supervision and Administration of Workplace Occupational Health Article 20 An employing entity with occupational hazards shall entrust an occupational health technical service agency with corresponding qualification to conduct evaluation on occupational hazard factors at least once everyyear. An employing entity with severe occupational hazards shall, in

,, , , , , , ,, ,, ,, ,, , 1 addition:to,the·:above'requ:irement;'entrusts:'an::occ:upational:health:techn:ical:s·ervice:age:ncy:with corresponding qualification to conduct assessment on occupational hazard status at least once every three years. The results of the evaluation and assessmi:•nt shall be kept in archive, reported to. local administration dRpartment of work safRty, and. announced tothewockRrs,

PERFORMANCE RATING

75%

Low(51% 70}'.:) Medium (71 % 1141/) High (85% I Oil/)

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C4. Management Systems

lOO

80

40

20 NA

0

Sub Section: Management Systems

Major

• Minor

• Minor

291.00 : The facility does not have a valid business license/ registration/ permit t o operate Auditor's comment Information of business license was not updated. Through facility tour, auditor found that the facility actual address was No 3 Building, ]inqiao Industrial Park, No 8 Jinqiao Road, Mudu Town, Wuzhong District , Suzhou City and No. 16 Muxu East Road, Mudu Town, Wuzhong District, Suzhou City, Jiangsu Province. Through document review, the address on business license was Sunzhuang village, Mudu Town, Wuzhong district, Suzhou City. Through manager interview, the facility moved from Sunzhuangvillage to No 3 Building, Jinqiao Industrial Park, No 8 Jinqiao Road, Mudu Town, Wuzhong District, Suzhou City and No. 16 Muxu East Road, Mudu Town, Wuzhong District, Suzhou City, Jiangsu Province and they did not update the address of buisness license.

296.05 : The facility has comprehensive processes and procedures in the area of general facility, dormitory (if any) and/ or cantee11 (if any) management (e.g. clea1tliness, ventilation, noise, lighting, toilets) in written manual that support adherence to social compliance requirement but they are not all being properly implemented. Auditor's comment The facility had established the. facility, dormitory and canteen management, hutthe daily implementation was insufficient Such as testing result ofoccupational hazards

296.07: The facility has comprehensive employee safety processes and procedures in a written manual that support adherence to social compliance requirements but they are not all being properly implemented Auditor's comment The facility had established the employee safety procedures, but the daily implementation was insufficient Such as testing result of occupational hazards factors exceeded standard.

PERFORMANCE RATING

72%

96%

75%

54%

Low(51% 70}'.:) Medium (71 % 1141/) High (85% I i!ilf)

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CS. Environment 74%

lOO

80

40

20 NA

0

Sub Section: Environment

Moderate 331.00 : The air emissions do not meet the discharge limits for regulated constituents 86%

Auditor's comment The facility did not perform monitoring tests for pollutants. During facility tour, auditor found that the waste gas was generated from injection workshop. However, the facility could not provide monitoring report of waste gas for review. Law of the People's Republic of China on the Prevention and Control of Atmosphelic Pollution Article 18 When a construction project that is going to be built will have an impact on atmospheric environment, enterprises, public institutions, and other production and business entities shall conduct environmental impact assessments and publicize the documents on environmental impact assessment according to the law; when discharging pollutants to the atmosphere, they shall conform to the atmospheric pollutant discharge standards and comply with the requirements of total emission volume control for the discharge of key atmospheric pollutants.

% Global Frequenq, of Compliance: Represents the implementation percentage performance of all suppliers participating in the WCA Community globally for each issue

Identification numbers: Represents the finding ID associated with each checklist question

RECOMMENDATION FOR IMPROVEMENT PLAN TIMELINE

• Minor Take action within O - 6 months to makenecessary improvements.

Moderate: Take action within O - 3 months to makenecessary improvements.

PERFORMANCE RATING

Low(51% 70}'.:)

'11> Major: Take action within O - 1 month to make necessary improvements.

• Zero Tolerance: Take immediate action to makenecessary improvements.

Medium (71 % 1141/) High (85% I Oil/)

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D. STRENGTHS AND CHALLENGES

Total overtime hours are within allowable limits under applicable law or agreement

The facility has comprehensive working hour and wages management processes and procedures in a written manual that support adherence to social compliance requirements and are being properly implemented

The facility provides social security, pensions, healthcare and/ or other insurance to employees as per legal requirement.

The facility does not have a valid business license/ registration/ permit to operate

Noise level at the facility is not acceptable

The air emissions do not meet the discharge limits for regulated constituents

The facility does not apply for testing of factors of occupational hazards at least once a year and the report kept for review

The facility has comprehensive processes and procedures in the area of general facility, dormitory (if any) and/ or canteen (if any) management (e.g. cleanliness, ventilation, noise, lighting, toilets) in written manual that support adherence to social compliance requirement but they are not all being properly implemented.

The facility does not conduct and/ or pay for regular occupational health examinations for employees when applicable

DISCLAIMER

Minor 51%

Moderate 57%

Major 96%

Minor 88%

Moderate 86%

Minor 75%

Minor 75%

Minor 73%

This report is for the exclusive use of the client oflutertek uamed in this report ("Client"] aud is provided pursuant to au agreement for services between Intertek and Client ("Client agreement"]. No other person may rely on the terms of this report. This report provides a summary of the findings and other applicable information found/ gathered during the audit conducted at the specified facilities ou the specified date ouly. Therefore, this report does not cover, and Intertek accepts no responsibility for, other locations that may be used in the supply chain of the relevant product or seivice. Further, as the audit process used by Intertek is a sampling exercise only, Intertek accepts no responsibility for any non-compliant issues that may be revealed relating to the operations of the identified facility at any other date. lntertek' s responsibility and liability are also limited in accordance to the terms and conditions of the Client Agreement. Intertek assumes no liability to any party, for any loss, expense or damage occasioned by the use of this information other than to the Client and in accordance with the Client Agreement and these disclaimers. In case there is any conflict between the disclaimers stated herein and the applicable terms and conditions of Intertek incorporated into the Client Agreement, then these disclaimers shall prevail.

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