Sedex Members Ethical Trade

Audit (SMETA) Best Practice

Guidance
Version 6.0 April 2017
Version 6.0 April 2017 (Replaces V. 5.0 December 2014). This
Best Practice Guidance covers both a 2-Pillar SMETA
Audit and a 4-Pillar SMETA Audit, which includes the
2 optional pillars of Environment and Business
Ethics.

This Best Practice Guidance (BPG) for

conducting SMETA audits has been
developed by the current members
of the Sedex Stakeholder Forum
(SSF). The guidance covers the
mandatory 2 pillars of Labour
Standards and Health and
Safety as well as the additional
options of Environment and
Business Ethics.
 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Contents
Chapter 1 (Sections 1-3) Introduction

1. Background 5

1.1 Sedex and SMETA 5

1.2 SMETA and the Ethical Trading Initiative (ETI) Base Code 6

1.3 SMETA 2-Pillar and 4-Pillar Audits 8

1.4 SMETA and the UN Guiding Principles 8

2. SMETA BPG Application 9

3. Supporting Documents 10

Chapter 2 (Sections 4-5) Audit Planning

4. Risk Assessment 12

4.1 Sedex Self-Assessment Questionnaire (SAQ) 13

4.2 13

4.3 Pre-Audit Information Pack 15

5. Types of Audit 16

5.1 Category of Auditor 16

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

5.3 Sequence of Audits 18

5.4 Labour Codes 19

Chapter 3 (Sections 6-7) Audit Execution

6. Overview of the Audit Process 22

6.1 Audit Request 23

6.2 Preparation for an Audit (for Auditors) 26

6.3 Selecting the Auditor/Audit Team 27

6.4 Audit Body Management System 29

6.5 Communication with the Site 31

6.6 Preparation for an Audit (Site of Employment) 38

7. Audit Execution 40

7.1 Opening Meeting 42

7.2 Tour of the Employment Site 44

7.3 Management and Worker Interviews 47

7.4 Document Review 56

7.5 Pre-closing Meeting 60

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

7.6 Closing Meeting and Summary of Findings 63

Chapter 4 (Section 8) Audit Reports And Audit Outputs

8. Audit Report and Audit Outputs 67

8.1 Audit Report Completion 68

8.2 Describing Non-Compliances, Observations and Good Examples 72

8.3 Sedex and Uploading the Audit 75

8.4 Information Management 80

8.5 Audit Records 80

Chapter 5 (Section 9) Audit Follow-Up

9. Audit Follow-up 81

9.1 Follow-up audits 82

9.2 Appeals and Disputes 84

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Chapter 1 (Sections 1-3)

Introduction
1. Background
Contains an explanation of how SMETA (Sedex

Advance system (a platform for buyers, suppliers

and auditors to store, share and report on supply
chain information), the standards used for a
SMETA audit and an overview of the audit content.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

1.1 Sedex and SMETA 1.2 SMETA and the Ethical Trading
Sedex is the name of the organisation – SMETA
Initiative (ETI) Base Code
is the name of an audit methodology. SMETA uses the Ethical Trading Initiative
Base Code and the local law as its monitoring
The Supplier Ethical Data Exchange (Sedex)
standards. SMETA can be tailored to use
with other codes based on conventions of the
that leads work with buyers and suppliers to
International Labour Organisation.
deliver improvements in responsible and ethical
business practices in global supply chains. Sedex Note: The ETI is an alliance of companies, trade
was founded in 2001 by a group of retailers to unions and voluntary organisations that work in
drive convergence in social audit standards and partnership to improve the lives of workers across
monitoring practices. Sedex aims to ease the the globe. More information can be found at
auditing burden on suppliers through the sharing www.ethicaltrade.org.
of audit reports and to drive improvements in
supply chain standards. SMETA Best Practice Guidance (BPG) describes
the key steps of planning, executing and
SMETA (Sedex Members Ethical Trade Audit) is documenting a SMETA Audit against the following
the audit methodology created by the Sedex four auditing pillars:
membership to give a central agreed audit
A SMETA 2-Pillar audit comprises:
Originally created by the Sedex Associate
Auditor Group (AAG), now renamed the Sedex Labour Standards
Stakeholder Forum (SSF) and involving multi-
Health and Safety
stakeholder consultation, it draws from practices
Additional Elements:
Social Compliance Programme (GSCP)
www.gscpnet.com. • Universal Rights covering UNGP
• Management Systems
SMETA consists of four core documents: • Entitlement to Work
• Subcontracting and Homeworking
SMETA Best Practice Guidance (this
• Environment (shortened)
document)
A SMETA 4-Pillar audit contains in addition:
SMETA Measurement Criteria
Environment (extended) – this replaces the
SMETA Audit Report
Environment (shortened) section detailed
SMETA Corrective Action Plan Report (CAPR) above

Business Ethics

The SMETA BPG (this document) has been

produced to give a consistent global auditing
procedure that Sedex members can share with

standards and protocols used.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Many types of social audits are performed such Note: Since Sedex allows sharing of audit data, any
as BSCI, WRAP, SA8000 and ICTI, and all social company uploading a SMETA audit must follow this
audits can be uploaded onto the Sedex platform. SMETA BPG exactly, especially ensuring that non-
It lies with the individual member to decide compliances uploaded on the system have been
what audit is acceptable to them; however, measured against at least the ETI Base Code and
Sedex hopes that by providing SMETA publicly, the local law. Companies may use this methodology
companies will increasingly converge on one for a variety of codes, but it must not be called a
international audit protocol. SMETA audit unless it follows the SMETA BPG and
SMETA Measurement Criteria.
SMETA 2-Pillar audit has been developed for
auditing against a Human Rights framework and SMETA BPG undergoes a regular review to ensure
the Ethical Trading Initiative (ETI) Base Code, Local
Law, plus the Additional Elements listed above. process includes feedback from stakeholders.
The latest version will be available on the Sedex
SMETA 4-Pillar audit includes the additional website.
assessments of Environment and Business Ethics.
In recognition of some members wishing to use
SMETA has been developed to provide the SMETA methodology for their own company
guidance for both 2-Pillar and 4-Pillar audits, code the SSF has developed this new version,
allowing individual supply chains to choose their in which a customer may require a SMETA audit
requirements. The guidance can be adopted and to include their own code, providing that it is in
tailored to carry out audits against a range of addition to the ETI Base Code and the local law.
other labour codes based on the conventions of
the International Labour Organisation (ILO). Note: It is imperative that the SMETA audit continues
to also be conducted against ETI base code and
local law requirements. All non-conformances
against ETI base code must be declared in a SMETA
audit report, even if the site or customer are not ETI
members. This is to enable sharing of SMETA audits
with other customers.

Details of the ETI Base Code and the items to be

investigated during a SMETA audit are found in
the ‘SMETA Measurement Criteria’ .

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

1.3 SMETA 2-Pillar and 4-Pillar 1.4 SMETA and Universal Rights
Audits covering UNGP – UN Guiding
Principles (Ruggie Framework)
An Introduction to an Environmental and
This SMETA review introduces the responsibility
Business Ethics Assessment.
for businesses to respect all human rights and to
A SMETA 2-Pillar audit comprises the 2 pillars measure the impact of their business operations
of Labour Standards and Health and Safety. within the areas and communities in which they
These are mandatory modules for any SMETA
audit. It also contains the additional elements of rights (human rights in the workplace) but this
Management Systems (including Land Rights), version also aims to address the responsibility
Universal Rights covering UNGP, Responsible of businesses to understand their broader
Recruitment Practices, Entitlement to Work, human rights impacts including the need to
Subcontracting and Homeworking, and a recognise community human rights e.g. in the
shortened Environment Assessment. form of grievance mechanisms and Freedom
of Association (the Remedy pillar). Also in this
A SMETA 4-Pillar audit includes all the version, business impacts are put into context of
above elements plus the additional pillars of the state’s duty to protect and create judiciary
Environment (extended assessment – replaces methods for business to have access to remedy
shortened assessment) and Business Ethics. (part of the Remedy pillar).
These additional pillars may not be required for
all Sedex members and it is important that sites Currently SMETA uses the ETI Base Code, the law
of employment and auditors are clear when these and under certain circumstances a customer’s
extra modules are required. For more information own code of conduct as measurement standards.
on 4-Pillar SMETA audits, see ‘5.4 4-Pillar SMETA
The UN Guiding Principles for Business and
Audits’.
Human Rights provide a global framework for
The basic 2-Pillars of a SMETA audit are governed preventing and addressing the risk of adverse
by the standards contained in the ETI Base Code. impacts on human rights linked to business
activity. The framework is set out in a
The additional pillars of Environment (extended
version) and Business Ethics in a 4-Pillar audit 3-pillar framework - “Protect, Respect and
are governed by standards developed through Remedy” - that details:
a process of member and multi-stakeholder
consultation.

rights.

Access to remedy (judicial and non-judicial)

for victims of business-related human rights
abuses.

This clause, designed through consultation

and stakeholder engagement, introduces the
responsibility of businesses to fully consider and

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

measure these direct and indirect human rights Any auditor or audit company including non-
impacts, both within the workplace (workplace Sedex members may use SMETA. It is also
rights) and beyond. applicable to all sizes and types of employment
site including manufacturing sites, agricultural
SMETA does include guidance for an optional sites and service providers. Supply chains,
perimeter survey (page 58 – Perimeter survey), however, come in all shapes and sizes and a
which can provide additional information to standard SMETA protocol may need adjustments

on local communities. Please see the next section on SMETA

Where sites are already implementing broader,

sites.
positive human rights practices, we encourage
auditors to raise these as good examples. This The purpose of SMETA is to act as a central audit
will help us to continue to develop the SMETA protocol, which is transparently understood by all
Best Practice Guidance through wider stakeholder users, enabling suppliers to share one audit with
consultation as the industry develops. many customers.

Sedex members are continuing to examine how

The reference to a ‘SMETA Audit’ shall only
and will be incorporating emerging best practice be used when all the criteria outlined in this
into subsequent reviews. document have been used during the audit
process.
For more information, visit the UN Guiding
principles website. Sedex does not certify auditors or auditing bodies
and relies on the controls and accreditations
that already exist. It is recommended that
2. SMETA BPG Application companies commissioning audits should assure

SMETA BPG assists the auditor to carry out a of the auditors and their ability to meet SMETA
SMETA Audit using a standard agreed protocol. requirements, as set out in the document ‘SMETA
Guide to Social Systems Auditor Competencies’.
SMETA BPG and Measurement Criteria are a This is available on the Sedex Advance
compilation of social audit best practices to help Knowledge Hub.
auditors achieve the consistency needed for
social audits to be widely accepted by retailers See also ‘6.3 Selecting the Auditor/Audit Team’.
and brands. It also helps organisations that are
Guidance can also be found for non-members at
commissioning audits to specify the auditing
‘GSCP reference tool for Auditing Competence’.
methodology required.

SMETA is not intended as a standalone

description of how to conduct an audit. Instead, it
sets out to establish a common set of criteria to
supplement auditors’ own systems.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

AUDIT PROCESS
3. Supporting Documents
SMETA Guidance for Auditors for Extended
There are a number of additional documents that Environment and Business Ethics Assessment:
support a SMETA audit. assessment checks for Auditors.
SMETA BPG and Measurement Criteria are used SMETA Guidance for Suppliers for Extended
in conjunction with the SMETA Audit Report form Environment and Business Ethics Assessment:
and accompanying CAPR. These are the four core guide for Supplier Sites.
documents of SMETA and they are all available on
the public section of the Sedex website. SMETA Non-Compliance Guidance:

CORE DOCUMENTS methods.

SMETA Best Practice Guidance: this document. Guidance for Dealing with Sensitive issues
Raised at Audits.
SMETA Measurement Criteria: gives details
of the items to be examined during a SMETA POST AUDIT PROCESS
audit.
Sedex Guidance on Operational Practice and
SMETA Audit Report: provides a template for Indicators of Forced Labour.

format that can be uploaded to the Sedex SMETA Corrective Action Guidance: suggested
platform. ways in which manufacturing sites may make
improvements.
SMETA Corrective Action Plan Report (CAPR):
a template for recording a summary of audit DIFFERENT TYPES OF SMETA AUDITS

actions. Supply chains come in all shapes and sizes and a

standard SMETA protocol may need adjustments
SUPPORTING DOCUMENTS FOR ALL SMETA
AUDITS

In addition, Sedex has created the two supporting the use and adjustment of this methodology.
documents for preparing for a SMETA audit:

PRE-AUDIT PROCESS
supply chain types that require tailored approaches.
SMETA Pre-Audit Information Pack: contains
It is important to remember that the standards
information to be sent to a supplier site before
governing the SMETA process will remain the
a SMETA audit.
same – the Ethical Trading Initiative Base Code,
SMETA Guide to Social Systems Auditor
Competencies: competency requirements for approaches will mainly cover sampling plans and
auditors who practice social audits. reporting procedures, with the aim of creating a
process that recognises the standard BPG may
not work for all. These Supplements should be
used in conjunction with this core Best Practice
Guidance and the Measurement Criteria.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

ADDITIONAL DOCUMENTS THAT SUPPORT

DIFFERENT AUDIT TYPES: monitoring multiple sites that operate within a
single company structure or single company
SMETA Supplement for Service Providers: to management system. Typical examples include:
assess the working conditions for employees
of service providers and contractors working at A central business controlling multiple
sites or remotely from their employer’s operation. smaller supply sites where a single central
Examples include: management system covers all production
operations and personnel including those
General and specialist cleaning companies. working remotely.

A pack house being supplied by a number of

installation and servicing of equipment. smaller producers all of which are owned by
the pack house.
Transport and personnel services.
Sedex Guidance on Operational Practice and
Indicators of Forced Labour
SMETA Supplement for Private Employment
Additional guidance for forced labour is available
Agencies: to assess the working conditions of
to identify indicators on forced labour:
workers who are supplied by private employment
agencies to work temporarily at user enterprise Note: These supplements are not intended as
sites. standalone documents to conduct an audit but
rather as a supplement to this document (the
SMETA Supplement for Multi-Site Audits: to
SMETA Best Practice Guidance) and Measurement
assess working conditions at small multi-
Criteria available from the Sedex website and audit
sites. Small suppliers that are part of a group
companies’ own systems.
of companies under a single ownership are

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Chapter 2 (Sections 4-5)

Audit Planning
4. Risk Assessment

potential ethical risks in supply chains including the Sedex

Self-Assessment Questionnaire (SAQ) and Risk Assessment
Tool.
A buying company will usually implement a Also of importance may be: level of supplier
process to identify risk in its supply chain. This commitment and/or previous audit results,
enables it to focus attention on key areas of research carried out by NGOs as well as issues
potential risk and direct its audit resources raised by the media.

needed. Within the Sedex Advance system there is an

online SAQ for sites of employment, which when
Risk assessments for suppliers and employment completed, allows A and AB members to use the
sites consider various criteria. Examples include: Sedex Risk Assessment Tool to provide insight into
geographical area, employment site function, areas of higher likelihood of risk and to support a
product/service category, type of purchase, due diligence approach to responsible sourcing.
employment patterns (migrant, casual workers
etc.), and level and nature of any subcontracting.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

4.1 Sedex Self-Assessment Completion of the SAQ before an audit will give
employment sites detailed information on the
Questionnaire (SAQ)
issues that auditors will be covering during a
SMETA audit. By completing and reviewing their
The Sedex SAQ, when completed by the site, own SAQ, an employment site will be able to self-
enables customers to use the Sedex Risk diagnose problem areas and correct issues prior
Assessment Tool. By examining the details to an audit.
recorded in the SAQ, both suppliers and
customers can identify areas that may need
addressing before the audit is carried out. information) enables a buying company,
supplier or agent to obtain information about an
To align with best practice guidance, sites of employment site, how it manages compliance
employment should complete the SAQ and make with social, environmental and governance
it available to customers before they decide standards and requirements, and how it measures
whether to commission an audit. The SAQ, which its performance against local, national and
international standards.
made available to the audit company to help plan
the audit. It is a useful tool that enables auditors to The site of employment is asked to complete
the SAQ within a given timescale and provide
supporting documentation. The buying company
The purpose-built Sedex SAQ, created in uses this information as part of its risk assessment.
consultation with Sedex members, is available The auditor uses the information to plan the audit
to members via the Sedex platform. The SAQ and to focus on high-risk areas.
consists of 4 key pillars – Labour Standards,
Health and Safety, Environment and Business
Ethics. All four pillars take into account legal
requirements, international standards and good
practice. Outlines the importance of the site completing
The Sedex system uses the information given
available to the auditor.
by the site of employment’s SAQ to feed into the
Sedex Risk Assessment Tool. An indication of risk
is created by combining inherent risk with the SAQ essential for the auditor to cost, plan and arrange
risk to support an assessment of the likelihood of the audit. It is therefore essential that the site of
an issue occurring in the supply chain. employment completes the SAQ in full and gives
access to the auditor ahead of the audit.
The intelligence behind the Risk Assessment Tool
is provided by global risk experts, Maplecroft. Customers (Sedex A or AB members) request the
For more information on the Tool and Maplecroft site of employment to complete the SAQ. When
please visit the Sedex website. doing so, they should communicate the following:
Note for sites: Failure to complete the Sedex SAQ The importance of accuracy in completing the
may result in a default to high risk. SAQ.

The timeframe for completion of the SAQ.

How to make the SAQ visible to the auditor.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Notes:
the audit process.

If the site of employment does not give access request the site to give the auditor access to their
to the SAQ, the auditor will need to obtain the completed SAQ. The Sedex SAQ contains the site

e.g. the use of a pre-audit employment site plan the audit.

completed by the employment site and returned

to the auditor. the SSF has produced the ‘SMETA Pre-Audit
Information Pack’. The auditor should send this
If the pre-audit information requested from the information, to be received by the site that will
site is not provided, the audit should not normally be audited at least 2 weeks ahead of a SMETA
take place. The auditor should make it clear to the audit. The auditor may use the Sedex format or
site that this information is necessary for the audit develop their own.
to take place and clearly establish a deadline for
submission. ‘SMETA Pre-Audit Information Pack’
contains suggestions only. The auditor should
ensure that the materials are appropriate to the
size of site.

Action! Action! Action!

Suppliers Customer Auditor

Complete the SAQ. Self- Review and use SAQ Review and use SAQ
diagnose and correct information to assess information to create a
issues in advance of the highest area of priority quote, plan the audit and
audit. assess areas of focus for
set priorities for future the audit.
collaboration with supplier.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

4.3 Pre-Audit Information Pack The ‘SMETA Pre-Audit Information Pack’ contains
suggestions only. The auditor should ensure that
Outlines the importance of the Audit Company the materials are appropriate to the size of site. At
sending necessary pre-audit information in a minimum, the auditor should communicate
advance of conducting the audit at the site. essential information relating to the audit process
including:
As the SMETA process becomes more widely
used, Sedex members see the need for a pre- - What is a social / ethical audit?
audit pack to provide suppliers/supplier sites with - The topics the covered by the audit.
essential pre-audit information, which will help - Links to the SMETA core documents
them to prepare for a SMETA audit. to allow sites to adequately prepare
including:
This pre-audit pack, developed by the SSF, o SMETA Best Practice Guidance
is a compilation of existing best practices of o SMETA Measurement Criteria
audit companies/auditors currently performing o SMETA report template
SMETA audits as well as some new additions. o SMETA CAPR
This pack has been assembled from an auditor’s o For a 4-pillar audit the additional
perspective and for an auditor’s use, anticipating guidance for Environment and
Business Ethics
has with Sedex & SMETA. - An agenda for the day.
- A list of documents to be available on the
Sedex members’ experience shows that both day.
- An overview of report distribution.
helpful in preparing supplier sites for audit. - A code of integrity and professional
Supplier sites can also improve their performance conduct of the auditor/audit company.

pre-audit pack is an essential pre-audit step as it In order for a site to adequately prepare for a
outlines the activities required of a supplier site in SMETA audit, the auditor should send the pre-
preparation for an audit. Correctly followed, this audit pack, to be received by the site to be
will facilitate the audit proceeding smoothly with audited at least 2 weeks ahead of a SMETA audit.
all relevant logistical arrangements, people and
documents in place on the day. Note:

SMETA recommends that sites implement a

process to assess themselves and recommends
using the SMETA methodology to do this on
a regular basis. Experience from membership
shows that a robust internal process to manage
compliance eases the burden of third party
auditing.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

5. Types of Audit 5.1 Category of Auditor

as agreed by the Sedex membership, as well based on their relationship with the audited site.

and sequence. More detailed information is also All social audit types can be uploaded to the
provided on the extended 4-Pillar SMETA Audit. Sedex platform, including those carried out by

assessments that may be undertaken to evaluate First Party: a company that “self-audits” their
an employment site. The use of these will vary own employment site using their own audit
depending on factors such as the outcome of risk resource.
assessments, a buying company’s relationship
Second Party: an audit or assessment
with its suppliers, audit cost and the history of a
undertaken by a body with a trading
site’s performance. A buying company may deploy
relationship with the site such as a retailer,
brand, vendor or agent.
supply chain.
Third Party: an audit or assessment
SMETA only covers formal social audits.
undertaken by an independent party e.g. an
However, buying companies may engage with
independent commercial audit company,
employment sites in a variety of other ways to
NGO or trade union. Where an independent
promote improvement, which may include site
commercial audit company is used, the
visits, follow-up assessments, improvement
auditor(s) should have no connection with the
programmes, workshops, multi-stakeholder
projects etc.
of interest. Audits may also be undertaken
Sites of employment register on Sedex thus collectively by a group of these stakeholders
encouraging them to take ownership of their (multi- stakeholder).
social compliance performance. The SSF has
Note: A multi-stakeholder audit is an audit carried
created a number of documents to assist this
out by a group of stakeholders including NGO’s
process of ownership including the
and/or unions where the NGO and/or union have
Corrective Action Guidance’ available for
been involved in a shared decision-making process
members on the member resources of Sedex.
on inspection methods. SMETA recommends the
use of multi-stakeholder audits as more sustained
nature/type of SMETA audit. The requestor of change and greater impact of corrective actions
each audit will decide which type(s) meet their have been seen as a result of multi-stakeholder
needs. audits.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

The necessary records and the concerned

personnel should be available at the
Depending on the outcome of risk assessments employment site on the day of the audit.
and/or audit planning, prior notice of the audit
may or may not be given.
5.2.2 Semi-Announced Audits
This results in three possible audit types: Semi-announced audits reduce the risks to the
commercial relationship and increase the ability
1. Announced: audit date is agreed with, or
of the buying company to remediate. Buying
disclosed to, the audited site.
companies should clearly communicate their
2. Semi-announced: audit date will fall policy on semi-announced audits to suppliers and
employment sites. The policy should state that:

3. Unannounced: no prior notice is given. The buying company or audit body will specify
a window during which an audit may take
The use or combination of these audit types place. Audit windows may range between 2
will depend upon the particular circumstances weeks and 2 months. (The SSF recommends
that a 3-week window gives optimum results.)
given on their selection, however below are some
examples of when they are used. All employment sites are required to provide
up-to-date and accurate pre-audit and self-
assessment information at the beginning of
5.2.1 Announced Audits the window.
The right to perform an announced audit should Auditors presenting the correct credentials
be a normal part of the commercial relationship. during the audit window should be allowed
However there is a risk that employment sites may full access to the employment site.
make special preparations for the audit, therefore
best practice is to use a mix of announced, semi- The necessary records should be kept at the
announced and unannounced audits to mitigate
this risk. Buying companies should clearly
communicate their policy on announced audits
to suppliers and employment sites. The policy 5.2.3 Unannounced Audits
should state that: Unannounced audits allow auditors to assess the
conditions at an employment site in their normal
The buying company will agree an audit date
state since the employment site has not had the
with the employment site in advance.
opportunity to make any special preparations.
The employment site is required to provide However there is a risk that the employment site
up-to-date and accurate pre-audit and self- will perceive unannounced auditing as deceitful,
assessment information in advance of the that the auditor will not be able to gain access
audit. to the employment site and that the necessary
information and personnel may not be available
Auditors presenting the correct credentials on on the day of the visit to complete the audit.
the date of the audit should be allowed full
access to the employment site.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

To minimise these risks, the buying company monitor supplier sites on an on-going basis.
should clearly communicate its policy The intervals between periodic audits may
on unannounced audits to suppliers and vary depending on the individual member.
employment sites. The policy should state that:
Follow-up Audit: Depending on the outcome
Audits may occur at any time on an of the initial audit, a follow-up audit may be
unannounced basis. required.

All employment sites are required to Follow-up audits are normally used to check
provide both pre-audit and self-assessment progress against issues found in the initial
information on a regular basis and this audit and so they may be of shorter duration
information must be accurate. than an initial or periodic audit. Follow-up
audits will also demonstrate the process of
Auditors presenting the correct credentials continuous improvement. It is essential that all
should be allowed full access to the appropriate site personnel are fully briefed on
employment site.
audit e.g. by re-sending the previous CAPR as
The necessary records for an audit should
part of the pre-audit information pack. There
always be kept at the employment site or
are three types of follow-up audits:
readily available.

Note: Whilst unannounced audits are extremely

the non-compliances found at a previous
audit was so broad that a full audit is
conditions at the employment site and may help
required to verify corrective action. In this
uncover high-risk issues, their use can undermine
case the methods and scope resemble an
the relationships along the supply chain, reducing
initial audit but take into account previous
the ability of the buying company to remediate.
The experience of many companies indicates that
unannounced audits should be reserved for due
visits a site but only checks progress
e.g. critical issues suspected, lack of commitment/ against issues found during a previous
involvement of the suppliers, suspicion of fraud. audit. This should then be recorded in
Sedex as a partial follow-up audit.

5.3 Sequence of Audits

certain corrective actions for which a site
For clarity of the SMETA audit process, the Sedex visit is not required and can instead be

sequence of audits. evidence or documents provided via

e-mail.
A site of employment may be assessed via a
combination of the following methods: Note: Where an auditor re-visits a site to check all
items of the code then this should be recorded as a
full follow- up audit and noted on the audit report.
employment is audited.

Periodic Audit: Usually a full audit used to

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

5.4 4-Pillar SMETA Audits For the additional 2-Pillars of Environment

(extended assessment) and Business Ethics, see
At the request of members, SMETA has now been section 10B4 and 10C in ‘SMETA Measurement
extended to include an extended Environment criteria’ for details of applicable standards.
and Business Ethics Assessment.
Note: In view of the time allocation the additional
2-Pillars cannot be considered as substitute for a full
Environment and Business Ethics audit, but they may
5.4.1 Background
assist supply chains in deciding whether full audits
are required.
Responsibility, Sedex members have created a
4-Pillar SMETA audit, including the extra modules
of Environment (extended assessment) and 5.4.2 Usage
Business Ethics. This BPG, the Measurement
When an auditor is carrying out an assessment
Criteria and the associated reports have been
of environmental performance, they will assess
designed so that users can include one or both of
whether the site of employment is meeting
these extra modules. Together they are intended
applicable local laws.
to take a total of 0.5 auditor days when added to a
2-Pillar SMETA procedure. The Business Ethics assessment process
also checks legal compliance in addition to
For a 2-Pillar audit covering Labour Standards and
international and customer requirements/
Health and Safety plus additional elements, see
standards.
1–10B2 in ‘SMETA Measurement criteria’ which
gives details on applicable standards.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

It is essential that Sedex members are clear 5.4.3 Application

when a 4-Pillar audit is required as the extra time
As the time allocated is 0.5 auditor days for both
taken is likely to incur additional time, resource
modules together it is likely that the number of
and cost.
interviews will be restricted and the document
The assessment process involved in the review is likely to be an “assisted self-assessment”
Environment (extended version) and Business rather than a full investigation. However, members

completed SAQ and should give the reader the are not already conducting full Environmental
option to: and/or Business Ethics audits.

Decide that no further action is needed

following the assessment. 5.4.4 Execution of Environment and
Business Ethics Assessments
Decide that a full Environment and/or
Business Ethics audit is required.
As each extra pillar is designed to take no more
Identify risks and decide on appropriate than 0.25 auditor days it is important that the
corrective action. auditor uses the SMETA guidance provided
to cover all required points. Some important
Note: For Environment and Business Ethics documents are detailed below.
assessments, non-compliances will only be raised
where a site of employment is not meeting the 5.4.4.1 Document Review: The auditor should
local/national/international law and/or customer review the completed Sedex SAQ prior to
the audit and should use the assessment
observations. process to check that the site’s policies
and procedures agree with the SAQ. Any
discrepancies should be noted on the
audit report.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

5.4.4.2 Permits and Licenses: These should be 5.4.4.5 Worker Interview: The auditor seeks
checked against legal as well as customer to verify practices in areas of legal
requirements and details should be compliance, such as contents of waste-
noted on the audit report. This should water discharge for the Environment
also include a review of any relevant assessment. Discussion with employees
prosecutions or legal actions against responsible for checking these contents
the site for environmental issues and can be evidence of procedures correctly
business ethics as well as noting any implemented. Business Ethics interviews
should be with departments where
Business Ethics policies are most
appropriate e.g. sales, purchasing, service
5.4.4.3 Natural Resources Usage: Where possible control and logistics departments.
usage and disposal of natural resources
5.4.4.6 As a minimum the auditor should interview
such as volumes of water used/recycled/ at least one worker from each of the areas
discharged. For details see 10B4 in ‘SMETA of Environment and Business Ethics.
Measurement Criteria’ and the SMETA
Audit Report. Note: Where policies do not exist, an auditor should
use the assessment process as an opportunity
5.4.4.4 Management Interview: The auditor to raise awareness, especially on Business Ethics
checks documentary evidence and issues. To assist this, process the SSF has produced
actual practices by interviewing relevant a suggested framework for content – See 10C of
personnel. As a minimum, this should ‘SMETA Measurement Criteria’.

the site as the person(s) responsible Additional information for members can be
for Environmental and Business Ethics found in the knowledge hub section, ‘SMETA
performance. Guidance for Auditors for Extended Environment
and Business Ethics Assessment’ and
‘SMETA Guidance for Suppliers for Extended
Environment and Business Ethics Assessment’.

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Chapter 3 (Sections 6-7)

Audit Execution
6. Overview Of The Audit Process

To ensure that members can share a SMETA audit with

follows all the steps detailed in the SMETA BPG and

Measurement Criteria. This overview details the key pre-
audit steps from audit request to audit preparation. The site
must receive all relevant pre-audit information at least 2
weeks ahead of the audit.
A social audit is usually carried out within the
context of a wider evaluation and remediation
programme. This includes a preliminary risk
assessment (see section 4 ‘Risk Assessment’)
to gauge the need for the audit, and progresses
through the audit itself to a programme of
improvement and monitoring.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

The following stages are covered by SMETA BPG: 6.1 Audit Request
1. Audit Request For the audit process to commence an audit
must be requested. Any company/organisation/
2. Preparation site requesting an audit is termed an “audit
requestor”. An audit may be commissioned and
3. Audit Execution paid for by a buying company, by a supplier, by
the site of employment or by any other party with
4. Audit Outputs
a legitimate interest in the site’s performance
5. Audit Follow-up in relation to responsible business issues. It is
essential that all the stages of a SMETA audit are
clearly understood and that costs of each stage
Note: Sites of employment should be involved as are made transparent by the audit company,
much as possible in the audit process. The focus ahead of the audit. See ‘6.1.2 Quote Generation
of the audit should be on how the site manages and Audit Information’ and section 8 ‘Audit
all items covered by the code (see ‘SMETA Report and Outputs’.
Measurement Criteria’ for more details).
Audit companies manage and supply professional
For example, this can be done by: auditing services to a wide variety of customers.

•
the preparation required of a site for in clients’ audit requests/requirements. When
audit. audits are commissioned, the audit company can
• Sharing other resources found on the
Sedex Advance Knowledge Hub (the customer requirements into one SMETA audit
member resources section of Sedex), e.g. if a customer requires the audit company
which includes details of common
auditors. For this reason, it is important for sites to
actions etc. declare ALL their customers to the audit company
when requesting a quote in order to minimise the
need for multiple audits.

The audit requestor should be clear whether

the audit is a 2-Pillar SMETA comprising Labour
Standards and Health and Safety or an audit that
contains the extra pillars of Environment and/or
Business Ethics.

Audits are usually paid for by the site, unless

other contractual arrangements are in place.
It is good practice for the auditor to obtain full
payment in advance of the audit, to maintain full
independence of the audit outcome.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

If the audit is to proceed, the audit body sends the

and circulation of the SMETA audit report. site of employment any appropriate information
Generally, the audit body will send the audit to assist them in preparing for an audit. This must
report to the organisation paying for the audit. The include a copy of the auditor’s/audit company’s
circulation of the audit report should normally be Business Ethics Policy, including their anti-
pre-agreed at the audit request stage between corruption policy. The site should receive this
the ultimate customer and all stages of the supply information a minimum of 2 weeks before the
chain including the site of employment (normally audit is to be carried out.
the audit payer). It is usual for the ultimate
customer to request a copy of the audit report. Employment sites should also be directed to
the additional guidance available on the Sedex
Depending on the brand/retailer’s programme, website. This will assist them in preparing for
audit prices quoted may or may not include the audit – please see the SMETA pre-audit
uploading the audit to the Sedex platform, and information pack.
subsequently recording and verifying corrective
actions. It is essential that the costing structure Audits should not take place during low season
and related services is clearly understood and but ideally during a period of high employment
agreed between all parties at the beginning of the numbers and when the employment site is in full
process. operation (such as peak production or harvest).

Whichever party requests the audit, the auditor Note:

should be made aware of who the audit report
To provide a consistent approach to pre-audit
owner and the audit report reviewers are, and
information the SSF has produced a ‘SMETA
ensure they conduct the audit in the best interests
Pre-Audit Information Pack’, available on the
of all relevant stakeholders.
Sedex website.
Auditors must be clear who should receive audit

suppliers only use auditors from an approved list.

the Sedex platform. In the case that the auditor is
A supplier site should check with its customers
required to send a copy to parties other than the
before engaging an auditor/audit company.

obtain approval from the audit payer.

In some instances, certain customers may require

completion of a supplementary audit report. If
customers use this supplementary process, it is
recommended that the audit company agrees
at quotation stage their ability to share such
supplementary audit information with the end
customer directly.

Note: Sedex recommends that the audit company

uploads the audit as this provides greater
independence. Note that within the Sedex platform,
the site of employment approves the publication of

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Example of process: 6.1.2 Quote Generation and Audit

Information
6.1.1 Audit Request Initiation
6.1.2.1 The audit body supplies the audit
6.1.1.1 The audit requestor contacts the audit
requestor with a quotation and contractual
body to request an audit.
details, including:
6.1.1.2 Since one of the missions of Sedex is to
Audit fees:
encourage audit sharing, the audit body
should ask the site if they already have a
previous and up-to-date audit uploaded to audit report to the Sedex platform, if
the Sedex platform and, if yes, encourage applicable.
them to ask their client if they will accept
that audit or whether a new audit is
required.

6.1.1.3 Any relevant expenses (including

the employment site to plan and execute translator fees).
the audit. For Sedex members, the Site
Proposed date of audit if announced
used to obtain this information (if the site or an agreed window in the case of a
gives access to the auditor). Where the site semi- announced audit.
does not give access to the SAQ the auditor
Audit length.
should obtain the information in other ways
Audit report receivers.
template supplied by the auditor. The
minimum information needed is: Third-party audit report release
approval.
Site location and contact details.
A copy of the audit company’s Business
Size and composition of workforce, Ethics policy.
including languages spoken.
Full information on any customer
Location and availability of
documentation covering audit topics. auditors, Sedex upload requirements
etc.).
Full list of clients supplied by the site (to
establish whether other requirements
apply e.g. semi- announced audits).
This allows audit companies to ensure
all client requirements are included
in the scope (e.g. 2/4-Pillar audit) and
promotes audit sharing.

Any requests for when the audit should

the management will not be available.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Action! Action! Action!

Supplier Auditor Customer

Declare all customers to Ensure audit details and Ensure all additional
audit company customer requirements requirements are clearly
are clearly communicated communicated to audit
Understand report and all additional costs are companies and suppliers
receivership and anti- transparent
corruption policy Encourage suppliers to
Ensure an initial audit quote share any existing audits in
Communicate any existing is generated only where no place
/ historical audits audit has taken place

Research any previous

audits and CAPR’s

6.2 Preparation for an Audit member of the audit team should have good,
personal knowledge of the local prevailing
(for Auditors)
issues for workers in the area. Meetings with local
unions and NGO’s in the region can give useful
It is essential that all parties are fully briefed on information on prevailing labour conditions and
the scope of the SMETA audit and the information the main issues for local workers.
which must be available at the audit. The auditor/
audit company is responsible for ensuring all Caution: a site’s details should not be discussed
requirements are clear to the site. between auditors and any local groups (unless
expressly directed by the audit requestor), as this is
Note: See also ‘6.6 Preparation for an Audit (site
of employment)’ which gives details of the actions
required of the site prior to the audit visit. Where possible, the auditor should familiarise
themselves with any previous audit reports and
Once the audit has been agreed certain CAPR’s. In addition, the auditor should be aware
preparations are required of the auditor. These of the current issues in the purchaser member’s
include but should not be limited to: markets.

The auditing organisation or auditor should

6.2.1 Background and Context Review also regularly gather information on broader
The auditor must be aware of the prevailing
workers and the local community from a broad
employment site being audited. This should range of sources. This should include relevant
ideally include contact with local civil society legislation covering employment, health and
organisations that are knowledgeable about the safety, employment agencies and data protection.
It should also include an understanding of the

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

living wage or living costs in the region. More 6.3 Selecting the Auditor/
information on the living wage is available from
Audit Team
the following organisations:

Ethical Trading Initiative

ISEAL/Anker Benchmarks auditor is the decision of individual members;

Sedex does not certify or accredit auditors nor
Asia Floor Wage
prescribe what type of auditor can undertake an
Figures provided by Unions audit.

Living Wage Foundation UK Some Sedex purchaser members (A and AB

members) require that their suppliers only use
Fair Wear Wage Ladder auditors from an approved list. A supplier site is
recommended to check with its customers before
Fairtrade Foundation engaging an auditor/audit company.

Auditors may be self-employed or be employed

conditions and legislation should be reviewed at by a commercial organisation, NGO, trade union or
least annually. industry body.

To assist members in their selection of auditors,

the SSF has produced a ‘SMETA Guide to Social
Systems Auditor Competencies’, which is available
on the members section Sedex knowledge hub.
Also see ‘GSCP Reference Tools for Auditing
Competence’ which is available publicly.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Auditors and auditing bodies should be chosen The team should meet the following criteria:
based on:

Audit training and skills

Includes at least one auditor who meets the
Audit experience criteria of the ‘SMETA Guide to Social Systems
Auditor Competencies’.
Local and industry knowledge
Possesses or has access to knowledge of
Language skills local working conditions i.e. by using an
experienced auditor or through the use of
Gender and ethnic/national background
guidance notes.

Can communicate in the main languages

Reputation
spoken by both management and workers
Integrity at the employment site. When this is not
possible, translators should be used.
Commitment to improving social compliance.
Where there is a majority language among
workers at the site (50% or more), the worker
reliability of audit information. interviewer must be a native speaker of that
language. Other minority languages spoken
Any approved lists of auditor/audit companies can then be covered using a translator.
from relevant customers (if applicable).
At least one member has knowledge/
The audit body ensures that the auditor assigned experience of the applicable industry.
to an audit is aware of the background and
context, and that they meet the basic level
of competencies outlined for members in the audit body’s quality system, including
the ‘SMETA Guide to Social Systems Auditor specialists used.
Competencies’, which can be found on the Sedex
advance knowledge hub. The worker gender balance and cultural
norms will be taken into account when
Additional information on auditor competencies is selecting the audit team. If this is not possible
publicly available at GSCP; ‘GSCP Reference Tools it should be noted on the SMETA declaration
for Auditing Competence’. at the beginning of the audit report. This is
especially important when only one auditor
The most appropriate auditor, in terms of skills, is carrying out both the auditor and worker
experience, gender, ethnicity, language ability interview roles. If there is only one auditor
etc. should be carefully considered at the audit involved in interviews it may be important
planning stage against the information provided in (depending on local cultural norms) that they
the SAQ and other sources. are not alone when interviewing an individual
of the opposite gender.
For third party, independent auditors, there must
be no connection between the auditor(s) and the If a translator or other external expert is to be
used, the team leader must ensure that they

For larger audits, an audit team may be needed.

interest arises.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

6.4 Audit Body Management System 6.4.2 Quality Control and Global
Consistency
It is essential that an auditor/audit body has a
system in place to assure the quality of their
output – the audit and documentation produced
practices, conducting a social audit is especially
to record the audit.
challenging. In addition, audit results are shared
with customers around the world. A SMETA
against a recognised quality management system
such as ISO9001:2000 and should ideally be and practices at a site level in a consistent way.
accredited to the requirements of ISO/IEC Guide Therefore, there is a need for robust systems to
62, 65 or ISO17020, ISO 17021, ISO 17065. make the complex process of a social audit as
clear and consistent as possible for all interested
parties. The following processes should be in
6.4.1 Auditor Monitoring and place to help minimize inconsistency and uphold
Evaluation a certain quality level for a SMETA audit:

As part of their Continuous Professional Production and implementation of Standard

Development, all auditors are subject to a Operating Procedures (SOPs) for all functions
review and appraisal of their performance. This related to delivery of the social audit service.
is achieved by combining a number of activities,
in part described in the ‘SMETA Guide to Social Regular training of personnel on those SOPs.
Systems Auditor Competencies’ (available in
A Code of Conduct that provides clear
the Sedex advance knowledge hub). Activities
guidelines, especially for bribery and
include:
corruption, ensuring impartiality, handling
sensitive issues (Forced Labour).

Attend a Social Audit full refresher course Ensuring personnel are suitably trained for
every two years. their job role and responsibilities (See above).

Regular review of sample documentation A robust system of mandatory shadow audits.

submitted by the auditor to their company.
A required level of experience is achieved
Annual appraisals. before leading an audit.

Annual observed audit (2 observed audits Implementation and maintenance of the audit
where possible) à Shadow audits. body’s management system.

Series of Key Performance Indicators to Implementing and maintaining an internal

measure an auditor’s performance e.g. audit program/quality management system.
Number of times an audit is sent back to the
Production of Key Performance Indicators,
auditor for further information.
objectives and targets to ensure continual
improvement in service delivery e.g. agreed
uploading times are met, report delivery times,
number of reviews required until publication etc.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

SMETA audit reports go through a thorough Assessment of quality of audit upload to

quality check before being issued to clients the Sedex system.
– ensuring that clients do not become the
quality controllers. Feedback loop systems for communication
(internally and externally).

processes to ensure global consistency of Communication to network of clients’

service delivery i.e. a complaints management requirements and SOPs

Maintenance of technical information and

and adequate and functioning escalation
knowledge management.
procedures. These processes should include:

Central analysis of clients’ social/ethical

required corrective and preventative
audit reports to assess compliance with
action.
requirements
On-going review of business ethics policy,
(central analysis may be based on a
sampling approach).
of an appropriate external ethics body.

Implement systems: Measure systems: Improve systems:

- Robust auditor - Auditor performance - Review performance

development (include measurement with KPIs and development plans
auditor experience) including training etc.
- Checking the checker,
- Implement robust quality including measuring - Move to a model that
management system performance of audit actively invites feedback.
reviewers
- Implement a complaints
procedure - Measuring response times
and number of escalations

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

6.5 Communication with the Site Key people to be available on the day of the
audit.
It is important that the site takes an active part
Request the presence of union and/or worker
in the audit process. It is the responsibility of the
representatives at all stages of the audit
auditor/audit company to make sure that the site
including the opening meeting.
has all relevant pre-audit information at least 2
weeks before the audit takes place. Arrangements for employee interviews.

When an audit request is made, the auditor should Arrangements to take photos.

are included in the SAQ) from the employment site,

either directly or via the Sedex platform.
Code of Business Ethics of the auditor/audit
Where possible, the auditor should also review company.
copies of recent audit reports, including all
corrective actions and outstanding non- Audit agenda and the process for raising
compliances. This information allows auditors issues.
to plan the audit, considering important aspects
Audit report circulation and arrangements for
such as working hours, shift patterns, any recent
uploading to the Sedex platform, including
expansions of the site or premises, the use
of agency labour and the possible need for
interpreters. Communication materials to enable the
employment site to communicate the labour
Where the audit is to be a follow-up audit, the
code to its employees.
auditor/audit company must ensure that the
site has received a copy of the CAPR from the For a follow-up audit: a copy of any previous
previous audit and that they are aware that the CAPR in the possession of the audit company.
follow-up audit will be looking for evidence to
verify these corrective actions. An established Note: The SSF has created a ‘SMETA Pre-Audit
good practice assurance is to send a copy with Information Pack’ which can be used in whole
the pre-audit communication. See ‘SMETA Pre- or in part, to inform the site to be audited about
Audit Information Pack’. the SMETA audit process and to assist them in
preparing for an audit. This should normally be sent
Once an audit is booked for a site, the auditor by the auditor to the site ahead of the audit. This
should forward at least the following information information should be received a minimum of at
to the main contact at the employment site: least 2 weeks before the audit.

The Standard or Code that the site will be

audited against.

The agreed scope of the audit in terms of

companies/sites/buildings.

Documentation that needs to be available

during the audit (see ‘SMETA Pre-Audit
Information Pack’).

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

6.5.1 Information for Workers 6.5.2 Planning the Audit

Clear information about the audit should be Once the auditor has received all required pre-
communicated to workers by the employment audit information, they should carefully plan the
site, explaining the purpose of the visit and the audit. For larger sites this may include selecting a
process. Such information is usually provided suitable team and appointing a lead auditor. The
by the audit body for the employment site to audit plan should take account of the risks already
distribute ahead of the audit, although it may also
be provided by a buying company or other audit
requestor. Particular care should be taken to ensure that
worker interviews can be carried out using the
The information should be available in the protocol outlined in ‘7.3 Management and Worker
principal languages spoken by workers and Interview’, which may include the need for one or
should include: more translators.

Purpose and scope of the audit. Note: Where there is a majority language at the
site of 50% plus of workers, the worker interviewer
Introduction to auditors and their role must be a native speaker of this language. Minority
(emphasising that they are independent and languages can then be covered using translators.
external).

The audit process including notice of 6.5.3 Audit Length, Sample Size and
Timetable
Below is an “auditor day” table setting out the
number of auditor days, individual and group
Contact details for the auditor/audit company
interviews as well as a sample size for review of
and for any whistle-blowing facility supported
by the audit requestor.
The table excludes audit preparation, travel,
Note: For an example of the type of information
Sedex “audit report uploading time” and audit
which should be given to workers see ‘SMETA Pre-
report writing, but includes production of a CAP
Audit Information Pack’.
(Corrective Action Plan) on site.

For best practice ethical trade audits, worker

interviews must include a representative sample
of people and departments within the production
site including agency, contract and migrant
workers.

These suggested auditor days are only guidelines.

Auditors use their discretion and consider industry,
location and individual facility knowledge when

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

6.5.3.1 Table of Auditor Days and Sample Size for

Full Initial and Full Re-Audit

Auditor No of Individual Group Total Worker

days workers interviews interviews employees time
excluding interviewed and wage spent on
management records interviews
checked
per month*

1 1-100 6 or total 1 group of 4 10 10 2.5 hrs

workers
if <5

2 101-500 6 4 groups of 5 26 26 6 hrs

3 501-1000 12 6 groups of 5 42 42 8.5 hrs

4 1001-2000 20 8 groups of 4 52 52 12.5 hrs

4 2000+ 22 8 groups of 5 62 62 14 hrs

line, at least three months’ worth of records for each

worker should be reviewed, including peak, current
(or most recent) and random/low season.

If a site has more than 2000 workers, the

number of interviews is determined on
a case by case basis depending on the
circumstances of the facility. The suggested
62 is a minimum and this should increase as
worker numbers increase. What number of
interviews to perform is at the discretion of the
auditor and should be decided in agreement
with the audit requestor.

For sites with non-employee workers, Sedex

members recommend using the following
breakdown of non-employee workers (this
refers to any worker on site who is not directly
employed by the site):

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Non-employee worker number Non-employee worker interview sample

1 1

2 2

3-7 3

8-48 4

49-54 5

55-64 6

Increases of 10 workers Increase by 1 additional non-employee worker

245+ Maximum 25

Where a supply chain wishes to “top-up” an

For sites with under 30 workers, please see existing 2-Pillar SMETA audit by performing
SMETA supplement for Multi-sites for sample only Environment and Business Ethics
size / plan. Assessments, this should be discussed
Note: This only applies to situations with a between the audit requestor and auditor. Since
central company and multiple sites it may be impractical to arrange 0.5 auditor
days, a solution may be to “top-up” during a
For small producers, where appropriate,
follow-up audit.
consideration should be given to the size,
spread and the number of growing locations It is recommended that single site audits
to ascertain auditor days required should be planned to take place continuously
with no breaks (not even weekends or public
Higher numbers of auditor days may require
holidays) in between.
the use of more than one auditor. Two or
more auditors in an audit team will allow for The workers that participate in the individual
a balance of skills, or improve the gender interviews should always be included in the
balance. However, when deciding the size
of the team, consideration must be given
to the size of supplier site and the potential randomly sampled from the rest of the workforce,
disruption caused by a large audit team. ensuring that all types of workers are sampled
(e.g. agency workers, temporary workers,
For a 4-Pillar SMETA Audit the guidance
permanent workers, migrant workers, and any
suggests adding 0.5 auditor days for the
vulnerable workers such as young workers,
additional procedures of the Extended
pregnant workers etc.) taking account of any
Environment and Business Ethics Assessments
underlying issues e.g. shift, pay rates, job roles.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

6.5.3.2 Table of Auditor Days and Sample Size for A partial follow-up audit (see
a Partial Follow-up Audit Process Audits’
need less time depending on the nature of the
A follow-up audit is required when corrective

through “desktop review” only. Examples of such

equals 1 auditor on site for 1 day and 2 can be 1
actions where a minimum of 2 months’ records is auditor for 2 days or 2 auditors for one day.
required to verify corrective actions.
The tables in 6.5.3.1 and 6.5.3.2 are guidance only
Below is guidance on the time and sampling plan and members should decide, with their auditors,
for a partial follow-up audit: the desired time and sample size depending on
the nature of the information required. SMETA Best
Auditor No. of
Days workers requirements. Auditors should use their experience
and judgement to increase the time and sample size
1 1-100 During the follow-up as necessary.
audit, a sample of
On the following pages are some typical Audit
1 101-500 interviews and record
Timetables, which show how this might work in
reviews will take
1 501-1000 practice:
place. The sample
size of these reviews
2 1001- will be determined
2000 by the nature and
corrective actions
TBC 2000+
being verified.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

6.5.3.3 Example Programme for a 1-day Ethical 6.5.3.4 Example Programme for a 2-day Ethical
Trade Audit Trade Audit - Two Auditors

One auditor over one day – example 50 workers: Two auditors over one day – example 500 workers:

9:00 Opening meeting (management 9:00 Opening meeting (management

team including Health and Safety, team including Health and Safety,
Environmental, Union and HR Environmental, Union and HR
representatives). representatives).
9:30 Site Tour (Health and Safety 9:30 Site tour (Health and Safety rep.
rep. and Environmental rep. and Environmental rep. to b§e
to be available). Health and available). Health and Safety,
Safety including selection of six including selection of employees
employees for interviews. for interviews. Both auditors.
10:30 Employee interviews (six in total, 10:35

representative interview one union representative interview

12:30 HR documentation (handbooks/ of thirty minutes. Both auditors to
conduct interviews according to
records) including paperwork (when skill set.
authorised) of those individuals 12:00 Both auditors. HR documentation
interviewed.
13:00 Lunch. payroll/time records) including
paperwork (when authorised) of
13:30 Further review of payroll/time/
those individuals interviewed. Both
auditors, six records each, 12 in total.
15:15 Health and Safety documentation
12:45 Lunch.
and group interview (one group of
four people). 13:15 Group employee interviews (must
include worker reps/union reps)
16:00 Auditors prepare CAPR for closing
and remaining individual interview
meeting.
split between auditors as per skill
16:30 Closing meeting with management
set.
15:30 Health and Safety documentation,
and issues with management.
more HR records as necessary and
17:00 Finish.
further tour/interviews if required.
One auditor for documentation, one
for interviews, depending on skill set.
16:30 Auditors to prepare CAPR for
closing meeting. Both auditors.
17:00 Closing meeting with management.
Both auditors and management:

issues with management.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

6.5.3.5. Example Programme for a 2-day Ethical Trade Audit - 1 Auditor

One auditor over two days – example 150 workers:

Day 1: Day 2:
9:00 Opening meeting (management 09:00 Further HR documentation
team including Health and Safety,
Environmental, Union and HR payroll/time records) including
representatives). paperwork (when authorised) of
9:30 Site tour (Health and Safety rep. and those individuals interviewed.
Environmental rep. to be available). 11:00 Further review of payroll/time/
Health & Safety, including selection
13:00 Review Health and Safety
10:30 Individual employee interviews documentation and further tour/
interviews if required.
including one union representative 15:00 Auditor to prepare CAPR for closing
interview of thirty minutes. meeting.
12:00 Reviewing of HR documentation 16:00 Closing meeting with management:

payroll/time records) including issues with management.

paperwork (when authorised) of 17:00 Finish.
those individuals interviewed
13:00 Lunch.
13.30 Group employee interviews

remaining individual interviews (two

include worker reps/union reps.

15:30 Health and Safety documentation,
HR documentation including those
interviewed and further tour/
interviews if required.
16:30
issues with management, with
presentation of plan for the next
day.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

6.6 Preparation for an Audit 6.6.2 Site Preparation

(Site of Employment) A quiet room free from interruptions and large
Once the site receives the relevant information enough to accommodate both group and
from the auditor (see ‘6.5 Communication with individual interviews should be reserved for
the Site’), they should plan their own input to the the auditors use throughout the audit. (This
audit. This should include, but not be limited to: should be a place where workers will feel
comfortable, near a canteen or a workers’ area
is preferred).
6.6.1 Communications – Internal
Any questions or concerns the site may have
All site management should be briefed prior about the audit should be referred to the
to the audit to guarantee they understand the
scope of the audit and what is required from
each department.
6.6.3. Required Document List
All site management should be instructed
on the importance of having the correct key To assist with these preparations, the auditor will
personnel and documentation available on the provide a list of typical documents that should be
day of the audit (see above) and understand made available to the audit body on the day of the
the importance of releasing personnel for audit. The site should prepare these in advance of
interviews on time. the audit:

The workforce should be informed about the

audit including the code to which the audit is
Applicable laws and regulations
conducted.
Labour contracts/written employment
Personnel should be given Worker Education
agreements

Code requires that all employees are fully Employee handbook (terms and conditions of
aware of the code. employment)

Union or other worker representatives should Collective Bargaining Agreements (CBA)

be briefed about the audit to ensure their
availability and understanding. A list of all the chemicals and solvents used on
the site
Any Labour Providers (agencies) that the site
uses should be informed about the audit. The Training records
site should make sure that they understand
the importance of having the correct key
personnel and documentation available on the operations, etc.
day.
Government Inspection reports e.g. sanitation,
There should be a contact within the site for
the workforce if they have any questions or compliance, etc.
worries about the audit e.g. HR Manager or
Machinery inspection/service logs
worker representatives.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Accident and injury log 6.6.4 Pre Audit Assessment (optional)

Emergency action procedures Sedex members have reported that the risk of
a high number of non-compliances at a SMETA
Evacuation plan audit can be greatly reduced by a pre-assessment
of a site’s procedures and practices in advance of
Time records for the past 12 months a SMETA audit.
Payroll records for past 12 months Members have used a number of approaches to
conduct this pre-audit assessment, including but
Piece rate records for the past 12 months (if
not limited to:
applicable)
Customer review of a site’s SAQ in
Insurance, tax and other required receipts
collaboration with the site.
Production records
A 2nd party audit conducted by a purchaser in
Minutes of joint committees on OHS e.g. the supply chain e.g. an agent, intermediary or
disciplinary matters
any other audit that would highlight issues.
Previous ethical trade audit reports/corrective
action logs A 1st party audit conducted by the site itself,
using the SMETA guidance documents and
reports to highlight and correct any problem
18000, ISO 9000, Chain of Custody etc. areas in advance of the audit .

Facility polices: Note: Although a 1st and 2nd party audit may lack
objectivity, members report that a thorough pre-
audit assessment results in fewer corrective actions
required and reduces the need for a follow-up audit.

contractors

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

on what is to be examined at audit, based on

7. Audit Execution the ETI Base Code and local law, as well as
Detailed information on the audit processes to be additional criteria created by members and multi-
carried out by the auditor during the audit. See stakeholder consultation.
also ‘SMETA Measurement Criteria’ and ‘6.5.3.1
The ‘SMETA Audit Report’ has been created to
Audit Length, Sample size and Time table’.
allow an auditor to record how a site manages all
The aim of the on-site audit is to evaluate the areas of the relevant measurement standards.
performance of an employment site against
a labour code or standard, local law and/or Examined’ appears for each code item within
additional requirements. This should include:
the auditor should include a clear description
Management interview to ascertain company of what the site does to manage each area of
practice.
Labour Shall Not be Used’, an auditor must
A tour of the premises. record how age is checked both at and prior
to recruitment and how the records of age are
A detailed review of documents.
maintained and monitored.
Employee interviews.

The overall aim of the audit is to provide an areas of good performance as well as areas which
accurate and clear account of the level of require improvement.
performance of the employment site compared
with the relevant standards.
compliances, observations and good examples
The ‘SMETA Measurement Criteria’ – a (good practices) for each individual code item.
companion publication to this Best Practice
Guidance – gives the auditor clear instructions

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

The audit should include the following:

A non-compliance must be recorded
where the practices of the site of 1. Opening meeting.
employment do not meet the requirements
2. Tour of the employment site.
of either the law, the applicable code or
3. Management and worker interviews.
system encourages audit sharing it is very
important that the standard procedure is 4. Document review.
followed and that non-compliances are
recorded where the site practice does not 5. Pre-closing meeting.
meet EITHER the law OR the applicable
6. Closing meeting and summary of
code OR a customer’s code OR all three

A non-compliance should be raised

where either there is no system in place,
Notes:
compliance is met or where a lapse in the Where appropriate, additional evidence can
system puts workers at a disadvantage.
interviews, etc., which are detailed later in this
An observation may be recorded where
document
there is a site practice which does not
break the law or standard, but if not Where a previous audit report and CAPR
corrected, could lead to non-compliance. is available for review, examination of any
It may be an opportunity for improvement. corrective action plans or outstanding issues
An observation should be noted where should form a major part of the audit
there are very robust systems in place and
there is only an isolated lapse and this can See ‘SMETA Measurement Criteria’ for information
be corrected immediately. An observation is on detailed checks.
also noted when a non-compliance can be

end of the audit.

A good practice example will be recorded

where the site practice exceeds the
requirements and the site is encouraged to
bring those to the attention of the auditor.

Note: Examples of non-compliances can be found in

‘SMETA Non-Compliance Guidance’ available in
the Sedex Advance Knowledge Hub.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

7.1 Opening Meeting Introduction

Introduce the audit team to the employment
It is essential that the site takes as active a part site’s management and explain the purpose
as possible in the audit process. The audit is and scope of the audit, including potential
intended to highlight to the site management
areas where they perform well, and in addition to
investigate, with management team’s help, areas Remind management of the importance of
that require improvement. The opening meeting having union representatives and any other
is an important part of this process. worker representatives present at all stages of
the audit, including the opening meeting. This
The opening meeting should be held in a should have already been covered in the pre-
language understood by the management audit communication but should be repeated
and, if applicable, worker representatives. The at this stage if worker representatives are not
meeting is held to ensure that the employment present at the meeting.
site management and workers understand
the purpose of the code. It should cover the Clarify that the purpose of an audit is to
requirements against which their employment site evaluate the performance of the site against
is being assessed and it should also include the pre-agreed standards – how they manage
audit process, timescales and activities of the site, each area of the code as well as areas for
improvement.

It should be attended by:

the audit will be conducted.
Senior management.

Managers who are responsible for key required to be available (this should have
functions e.g. HR and production. already been received by the site with the
pre-audit information at least 2 weeks ahead
Trade union or worker representatives (if
of the audit). The site may wish to share
present at the site). Both groups should be
other documents at the audit and it may be
involved if both are at the site.
necessary to agree a more detailed list at the
Note: Where union and/or worker representatives opening meeting.
are present at the site auditors should strongly
request that they are present at the opening meeting.
cross-check the areas to be visited.
If this does not occur the auditor should obtain a
reason from the site and record this on the audit Discuss the need for openness and
report. transparency. For example, indicate where
relevant that Sedex members prefer to work
CHECKLIST – OPENING MEETING
with sites on challenging areas such as
A suggested agenda for the opening meeting is excessive overtime hours, rather than record
outlined below:
because of inconsistent records.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Establish if the site has any previous audit

information that they are willing to share. establish that the relevant Code has been
For example, this could be their own internal communicated to them.
audits. Assure them that any information from
previous audit information shared will not
prejudice the results of this new audit, but Business Ethics policy.
rather the auditor will review all areas without
bias.
Planning
Auditors should communicate issues Discuss and agree the audit schedule.

management the opportunity to provide Agree the managers responsible for each area
additional evidence to show how they are of the labour code (e.g. HR manager, Health
complying. It is best practice to communicate and Safety Manager) and where to conduct
issues as they arise to build agreement around interviews with these relevant persons.

management to: Request a list of workers who are scheduled

to work that day, together with any details
Provide additional evidence where that may be required to ensure that a
necessary. representative sample can be chosen for
interview e.g. gender, nationality, contract
Address issues immediately. These issues type, length of service.
will be recorded, but where corrective
actions are taken immediately, the issues
will be recorded as observations only and and the availability of an appropriate space.
the positive steps taken by the site will also
be recorded.
worker interview process and the expectation
Raise questions and address concerns. that workers will be paid for the time they
spend at interview.

other recipients of the audit report.

selected by the auditor.
Review the information provided in the pre-

previous non- compliances and follow-up patterns.

actions using the previous CAPR where
appropriate. Agree tentative time for the closing meeting
and invite attendees. If union and/or worker
If needed, explain the Sedex process including representatives are present at the site,
site registration and upload process (See ‘8.3 auditors should strongly request that they
Sedex and Uploading the Audit’). are present at the closing meeting. Ensure
that enough time is allowed to re-investigate
non-compliances if further evidence is made
take photographs. available.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Agree who will support the audit and 7.2 Tour of the Employment Site
accompany the site tour.
A detailed list of what must be covered as part of
the site tour.
production periods and explain the need to
sample working hours from this period. The purpose of the employment site tour is for
the audit team to observe physical conditions and
current practices in all areas of the employment
precautions required for the employment site
site, and to form a view of how they compare with
the applicable standards and codes. At the same
time, the auditor should be checking how the site
including dormitories. performs against its own policies and procedures.

Review list of chemicals available on site. Where a site is meeting the required customer
standard of the law and the code, but is not
Ask the management if they have any meeting its own internal standards, this can be
questions. recorded as an “opportunity for improvement”
and can be recorded on the audit report as an
If the employment site’s management do observation.
not agree to the participation of worker
representatives in the opening meeting or audit The tour is also an opportunity to hold
process, auditors should note this in the audit unstructured conversations with management
report and auditors must always arrange a and workers, seek site- based evidence to
separate meeting with worker representatives
where they exist.
evidence from management, document reviews
Note: Auditors should communicate issues to and worker interviews.
management as they arise during the audit. This
As a general principle, the auditor should be
corrective actions and allow management to: able to visit all the areas of the employment site
and should set the pace of the tour. In some
Provide additional evidence where necessary. cases, employment sites may prohibit visitors
from walking through some areas or forbid
Address issues immediately (these issues will
photography for reasons of safety or commercial
be recorded, but where corrective actions are
taken immediately, the issues will be recorded as
on access or photography in the audit report and
observations only and the positive steps taken by
if restrictions seem unreasonable should escalate
the site will also be recorded).
according to the audit requestor’s policy.
Raise questions and address concerns.
The ability of management to continue
production at the site during a visit is crucial to
enable the auditor to gain an accurate idea of
working conditions and to secure management
co-operation for the remainder of the visit.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

ensure production is not disrupted during the tour, with the auditor taking care to select a
employment site tour, whilst ensuring that they representative sample including workers who may
are able to view the production area during busy be considered more vulnerable such as those in
production periods. It should be possible to more hazardous jobs.
move around the site without delaying or halting
production. The site tour is important to establish an
overview of health and safety issues. However,
During the site tour, the auditor should meet a it is advisable that the time spent on the site
range of managers/supervisors/workers across tour is managed carefully so that it does not
all site operations. The auditor should not be disproportionately impact on the time available to
purely guided by management on areas to visit investigate other areas of the code.
and should freely investigate all areas that they
feel are needed to perform the audit. For detailed information on numbers of workers
to be selected for interview see ‘6.5.3.1 Table for
The auditor should raise issues as they arise, Auditor days and sample size’.
giving managers the opportunity to seek
Note: Auditors should ensure that workers cannot be
further evidence.
interviewed.

interviews should be made during this site

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

OBJECTIVES OF A SITE TOUR

The auditor should walk around all areas of the Hazardous substances storage, handling and
employment site in order to: disposal.

Understand the types of work. Warnings and labels, in local language as

appropriate.
Evaluate Health and Safety.
Waste management.
Identify potentially vulnerable groups of
workers. Toilets and sanitation.

Assess whether some operations may be sub- Potable water.

contracted to other units.
Canteen hygiene and safety when applicable.
Observe management systems and practices,
including interaction between management Dormitory hygiene and safety when
and workers. applicable.

Take the opportunity to have some informal Employment and Labour Practices
conversations with workers during the tour.
Young-looking workers.
During the site tour, the auditor should include the
Workers who could be at risk e.g. pregnant
following areas of focus:
workers or those working with potentially
Working Environment and Health and Safety hazardous equipment or chemicals.

Working environment e.g. layout, temperature, Indications of restrictions of workers’ freedom

tidiness. of movement.

Workstations. Indications of infringements of workers’ dignity.

Evacuation plans and evacuation routes.

interviews during the site tour or later in the
Any locked or barred exits or emergency exits. audit process.

Signs in local language as appropriate. Any indications of the lack of protection of

workers’ rights.
Fire equipment and emergency equipment.
Any indication of inequality, discrimination,
Building construction, maintenance and harassment or intimidation.

Locating documents and records:

Machine safety, guarding and maintenance.
Emergency procedures.
Emergency procedures.
Quality records.
Personal protective equipment.
Production records.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Time records. 7.3 Management and Worker

Displayed codes of conduct or labour law. Interviews

Displayed information relating to trade union It is essential that site practices are observed to
or workers’ committee meetings.
written procedures. Information from manager
Any legally required postings.
and worker interviews forms a key part of this
observation.
PERIMETER SURVEY

An optional perimeter survey can be useful 7.3.1 Management Interviews

to provide additional information about the The audit team should work through the relevant
employment site and its local context, and to code and local laws, talking to managers about
each issue area. It is essential to establish and
with waste storage etc. record what procedures the site already has in
place to manage all areas of the measurement
Note: A perimeter survey should only be undertaken
criteria. This is reported by the auditor in the
from the time spent inside the employment site.
Evidence Examined’.
The perimeter survey focuses on:
Open questions and discussion techniques should
The immediate surrounding environment. be used. It is important not only to talk to the
senior managers, but also to less senior managers
Neighbouring facilities e.g. hospitals, clinics,

police, waste disposal etc. Example questions:

Local perceptions of the employment site e.g. Ask - “How do you check ages when recruiting
work hours, labour issues, support for the local new workers?”
community, waste discharge etc.
This question allows for better responses and
Other facilities located on the employment therefore better information gathered than “Do
site e.g. dormitories, canteen, clinic, water you ensure that all workers are over the minimum
treatment vs. external water discharge. age at recruitment?”

The physical construction and layout of the Ask - “Can you show me the evidence to support
employment site e.g. building structure, how you check this?”
access, worker transport etc.
This should allow the site to take an active role in
Other production units or facilities on the re-examining their own procedures.
employment site which are not part of the
scope of the audit.
managers, and the process of examining and
sharing their practices with the auditor, will allow
the site to review its own practices during the
audit.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

The audit team should work with administration 7.3.2 Worker Interviews
review. If management is in possession of any INTERVIEW PRINCIPLES
worker survey feedback, this should form part
of the management interviews and can used in It is essential that workers are interviewed to hear
subsequent worker interviews if permitted by directly what they think of working conditions
management. at the employment site. The number of workers
to be interviewed relates to the total number of
The audit team should be prepared to challenge workers at the site. See ‘6.5.3.1 Audit Length,
management to obtain genuine information Sample Size and Timetable’ for information on
about management practices but should remain sample sizes.
courteous and cooperative.
Individual or group interviews may raise new issues,

compliance. This is when the personal skills and

experience of an auditor are invaluable in creating
the trust needed for workers to feel comfortable
disclosing details about the workplace.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Note: Workers identities should not be disclosed to 7.3.3 Planning Interviews

the management or be written on the audit report.
Workers must be selected to take part in
See ‘7.3.8 Protection of Interviewees’ for more
interviews by the auditor only. Ideally, worker
details.
selection should be balanced and proportionate,
Workers should be interviewed individually taking account of the types of workers, such
and in groups, without management present as local and migrant, agency workers, workers
and preferably in their own language. Where provided by service providers etc. All worker types
necessary, an independent, professionally- on site are in scope. The auditor should also be
aware of underlying issues e.g. shift, pay rates,
or their representatives must not act as translators.
Where a single language group makes up types.

50% or more of the total workforce, the worker Wherever possible, the identities of interviewees
interviewer must be a native speaker of that
language.

Audit team members carrying out worker of feedback to be maintained. Where it is felt that
interviews must have the skills to make workers
feel at ease. It is best practice to use informal, taken regarding the issues that are documented in
open interviewing techniques to encourage
interviewees to identify the issues of most
importance to them. It is important to uncover Identities of workers e.g. names or ID numbers
any hidden issues such as discrimination and should never be included in the audit report.
intimidation, which are not easily found through
In countries where Data Protection Laws apply,
other stages of the audit process.
the auditor should ensure that appropriate
Worker interviews should be conducted in a place
where the workers feel comfortable and where
Details of the number of workers that should be
a relaxed and informal setting can be created.
interviewed and the methods for selecting them
are covered in ‘6.5.3.1 Audit Length, Sample Size
with no representatives of management present
and Timetable’.
and where the interview cannot be watched or
overheard. Informal interviews may also take
place during the physical tour of the employment during the site tour as selection from documentation
site, at lunch-time or during breaks. assumes that all workers on site are documented. If
interviews are carried out prior to document review,
any issues raised can then be checked against
appropriate, especially if the auditor feels that
employees’ records to gain supporting evidence.
workers may be coached or intimidated in the
employment site. Possible locations may include
workers’ homes or local shops or facilities used by
workers.

Workers should be interviewed individually or in

groups, preferably using a combination of both.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

BEST PRACTICE – INTERVIEW DESIGN

with machines or chemicals.
The following best practices should be
considered when selecting workers and planning
interviews.

Workers interviewed are representative of

worker type and departments within the
employment site.

The worker interview samples take account issues such as disciplinary action.
of the proportion of local and migrant workers
The selection of workers should take place as
late as possible i.e. just before the interview,
types e.g. permanent, temporary and agency
in order to minimise the risk of workers being
coached.
work where possible.
The interviewer should aim to talk to a
Interviewees should be selected by the audit
wide range of workers including potentially
team and never by management. In making
vulnerable workers and those in less skilled
the selection, the auditor considers:
positions.

For sites with non-employee workers

(meaning any worker on site who is not directly
migrant or religious groups. employed by the site), Sedex members
recommend the following breakdown
within the sample size in order to ensure a
representative view of all types of workers.

canteen workers, cleaners and production

workers.

supervisors involved in production.

representatives.

representative(s).

training quality).

highest) in order to evaluate wages and

working hours.

Pregnant women.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

Auditors must aim to make the interviewee

Non-employee worker Non-employee worker
comfortable i.e. in the way they dress,
number interview sample
approach the interviewees and arrange the
1 1
chairs so that there are no obstacles between
2 2 auditors and workers e.g a desk can create an

3-7 3
Where two auditors are conducting interviews
8-48 4 together, it may help communication if
one auditor takes notes while the other
49-54 5
concentrates on establishing a rapport with
55-64 6
the interviewee(s).

Increases of 10 workers Increase by 1 additional

Where necessary, worker interviewers can
non-employee worker
take place through a translator. Translators
must be independent of employment site
245+ Maximum 25 management and must speak the language
concerned. Where there is a 50% majority
language at the site the worker interviewer
must be a native speaker of that language.

7.3.4 Conducting Interviews Where a translator is being used, they must

be fully briefed on the need for interviewee
Worker interviews must be managed with
discretion and empathy. The audit team should
introduce themselves and communicate the The auditor should provide interviewees with
purpose of the audit. They should assure
interviewees that all information shared during the event that a worker wishes to add information
interview will remain unattributed. No manager or outside the interview or while not at work.
representative of the employment site, apart from
the workers concerned, should be present during
any worker interview. 7.3.5 Individual and Group Interviews
The auditor must make a judgement on the most
Examples of good technique include:
appropriate interviewing methods, considering
individual and group interviews, the sample of
nature of the interviews and must never
mention an individual worker’s identity to interview locations. The method chosen should
management.
about the work environment and to discuss
The auditor must conduct the interview using issues such as pay rates, management style,
an informal “conversational” technique, using discrimination, harassment etc.
open questions that encourage dialogue. A
comfortable, relaxed atmosphere is the target.

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The following points are guidance only and 7.3.5.5 Group interviews are most valuable when
workers actively participate. In regions
However, the total number of interviewees where literacy levels are low, it may
given in ‘6.5.3.1 Audit Length, Sample Size and
Timetable’ should be adhered to as a minimum. communication, for example by using
paper and drawing tools to describe what

quieter workers can be encouraged to take

included. a more active part. Another example would
be the use of a priority chart to establish
7.3.5.1 Individual interviews typically last between the group’s view on the most problematic
15 and 30 minutes. Longer interviews issues for workers at the site. For more
will be required in some circumstances. information on these possible techniques,
Auditors should respond to any signals
(verbal and non-verbal) from workers
and may choose to convert an individual dialogue’ in ‘SMETA Measurement Criteria’.
interview to a group interview or vice versa.
7.3.5.6 To supplement the individual and group
7.3.5.2 Group interviews enable more rapid interviews, auditors may choose to provide
consultation with a larger number of a written survey to a large number of
people. Group interviews can be useful workers on site. To encourage responses,
at the beginning of an audit to gather these can be anonymous but their success
information quickly to inform the audit will depend on literacy levels.
process. Auditors should never use group
interviews to discuss personal issues such 7.3.5.7 As stated in ‘5.4 4-Pillar SMETA Audit’, the
as an individual’s wages. auditor should interview a minimum of one
manager and one worker from each area
7.3.5.3 Group interviews should be handled of Environment and Business Ethics.
with sensitivity. Some workers may be
encouraged to talk more freely in the Note: See ‘6.5.3.1 Audit Length, Sample Size and
presence of colleagues. However, other Timetable’ for guidance on number of interviewees.
individuals may become introverted in The auditor must select the correct total number but
group situations or may follow the majority
opinion rather than express their own. individually or in groups.

7.3.5.4 Group interviews should be planned to

last between 30 and 45 minutes taking into
account the additional time needed to get
workers to attend and to give everyone
site, where they may feel more able to speak
an opportunity to express themselves. If
freely about any concerns. This is often done
issues are uncovered, the interview may
when there is a perceived atmosphere of fear that
need to be extended to fully explore them.
prevents an open discussion in the workplace.
Alternatively, if workers are consistently
However, only very experienced auditors should
providing the same information, interviews
may be completed within the minimum
should also preferably be conducted in pairs, both
timeframe.

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for safety reasons and to capture and interpret spent on the SMETA audit at the main site.
information accurately.

7.3.7 Other Types of Interview

facilities frequented by workers, a worker
Where union and worker representatives are
dormitory where it is outside the site of
present, the audit team must include a selection
employment, a worker centre etc.
of any union and/or worker representatives as

interviews, there is a risk that they may perceive any training and support given by the trade union,
the practice to be inciting workers or causing as well as the union representatives’ knowledge
discontent. This can damage supply chain of collective bargaining agreements and union
relationships if not handled carefully. An auditor procedures for worker participation.
should always check whether this is a required
part of the audit programme.
worker representation present, especially where
there is a legal requirement for formal worker
information indicates that production processes management dialogue. For example, in some
are undertaken by homeworkers, the auditor areas where there may not be a legal requirement
should check with the audit requestor whether to have a union, there may instead be a law that
these are to be included in the audit’s scope. requires a functioning workers’ committee. It is
Where homeworking is discovered during an important that the auditor establishes and records
audit, the auditor should, at the least, report the responsibilities and actual function of any
the presence of homeworking and, again, committee present – Have they been elected by
check with the audit requestor whether a visit co-workers or selected by management? Does
to homeworkers is within the audit’s scope. In the committee only arrange leisure activities or
cases where a visit is not possible, for example does it also negotiate on behalf of workers?
due to location constraints, a separate audit of
External interviews with unions and NGOs in the
homeworkers and their working conditions may
region can give useful information regarding
be required.
prevailing labour conditions and the main issues
Similarly, if a site is found to be sub-contracting, for local workers.
the auditor should try to establish whether this
Caution: A site’s details should not be discussed
falls within the scope of the audit. The auditor
between auditors and any local groups (unless
may be required only to establish what systems
expressly directed by the audit requestor) as
the audited site has in place to control sub-
contractors, or they may be required to pay a visit
its customers. (See also ‘6.2.1 Background and
to sub-contractors. In any event, sub-contracting
context review’).
should always be reported on a SMETA Audit
Report. The auditor should gain an understanding of how
the trade union is organised at a local level and its
If the auditor is required to pay a visit to the
relationships with workers and management.
subcontractors, this ideally should be pre-agreed
ahead of the audit. The scope of the audit can Note: It is useful to ask the general workforce if they
then be increased to give time for visits to external know who their worker/union representatives are
sites alongside ensuring that the correct time is and how they use them.

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7.3.8 Protection of Interviewees and Examples of appropriate tools such as a

Use of Interview Information

through the Global Social Compliance Programme
The protection of workers and others against the (GSCP) ‘Reference Tool on Audit Programme and
possibility of reprisals must be paramount in all Methodology’.
audit planning, and especially during interviewing.
Auditors may feel the need to produce a separate,
In order to protect workers from retaliation, the
names of workers involved in identifying an issue for the audit reviewer (see also ‘Supplementary
must never be divulged to the employment site, Guidance for Dealing with Sensitive Issues
supplier or audit requestor, nor must they be Raised at Audit’). The contents of these reports
included in the audit report.

Note: The auditor may need to keep identity 7.3.8.1 Supplementary Audit Report
information for traceability reasons but this must not
be disclosed. See also ‘Supplementary Guidance Information too sensitive for the audit report.
for Dealing with Sensitive Issues Raised at Audit’
Concerns that cannot be substantiated
in the Sedex Advance knowledge hub.
through evidence and/or interviews.
In exceptional circumstances, where the best
Attitude of management towards the non-
interests of the worker cannot be met without
compliances or the audit process as a whole.
disclosure of their identity (for example, names
of child workers that the auditor fears may be
Supplementary reports may be appropriate:
sacked without any remediation), the auditor can
communicate this information to the appropriate If workers appear to be under undue pressure
from management on the day of audit.

Any issues of a sensitive nature or unsubstantiated If workers appear to have been coached.
information should not be mentioned to the site’s
management if this endangers workers. However, If management was obstructive or reluctant to
the issues or information may be reported

Where the auditor has concerns about the

This can only be done if the name of the brand/

Where sensitive issues could not be discussed
retailer is known and the auditor is aware of
during the closing meeting because of a
their requirements regarding the use of Alert
potential risk to workers’ wellbeing.
Wherever possible, these details must be sought
ahead of the audit.

information produced must not be uploaded

to the Sedex platform in order to protect the

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7.3.8.2
are required these should be made available to
Note: Where immediate communication is advisable. the appropriate reviewers within 24 hours of the

Urgent information, which the auditor feels

must be rapidly conveyed to the audit
requestor. CHECKLIST – PROTECTION OF INTERVIEWEES

Where immediate communication is advisable The following steps are essential to protect the
identity of workers who divulge information during
Note: This type of report may not be appropriate interviews:
when the audit requestor is the employment site
itself. The auditor must check whether separate
reports are required. These separate reports to be interviewed so that points raised are not
containing sensitive information must not be attributable.
uploaded to the Sedex platform. Please see
‘Supplementary Guidance for Dealing with The auditor should also consider the use of
Sensitive Issues Raised at Audit’ available individual rather than group interviews to
for members. For this reason there is no SMETA
template for these documents but examples are
available at GSCP ‘GSCP Reference Tools on Audit
who is being interviewed so that workers can
Process and Methodology’.
be protected in future if necessary.
Reminder: The auditor should always check if
Auditors should ensure that problems raised
by workers are discussed with management
are required. These should NOT be uploaded to
in a non- attributable way. Auditors must also
the Sedex platform.
ensure that the comments that they report
cannot be traced back to an individual worker.

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When workers raise issues that could be 7.4 Document Review

directly attributable to one particular worker
and/or could result in reprisals against Documentation is key to understanding how a
workers, these can be reported directly site manages all areas of the labour code. The list
to the appropriate audit reviewers via a of documents required should be sent with the
supplementary report, available at GSCP pre-audit information, to be received by the site
website (Note: Auditors should check the a minimum of 2 weeks ahead of the audit. This
reviewer’s requirements). The issue should not section details how the major documents should
be raised at the closing meeting nor uploaded be checked.
to the Sedex platform.

Where possible, an auditor should attempt to

7.4.1 Document Availability
cross reference points raised by the workers
through document checks. In this way, an The documentation needed for the audit
issue can be raised in relation to evidence and should have been requested during initial
not a worker’s information. communications with the employment site. As
the document review is an important part of the
Auditors/worker interviewers should leave a audit, the need for preparedness and availability
contact telephone number, preferably their
document reviews for the success of the audit,
number, with all workers interviewed so that should be emphasised in communication with the
workers can contact the auditor to volunteer site.
further information or to alert the auditor if
there are reprisals or intimidation. As part of encouraging a site to take responsibility
for its own compliance with codes, the auditor
should pay special attention to any local
inspections carried out by relevant organisations
document review where possible) can be e.g. government bodies, for example, business
shared with the employment site owner only licenses, checks on health and safety by local
where there is no risk of victimisation. An
example might be a verbal abuse issue where
a large number of interviewees have raised it, such as OSHAS 18000/ISO 9000 should be
making it impossible to trace individuals. The investigated and their reference number and date
auditor must use judgement and above all should be recorded. These should be noted in

and Evidence Examined’ where appropriate, and

Note: See also ‘Supplementary Guidance for copies may be attached to the SMETA Audit
Dealing with Sensitive Issues Raised at Audit’ Report.
available to members on the Sedex Advance
Resources Hub. On the day of the audit, all documentation should
be available at the employment site for inspection,
including payroll and working hours records.
All documents should be available covering
a minimum 12 month period prior to the audit.
If records for the previous 12 months are not
available, the employment site should explain why

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this is the case. Any non-legitimate absence of always be checked. The remainder of
documentation should be recorded on the audit records checked should be sampled from
report as non-compliance. the broader pool of employees.

For a full list of the documents that need to be 7.4.2.4 For each pay period selected, a minimum
reviewed, see 6.6 Preparation for Audit (Site of 10 records for a site up to 100 workers
of Employment)’. The list is also included in the should be reviewed. For larger sites the
‘SMETA Pre-Audit Information Pack’. number of workers reviewed should
follow the sample size table detailed in
this document. A larger sample may be
7.4.2 Document Sampling for Wages
and Hours found in the initial sample. A minimum
of 3 pay periods should be checked
Auditors should review at least three months’
including peak, current (or the most recent
worth of records from the 12-month set of data
available) and random/low month. For the
(or the available data for all months of production
avoidance of doubt the full sample should
when the factory has been operational less than
be reviewed for each of the pay periods
12 months) and should include records for the
selected.
most recent peak season available and for low
season or random months. In addition, documents 7.4.2.5 Wages and overtime rates paid must be
should be checked for correct holiday/leave recorded at the level of each individual
entitlement. Particular emphasis should be worker (see wages analysis table SMETA
placed on how the site manages all aspects of the Audit Report) . It must be made clear to
the reader of the audit report whether
and hours in contracts/engagement letters. the rates meet local law requirements
and whether they have been agreed with
To complete the wages and hours analysis,
representatives of the workforce.
auditors should concentrate on all types of
workers. The following points will help auditors 7.4.2.6 Hours worked must be recorded at
to complete the analysis in line with SMETA Audit the level of each individual worker (see
Report requirements. working hours analysis table SMETA
Audit Report) . It must made be clear to
7.4.2.1 It is necessary to examine full wage
the reader of the audit report whether
records for selected workers for a full
the hours meet local law requirements
12-month period to establish peak
and whether they have been agreed with
production and the extremes of both low
representatives of the workforce.
and high levels of wages and hours over
one year.
be able to complete the SMETA wages and hours
7.4.2.2 Working hours and wage records are
analysis, which requires highest, average and lowest
selected for investigation to cover peak
wage information for workers. Where discrepancies
and current production levels, and a
exist, for example between production records and
random/low month.
payroll records, the auditor should still endeavour to
7.4.2.3 The records for the workers who have complete the wages and hours table for individual
taken part in individual interviews should workers.

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See ‘6.5.3.1 Audit Length, Sample Size and should examine (where possible) hours records
Timetable’ for details. from a 12-month period for a sample of workers to
ascertain whether their actual hours worked meet
the waiver.
7.4.3 Presence of Waivers
It should be clearly recorded whether the non-
compliances are contrary to law as well as the
ETI Base Code. The legality of such a waiver
should be investigated and endorsement by local
working hours, whilst still meeting the law. If the
government should be noted.
auditor is presented with a waiver, the details
should be documented in the audit report and Note: Even if a local waiver is in place that overrides
copies attached (with translation into English if the local law, it can still be a non-compliance
necessary). against the ETI Base Code.

For example, if a waiver is presented that allows

7.4.4 Data Protection
workers to work in excess of the legal maximum
hours, the auditor should verify that the workers In countries where there are data protection
have agreed to such a practice and that they are requirements (e.g. all EU countries), auditors
suitably compensated at the correct overtime can obtain the written permission of workers to
rates with the application of overtime premiums
as required. the use of data consent forms, or in advance by
coordinating with management.
In the case of a local waiver that allows a total
number of annual overtime hours the auditor Note: See ‘SMETA Pre-Audit Information Pack’ for
more detail.

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7.4.5 Document Inconsistencies

will be informed of document inconsistencies,
the audit should record in the comments box
below the wage and hours table whether the
information in the wages analysis and hours
misconceptions by site management that the
analysis are ‘best available’ and could not be

are found. To try to overcome this lack of production records and wages and hours
trust, auditors should develop a rapport with records for example, OR if they are, in the opinion
management to explain that SMETA audits do not
other documents e.g. broken needle record,
to provide accurate records which present the production records etc. Members request that
full picture of the employment site’s operations. as much detail as possible is given about any
It should also be explained that Sedex members inconsistencies e.g. what records are showing

as a serious non- compliance. is it a single occurrence or a site practice?

If an employment site volunteers information

documents and worker interviews should be about incomplete and/or inconsistent records,
raised with the employment site’s management as this should be noted. Sedex members may
early as possible during the audit. It is imperative downgrade to a less serious non-compliance
that the nature of inconsistent or missing when site management have been transparent
information is established. about issues.

A systemic or wilful intent to mislead should be

treated seriously and recorded in the SMETA 7.4.6 Zero-hours contracts, gig-
economy and other casual work
to verify’ rather than a written accusation of an
Whilst there is a large focus on monitoring
attempt to mislead. A more detailed account can
excessive hours, there are also issues related
be submitted in a supplementary audit report or
to short shift times, zero-hours contracts, gig-
economy and other similar examples. In these
auditor requestor.)
instances, workers are paid for their individual
Note: hours / orders / assignments and neither party

minimum amount of work.

as a reason for not completing the wages and
hours analysis, but rather should complete
the table with the information available. At the also incur higher risk as often holiday and/or sick
same time the auditor should clearly state in the pay is not covered. There may be several reasons
appropriate section of the SMETA Audit Report
whether inconsistencies were an isolated incident however full details should be declared under the
or repeated occurrence. regular employment section in the SMETA audit
report together with substantive evidence and

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7.4.7 Purchasing Practices 7.5 Pre-Closing Meeting

Whilst Sedex members do all they can to work
together with their suppliers in a collaborative It is important that the audit team (even if only
way, the supplier may feel that there are
circumstances outside of their control that lead to presented at the closing meeting. This is done at
excessive overtime hours. a pre-closing meeting.

Suppliers may have several reasons for excessive The audit team should meet before the closing
overtime hours and they should be encouraged to
share these with the auditor. Their views should be and identify inconsistencies, non-compliances,
recorded at the end of the Working Hours Analysis observations and good examples. The analysis of
table under evidence gathered must be undertaken before
the closing meeting, even if there is a single
auditor carrying out the audit.
reasons/circumstances that explain the highest
working hours)’ in the SMETA Audit Report. The audit team should prepare for the closing
meeting by reviewing and discussing the
Suppliers may feel that customers play a key role evidence presented and then identifying and
in managing overtime levels by ensuring that they agreeing:

it to be well planned. There might be elements Non-compliances.

of the customer’s practices or buying patterns
that increase the risk for excessive hours, and
in the interest of continuous improvement and Possible corrective actions, how these can
collaboration, it is important that this is captured.
completion.
Where a supplier states that this is happening and
that given lead times are too short, the auditor Systematic problems and issues.
should record this and, wherever possible, should
seek substantive evidence e.g. order dates and The root cause of problems, where possible.
requested delivery dates.
Good examples.
This exercise can often give the site an
opportunity to examine their own systems to Possible prioritisation of issues.
establish whether their own internal ordering
Any requests for additional information or
evidence.
The auditor’s recorded information is of use to the
customers as they start to examine their own role

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7.5.1 Grading Non-Compliances

observations and good examples, see section 7
SMETA does not give guidance to auditors
‘Audit Execution’.
regarding the grading of issues. If the audit
requestor requires the auditor to grade non- For each non-compliance or observation, the
compliances, the auditor should use the audit SMETA Audit Report should provide:
requestor’s grading structure. Guidance on
severities can be found in the ‘SMETA Non- A description of the non-compliance or
Compliance Guidance’ on the member resources observation, its frequency and the number of
of Sedex. people concerned.

The Sedex system also allows all members A/ Whether it is an isolated incident or a more
AB/B to allocate grading severities to their own systemic problem.
non-compliances on the system, and the system
supplies a default grading list accepted by most
Sedex members.
Reference and details of the relevant area of
the code and/or local law.
7.5.2 Corrective Action Plan Report Recommended corrective action with a
The ‘SMETA Corrective Action Plan Report timeframe for completion, responsibility and
(CAPR)’ has been designed to provide a structure

site develop a corrective action plan at the closing The Corrective Action Plan Report (CAPR) should:
meeting.
Be clear and presented in the local language
For all non-compliances and especially those spoken by the employment site management,
related to working hours or wages, the audit team with a copy provided to the audit requestor
should identify the context of the issue and its in English. In addition, the audit report and
frequency, the number of people impacted and CAPR uploaded to the Sedex platform must
the department(s) concerned both at the closing be in English, signed by the auditor and site
meeting and in the audit report. management.

The auditor should complete a draft CAPR prior to Be distributed as follows:

the closing meeting with the objective of agreeing

employment site manager (in a language

corrective actions at the closing meeting. Non-
understood by the site).

site’s practices do not meet the law and/or the

applicable code. by the auditor together with other audit
documentation.
Observations and examples of good practice are
also noted so that the CAPR provides a clear and A hard or soft copy sent to the audit
balanced picture of how the employment site requestor and the agreed reviewers.
is managing each aspect of the relevant labour
code.

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Note: Where extra copies cannot be signed on the Preventative and Corrective Actions
day, the documents should at least contain the
signatories’names as evidence of signatures. This column contains details of actions to be
taken to clear the non-compliance i.e. immediate
The CAPR should be issued to the site actions and the system changes required to
management immediately/as soon as possible prevent re-occurrence i.e. longer-term actions.
after the audit has taken place. If amends are The recommendations for corrective actions
required, a new version is issued with the audit should be made either by site management or
report to all 3 parties. by workers and, only if necessary, by the auditor.
Auditors are encouraged to share best practice
CHECKLIST FOR COMPLETING A CAPR and solutions from their own experience but

Non-compliance number
site.
This should include a separate line for each
The auditor should attempt to ensure that the
non-compliance. The ETI Base Code number for
recommended actions address root causes as far
the element of the labour code or local law that
as practical.
has not been met should be used. It should be
numbered as per the ETI Base Code i.e. number 2 Note: Auditors should direct suppliers to information
available on the member’s section of Sedex website
e.g. ‘Supplier Workbook’ and ‘SMETA Corrective
Details of non-compliance
Action Guidance’.
The non-compliance should be described clearly
Timescale
and concisely, with reference to the element of
the labour code and/or local law that has been This is the time required for the recommended
breached. The information in the CAPR can be corrective actions to be implemented and for the
more concise than in the audit report, but it is issue to be closed. Immediate correction may
important that the information is consistent with be listed in the timescale column, but the time
the audit report and makes clear which non- allocated for corrective actions to be completed
compliance the action refers to. should be appropriate and realistic. Longer term
actions and recommendations of how to address
Root cause
root causes may require extended timescales and
The main objective of the CAPR is to promote cannot be decided at the closing meeting. In this
improvement at the employment site. The case, they need not be included.
auditor should encourage the site to identify the
In the exceptional cases where it is not possible
root causes of issues as far as is practical to do
to agree timescales e.g. the site wants time to
so. This is best achieved by repeatedly asking
consider, then the auditor should at least record
“why” to develop a deeper understanding of
on the CAPR that timescales were discussed e.g.
underlying causes and their relationship to the

a root cause will often prevent a re-occurrence of Recommended timescales are given in the
that non-compliance (see the ‘SMETA Corrective ‘SMETA Non-Compliance Guidance’.
Action Plan Report (CAPR)’ document for more
information on how to identify root causes).

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This column should be completed by the auditor 7.6 Closing Meeting and Summary
in agreement with the site’s management. The
of Findings
auditor should ensure that management clearly

route selected and the next steps required. a full discussion at the closing meeting. The
corrective actions suggested by the site must
On-site follow-up audits are recommended for be fully discussed and recorded once agreed.
non-compliances for which corrective actions can Close attention should be paid to whether the
only be evaluated through a site tour, interviews or suggestions are practical and whether the site is
a physical review of documentation. certain they can be completed within the agreed
time frame.
A desk-based follow-up may be used to verify
corrective actions if agreed by the audit requestor. The aim of the closing meeting is to inform
Desk-based follow-up can be used to verify
corrective actions through photographs, copies employment site’s management, and to verify

employment site. Desk-based follow-up cannot

worker testimony or physical site evidence. communicated as soon as possible throughout

the audit. The closing meeting is also another
opportunity for the site to supply any additional
‘SMETA Non-Compliance Guidance’ on the Sedex information not yet seen.
advance knowledge hub., which gives examples
of timescales and methods for verifying corrective
actions.

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7.6.1 Agreeing Corrective Actions

Corrective actions should focus on long-term
non- compliances, this may be recorded as an
sustainable solutions, which correct the root
observation. However, it is important that the
cause of any problem. The auditor should
original issue is fully recorded along with the
encourage the employment site to take time to
evidence provided as a corrective action, and that
formulate a Corrective Action Plan that creates a
ensures that the problem will not re-occur.
blocked, a system is required to ensure that they
The purpose of the closing meeting is to agree remain clear.
the suggested corrective action plan, which
For endemic long-term issues e.g. excessive
sets out areas for improvement, actions and
working hours, the employment site management
timeframes. This meeting should involve all those
may need to formulate a Corrective Action Plan
attending the opening meeting, ideally including a
in collaboration with their customers but should
worker representative.
acknowledge their acceptance of the non-
The meeting should be conducted in a language compliance.
understood by management/all present. If no
If the management of the employment site does
worker representative is present, details of how
information will be communicated to worker
state that if they produce evidence that shows the
representatives needs to be ascertained and
noted on the CAPR.

via another route such as employee interview,

site in a language understood by the site, however document review and observation before
it will also be necessary to supply a copy in acceptance.
English – especially to the appropriate customers.
CAPRs uploaded onto the Sedex system must, at
a minimum, be uploaded in English. For SMETA 7.6.2 Immediate Correction of
audits, the CAPR must be uploaded to the Sedex Non-Compliances
system, ideally as a pdf along with the audit If evidence is produced which clears non-
report. compliance, the non-compliance may be
recorded as an observation. The evidence
Note: In cases where management does not agree,
produced at the closing meeting should be
they should sign the ‘dispute’ section of the CAPR
recorded on the CAPR as an immediate corrective
and state their reasons.

produced at the closing meeting that had not

previously been seen by the auditors.

If a non-compliance can be corrected

immediately e.g. a blocked gangway, it should be
recorded as an observation, but only if the auditor
is shown proof of a system that can ensure the
route will be kept clear.

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The auditor should always investigate and

document how compliance will be maintained as necessary.
before recording an observation rather than a
non-compliance. Record non-compliances that can be
corrected immediately.

7.6.3 Conclusion of the Audit Answer any questions that management have.

Finally, ask the management team if they have Explain when the full audit report will be
any questions. Explain the agreed distribution of completed and who it will be sent to.
the full audit report and who will be in contact
with the employment site regarding any follow- Summary of Findings and Corrective Actions
up. Inform the employment site of the Sedex must be signed by both the lead auditor and
uploading and corrective action management site representative.
process and explain their responsibilities.
Leave an understandable copy of the
See ‘8.3 Sedex and Uploading the Audit’ for more corrective action plan with management.
detail.
The corrective actions should include a
timeframe for completion and the type of
CHECKLIST – CLOSING MEETING:

Thank the management for their time and If the Summary of Findings and Corrective
contribution. Actions are not agreed, the auditor should ask
the site to sign the CAPR in the dispute box
along with reasons for the dispute. The auditor
assessment. should then leave a copy with the factory and
report disputed points to the audit requestor,
copying in the factory.
at the meeting, but any issues they have
agreed to cannot be queried later. Inform the facility of the Sedex uploading and
corrective action management process that
Recognise good examples that have been
forms part of the Sedex system, ensuring they
observed during the day.
are made aware of their responsibilities.
Agree any non-compliances and explain that
See section 8 ‘Audit Report and Outputs’ for more
the audit was based on a sample examination
information.
of their employment site and there may
be some non-compliances that were not
observed.

Ask the site to identify root causes, suggest

corrective actions, timescales and person
responsible for correction. Record the
corrective actions.

Cancel any non-compliances where evidence

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7.6.4 Dispute of Findings Note: The CAPR must always be signed by a site

There is the facility on the CAPR for an

by the management (you) signature:______________”

page of the CAPR: Or in the box “please indicate below if you, the

Section 1 – Non-compliances discussed and

signature::______________”

to reach agreement with the employment site Where it is not possible to include a handwritten
and obtain their representative’s signature. signature on the uploaded CAPR, the document
should at least include typed names of signatories
Section 2 – Where there are any disputed
as evidence of signatures.
non-compliances, the employment site
management should be invited to complete In cases where the site refuses to sign either
the second part of the signature box and to section, and particularly if the auditor may feel
state their reason for any dispute.
should be recorded in the management attitude
section of the audit report – ensuring that there is
no risk to the auditor.

Note: The ‘SMETA CAPR’ invites feedback on the

gives access to a survey, which records views

concerning the audit experience.

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Chapter 4 (Section 8)

Audit Reports
and Outputs
8. Audit Report and Outputs

The SMETA Audit Report and CAPR are the most important
outputs from an audit as this information is visible to the
site’s customers. It is essential that both the audit report
and CAPR are clear and contain as much useful information
as possible. The auditor must remember that the parties
reviewing the audit were usually not present at the audit.

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8.1 Audit Report Completion Evidence and information to substantiate any

This section includes details of how an audit

Photographs to identify the site and to
report should be written including timeframes for
delivery.
For each non-compliance or observation, the
audit report should provide:
8.1.1 General Points
A description of the non-compliance or
The SMETA Audit Report should be completed
observation, its frequency and the number
as soon as possible after the audit and should
of people concerned.
always meet the Service Level Agreement (SLA)
of the auditor/audit requestor. The audit report Whether it is an isolated incident or a more
should be written to present a full and balanced systemic problem.

on continuous improvement, the audit report

should be shared with all interested parties e.g.
employment site/supplier/customer as soon as
possible after the audit. of the Code and/or local law.

If the SMETA Audit Report and CAPR are to be Site-suggested corrective action with a
uploaded to the Sedex platform, they must at timeframe for completion, responsibility
the least be written in English and must use
the standard ‘SMETA Audit Report’ template. In
addition a copy of the audit report should also be
reviewer who was not present at the audit is able
available in the language of the employment site’s
to accurately understand the type and scale of the
management (two languages may be combined
on one copy if agreed by all relevant parties). Any
deviation from the SMETA must be recorded in
the SMETA Declaration at the front of the audit
report.
The purpose of the audit report is to give a full

language, stating the issues or observations of the audit. Readers of the audit report should
clearly so that they could be understood by be able to build up an accurate picture of the
someone who was not present at the audit. supplier site, both what it is like to work there as

For each area of the Code, the Audit Report by auditors.

should include:
8.1.2.1 Completing Current Systems and Evidence
A description of the current situation and how Examined
requirements are managed (see ‘8.1.2. S
Points’). Most Sedex members are interested in working
with their suppliers on a programme of continuous

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Improvement. To understand improvement Who is responsible for checking?

opportunities, readers need a detailed picture
of the current systems of a supplier site. When Is it documented? Can someone take over that
correctly completed, a detailed SMETA audit responsibility if required?

The above information should be checked and

facilitate a discussion of how improvements can
recorded by the auditor, investigated by asking
be made.
open questions of the management and allowing
the responsible manager to demonstrate to the
Systems and Evidence Examined’ for each area auditor how this area of the code is managed.
of the code. This is an opportunity for the auditor This can be substantiated at worker interviews by

item is managed by the site. It is the place on the perspective.

audit report where a detailed description of the
By detailing the above procedures and practices
management system that either prevents or leads
and the evidence checked in this section, the
to a non-compliance can be recorded.
responsible manager and the audit report reader
Under Current Systems for each clause, the can judge whether any problems found are likely
auditor must record the processes in place to occur or re-occur.
to manage each area of the labour code. For
8.1.2.2 Completing Wages and Hours Tables
example:
The wages and hours tables were created to
How does the site recruit workers (linked to
provide an overview of payment to and hours
minimum age of employment)?
worked by individual workers. The additional
selection criteria for the individual workers is
engagement, contracts? based on their wage levels, and the table requires
an auditor to identify proportions of the lowest
How does it manage hours of work for each paid, average paid and highest paid. The aim of
individual worker, what recording system is the table is to give the audit report reader a snap
used, and how is overtime managed? shot of wage levels, at the level of individual
workers, particularly in a situation where it is
How are workers paid, how are wages
not possible to verify hours of work and wages
calculated, is it piece rate or hourly and how
does management ensure at least minimum because of discrepancy between records e.g.
legal wage is paid for standard hours?Clause production records and wages/hours records.
4: Child labour shall not be used

An employment site should have detailed, robust correctly as possible making sure that all time
procedures for hiring workers of the correct age. intervals and currencies are included - per hour/
per week/per month and the units stated.

should detail: Wages table

How workers are hired. The wages table contains a number of questions
that need to be answered for three individual
What is checked? workers based on their wages levels. The records

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

should be selected from the pool of records How many rest days the workers have in any
reviewed within the scope of the audit. For all 7- or 14-day period.
three wage levels presented in the table, the
same month should be reviewed (e.g. October). If there are deviations from the standard, any

peak, current or random/low sampled months the For both of the above tables, the information
wages table is based on, but it is recommended should be retrieved by checking the provided
that the auditor chooses an example month which records. If the information is not clear, an
is representative for the site. The aim of the wages additional number of records can be checked to
table is to give the reader an understanding of clarify the situation. If the wages level or working
(amongst other things):
in records, the auditor should report on the
Whether or not the workers receive minimum
wage or above/below minimum wage. comment on inconsistencies in other applicable
parts of the audit report (Current Systems and
The spread of wage levels. Evidence Examined, Non-Compliances, Key
information, Management Systems). Members
If the workers are paid extra for overtime and,
if so, how much.
verify’ in the wages or hours table.

8.1.2.3 Other areas of the SMETA Audit Report

insurance.
In addition, from some recent anonymous surveys
It is essential that units of currency and the time
of the SMETA audits, the SSF has prepared the
period are stated for each entry.
following list of common misinterpretations made
Working hours table by some auditors. The SSF anticipate that referring
to this list whilst completing an audit report will
The working hours table should be answered reduce the level of unclear information:
with information from all sampled workers’
records in the audit and, where needed, for the Any variation to the standard SMETA process
full workforce. ETI updated their working hours must be recorded in the SMETA declaration on
standard in April 2014, and these changes have
now been incorporated into SMETA (for more sizes or audit duration. A common error is a
information see ETI website on ‘Working Hours’). shorter duration of audit than described in
‘6.5.3.3 Example Programmes’, without any
The aim of the working hours table is to give explanations in the SMETA declaration.
the reader an understanding of (amongst other
things): Key information in the SMETA Audit Report
asks whether the lowest paid worker at the
How many standard hours the workers do per site is below minimum wage, meets minimum
day/week/month. wage or is above minimum wage. The auditor
should check the correct box and attempt to
How many overtime (OT) hours the workers do estimate from the total wage analysis what
per day/week/month. % of workers are below, meet or exceed the
minimum legal wage.

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Migrant worker numbers are required in the 8.1.2.4

Auditors must list non-compliances

the country. Auditors should be clear about individually with the appropriate code clause
or law and appropriate corrective action
accompanying each single non-compliance.

province or region where they are not a Current Systems and Evidence Examined by
native and where they are not eligible
to become or do not intend to become
permanent residents. above).

In some countries/areas, they can be For greater clarity in producing a good practice
SMETA audit report, the SSF has produced the
permits to work in that location. ‘Guide to Completing a SMETA Report’ and
‘Guide to Completing a SMETA Corrective Action
Wages and hours analysis must always state Plan Report’, both publicly available on the Sedex
the units (for wages) and the payment interval website.
– per hour, per day, per week, per month.
For hours analysed, the auditor must record
whether they are daily, weekly, monthly for
both standard hours excluding overtime
as well as for the recorded time period for
overtime hours.

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Note: A non-compliance: when a site does not meet

local/national/international law requirements.

A non-conformance: when a site meets

member resources section of the Sedex website the law but does not meet the ETI code or
(see ‘SMETA Non-Compliance Guidance’). customer code requirements.

The audit report must not include any Sedex members suggest providing maximum
information that could be used to identify detail of the non-compliance action in the audit
report, which should include a description of
descriptions and/or work location. the non-compliance, the local law and/or ETI
requirement, the recommended corrective action
Unless agreed otherwise, the audit body will not and the objective evidence observed.
distribute the audit report outside Sedex to any
entities except the audit requestor. A non-compliance should report on:

A description of the non-compliance, its

8.2 Describing Non-Compliances, frequency and the number of people
concerned.
Observations & Good Examples
Whether it is an isolated incident or a more
Sedex members have provided some examples systemic problem.
to encourage consistent reporting on issues
found.

Reference and details of the relevant area of

8.2.1 Describing a Non-Compliance the code and/or local law.

Recommended corrective action with a timeframe

A non-compliance must be recorded where
the practices of the site of employment do method required.
not meet the requirements of either the law,
Examples:
code. Since the Sedex system encourages Issue title: Provision of PPE
audit sharing, it is very important that the
standard procedure is followed and that non- Description of Non-Compliance:
compliances are recorded where the site
practice does not meet EITHER the law OR NC against local law
the applicable code OR a customer’s code
OR all three. During the site visit it was noted that all 6
workers in the spray-painting department
A non-compliance should be raised where were not wearing rubber gloves, goggles and
either there is no system in place, the system masks. Examination of the MSDS showed
that these were solvent-based paints and the
or where a lapse in the system puts workers recommended safety precautions were to use
at a disadvantage. them with the above protective equipment (PPE).

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Local law and/or ETI requirement:

ETI 3.1 - A safe and hygienic working Description of Non-Compliance:

environment shall be provided, bearing in
mind the prevailing knowledge of the industry NC against local law

shall be taken to prevent accidents and Workers expressed dissatisfaction with

injury to health arising out of, associated performance of the welfare committee citing
with, or occurring in the course of work, by
minimising, so far as is reasonably practicable, receiving feedback from management.
the causes of hazards inherent in the working
Local law and/or ETI requirement:
environment.

ETI 2.1 - Workers, without distinction, have the

right to join or form trade unions of their own
Article 37’ states that “units shall provide
choosing and to bargain collectively.
PPE for employees and arrange the correct
supervision and training.” Recommended Corrective Action:

Recommended Corrective Action:

It is recommended that the welfare committee
meets regularly, that meetings are minuted
The Health and Safety Manager Mr FFF
and that minutes are shared with the
discussed with the factory manager that PPE
workforce.
must be obtained for all 6 workers in the
spray-painting workshop and that he (Mr FFF)
Action By: Personnel Manager Time frame: 60
would ensure that all workers were trained
days.
in its correct use. He believed that training
was available from the supplier of the paints Objective Evidence Observed:
and would organise for the supplier to visit to
provide a training session. Following worker interview results, auditors
found that the welfare committee met
Action By: Mr FFF Time frame: 30 days. very infrequently, did not discuss the items
suggested by the workers and did not produce
Objective Evidence Observed:
minutes of meetings.

Site tour and MSDS of paints. Note: Freedom of Association is a complex area

between countries and also between Export

Processing Zones. The following description
represents the level of detail that Sedex members
would like to see in an audit report.

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Current systems and evidence examined: 8.2.2 Collecting Observations

Description of Observations
“There is no trade union on the farm. However,
there is a parallel means of engaging
management, by use of a workers’ welfare
committee. The committee meets with An observation may be recorded where
management to review labour and welfare there is a site practice which does not
conditions at the work place. contravene the law or standard but, if not
corrected, could lead to non-compliance.
The workers’ welfare committee is also used It may be an opportunity for improvement.
to communicate to workers. Workers and An observation should be noted where
management discuss and agree on practical there are very robust systems in place and
solutions to any issues that may have been there is only an isolated lapse and this can
raised, assign responsibilities and set timelines be corrected immediately. An observation is
for actions and follow-up on any actions also noted when a non-compliance can be
agreed in previous meetings.
end of the audit.
Other than the welfare committee, there exists
a gender and a health and safety committee.
Worker representation is from every An observation is recorded where there is a site
department of the farm. Workers elect their practice that does not contravene the law or
representatives themselves. standard, but if not corrected it could lead to non-
compliance. It is an opportunity for improvement
Training is conducted to enable these e.g.

duties. The committees have agendas for their Minutes of the workers’ committee meeting
meetings. are produced but they are not circulated.

Fire extinguishers all appear in date and

Minutes of all meetings are documented and
correct but no system is in place for checking.
shared during workers’ meetings and posted Personnel handling chemicals were doing
on notice boards”. so satisfactorily but no system is in place for
training new workers.

Observations can also be raised where a non-

compliance is immediately corrected, see ‘7.6.2
Immediate Correction of Non-Compliances’.

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8.2.3 Collecting Good Examples The site supports a local school. They donate

Description of Good Examples

their own is replaced with new. This resulted in
donations approximately every 6 months. The
Good examples should not be raised were previous donation was of 5 computers and
the site is merely meeting legal or Code printers which were still usable.
requirements.
The factory had open days for workers’ friends
and families. On these days, they are all invited
A good example is an issue that the auditor feels for food and a look around the factory so
is over and above the standards and applicable that they can be reassured of the working
laws against which the site was audited e.g. conditions of their family members.

Crèche available for the workers’ children The factory arranges for factory tours for the
(where not required by law). pupils of a local school for children with sight,
hearing and speech disabilities. The pupils
Storage for bikes and shower facilities. learn about life at the factory and, wherever
possible, the factory recruits from the school
Good examples can be collected through on-
– placing individuals into jobs that suit their
site observation and interviews and can be
capabilities (approx. 5% of the workforce had
summarised under each section of the Audit
come from the school).
Results by Clause of the SMETA Audit Report

be required to enter an action for a Good Example

8.3 Sedex and Uploading the Audit
(GE).
The Sedex membership depends on and expects
good quality audit information to be correctly
uploaded to the Sedex system. To demonstrate
The auditor should ask the site if they support any impartiality, Sedex recommends that the audit
information is uploaded by the audit company.
workers not already recorded. Any information
shared should be stated in this section. For
example: requirements regarding which party should
upload an audit. Both the auditor and the supplier
site are advised to check these requirements
and agree this at the quotation stage of the audit.
Failure to check the requirements of customers
may result in a site doing more than one audit.
It is recommended that the site investigates the
requirements of all its customers and aims for an
audit that is satisfactory for all, wherever possible,
to avoid audit duplication.

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Even when the auditor uploads the audit

information, control of visibility of the audit
Sedex (Supplier Ethical Data Exchange)
information remains with the site as they control
access by their customer linkages.
for businesses committed to continuous
Below are guidelines on how to upload audits to improvement of the ethical and responsible
Sedex Advance, as well as how to add and review practices in their supply chains.
corrective actions. Where relevant, links to step-
Sedex promotes data sharing to ease the
by-step guidance are included.
administrative burden on suppliers when
trading with multiple retailers/brand
information regarding Sedex to the audited facility customers that require ethical audits.
to ensure that they understand the activities the Suppliers can upload audits and share them
site must carry out on the Sedex system (please with their customers, cutting out repetition,
see the ‘SMETA Pre-Audit Information Pack’ for cost and administration and reducing the
examples). number of audits.

Information should include but not be limited to: Sedex also allows the sharing of good practice

uploaded; details of training programmes;

involvement with community projects and
NGO’s; and good examples in audit reports.

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Sedex members include leading global brands Filling out the Self-Assessment Questionnaire
and thousands of suppliers already registered – this is highly recommend before an audit.

growing each month and an ever-increasing Audits on Sedex Advance.

number of customers are likely to be using the
Adding Corrective Actions.
Sedex platform.
The Sedex Supplier Workbook.

8.3.2 The Sedex Process

The audit body advises the auditee of the auditees/sites to help them complete the
customer requirement, as well as the process for following three essential steps before an audit
uploading to the Sedex platform and associated can be uploaded:
fees for these services. The auditor should supply
Set up their account and register at least one
the auditee with links to the relevant guidance
packs, which can be accessed and downloaded
on the Sedex Knowledge Hub, our members’ Complete a Self-Assessment Questionnaire
resource section. To upload an audit to the and share it with the auditor prior to the audit
system, a few pre-requirements are necessary:

The auditee must be a registered audit. This will give the auditor access to the
active member of Sedex. If the supplier Self-Assessment Questionnaire
requires guidance, please see: http://
www.sedexglobal.com/wp-content/
uploads/2011/06/Supplier-Guidance- 8.3.3 Uploading the Audit (Supplier
Register-for-Sedex-1.pdf
Site or Auditor)
Once the registration process on Sedex Once the audit has been conducted and
Advance has been successful, we suggest completed, it is recommended that the SMETA
they consult the Knowledge Hub for further report and CAPR are shared on the system
steps to minimise audit requests from any further
customers. Any social audit from any auditor
How can the Knowledge Hub be accessed? can be uploaded to the Sedex platform.

Knowledge Hub? For detailed guidance on how to upload an

audit report on Sedex Advance, please consult
The Knowledge Hub and the documents it the Knowledge Hub:
contains can be accessed by logging into Sedex
Advance and either clicking on the Help button or
the little pink icons on the top of each page.

Knowledge Hub?

How to set up your account and register sites.

How to add customers and grant access

rights.

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Please note that where the site has requested Sedex strongly recommends that external
the audit on the Sedex system, the system will audits are uploaded by the auditing company
auto-publish within 7 days of audit upload. Audit as this provides greater assurance of
independence.
authorised third parties in a protected and un-
editable format. A documented release statement
should be obtained by the auditor prior to such
release.

Site logs into the Sedex

advance, nominates the
site which will have an
audit and creates an
Audit upload audit request in advance
request of the audit.

Tip: Ensure your SAQ is

shared with the audit
Audit company receives company.

reviews SAQ.
Upload
audit report
After audit, the auditor
logs into Sedex Advance Site receives an email
to complete the upload
the Sedex Advance
platform. The site reviews
the audit uploaded and
review &
publishes the audit.
publish audit
Tip: Your audit will only
be visible to the clients
selected and to which
you are fully linked.

Audit now visible to all clients on your client list.

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8.3.4 Adding Corrective Actions 8.3.5 Reviewing Findings (Auditor)

(Supplier Site) This assumes that the supplier site has submitted
Sedex requires supplier sites to input the actions
that they have completed in response to the audit through the Sedex system.

The auditor reviews the attached actions

The site: which should include documentary evidence.

For step-by-step guidance, please see

‘Auditor Guidance Pack Stage 3 – Reviewing
Non- Compliances & Corrective Actions’,
available on the Sedex Advance Knowledge
actions attached) back to the auditor for Hub.

For step-by-step guidance, please see ‘Auditor

Guidance Pack Stage 3 – Reviewing Non-
Compliances & Corrective Actions’, available
on the Sedex Advance Knowledge hub.

Site logs into the Sedex

Advance platform and
adds all their planned
actions.
Add Corrective
Audit company receives actions & send Once completed, the site
to auditor attaches all necessary
reviews the corrective documentary evidence
action and all attached and submits to audit
documentary evidence. company.

The auditor responds Review Site's

with one of the following: Corrective
Reject Actions
Site receives an email
Progress made/
pending follow-up the Sedex Advance
platform, to see if any
If necessary, further actions are
re-do above required.
actions
Tip: You may need a
follow-up audit to verify –
contact the audit
company to arrange.

Corrective actions and non-compliances completed.

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8.3.6 Other Recommendations 8.5 Audit Records

While Sedex does not set any standards/ Auditors should retain audit reports (for reference)
requirements, each customer may have their for a minimum of two years, or longer if agreed
own standards/requirement. Therefore, Sedex with the audit requestor or if required by law.
recommends that:
It is recommended that the auditor retains
The auditor checks with customers regarding copies of at least the following documents:
their requirements for Sedex upload and
communicates these clearly at quotation
stage to the site. This would include their status of the company (business licence).
customers’ requirements for the timing of the
upload and visibility of audit information on the
buildings and people).
Sedex system.

External audits are uploaded by the auditing

format).
company as this provides greater assurance
of independence and greater ability to
meet several customers’ requirements
simultaneously. Samples of risk assessments of
employment site, if available.

8.4 Information Management

Following each audit, the auditor should provide
the following documents to the audit requestor: wherever possible.

the audit requestor is the site, or if the Sedex workers interviewed and records reviewed.
SAQ is already visible to the audit requestor
(through the Sedex system), there is no Data and privacy laws in some countries prohibit
additional need to provide the Pre-Audit copies being made of certain documents; in such
cases, auditors should respect these restrictions.

The completed audit report (SMETA Audit

Report).

(CAPR).

Supplementary audit information (where

applicable).

Note: If the audit requestor is not the site, necessary

permissions must be obtained before sharing
information. Please see ‘6.1 Audit Request’ for
details of audit ownership.

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Chapter 5 (Section 9)

Audit Follow-Up
Finding issues during an audit is only one part of any audit
programme. At least equally important are the actions taken
by the site to correct the issues found. Follow-up audits are
an important part of the SMETA process, giving both the site

should remember that they are auditing for improvement,

not only compliance and where a site has made progress
against an incomplete corrective action, the progress must
also be recorded in the SMETA Audit Report.

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9.1 Follow-up Audits 9.1.1 Purpose of a Follow-up Audit

The follow-up audit focuses on the corrective
A follow-up audit is commissioned to check on actions agreed during the audit and closing
progress against the issues found at an earlier meeting of the previous audit. It is essential that
audit. It is important that the agreed CAPR from the site has an understandable copy of the CAPR,
the previous audit is used as the basis of any where relevant. It is also good practice to send an
follow-up audit. additional copy of the previous CAPR to the site
ahead of the follow-up audit as a reminder of what
was discussed and agreed. This should be sent
actions can be carried out by a re-visit to the site
along with any pre-audit information, and should
to examine the actions that have been taken in
be received by the site at least 2 weeks before the
response to non-compliances from a previous
follow-up audit.
audit. This is known as a follow-up audit and it can
be full or partial (see ‘5.3 Sequence of Audits’ for The opening meeting of any follow-up audit
details). should focus on the previous CAPR, when it is
available. The auditor and the site should use the
A follow-up audit is required when corrective
CAPR to guide the follow-up audit process. The
following points should be kept in mind:

The site should be given the opportunity to

For corrective actions related to wages and hours,
describe and show what actions have been
completed in line with the agreed CAPR.
a minimum of 2 months’ new records need to be
available for review. The auditor will be responsible for verifying
what actions have been taken and recording
The auditor days and sampling numbers needed
to verify follow-up e.g. for wages or working hours,
Where a follow-up audit is required, for
guidance, see 6.5.3.2 ’Auditor Days and Sample example on issues relating to working hours
Size for a Partial Follow-up Audit Process’. and wages or where the original issue was
raised by workers, the site should have already
A desktop review or a desktop follow-up can
been informed that the length of time taken at
be used to verify information remotely such as
the follow-up will be related to the number and

Note: The SSF has suggested examples of issues

When only one auditor is taking the role
of both auditor and worker interviewer at
‘SMETA Guide to Non-Compliance’ on the Sedex
the follow-up audit, it may be necessary to
Advance Knowledge Hub for further information. If in
consider the auditor’s gender, especially if
doubt, it may be necessary to check with the audit
there is a majority gender at the site.
requestor.
For corrective actions, where it is judged that

will review evidence submitted.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

9.1.2 Follow-up Audit Reports 9.1.3 Guidance for Follow-up and

The follow-up audit report is an updated version Desktop Audits
of the original audit report with all new elements Please see ‘5.3 Sequence of Audits’
highlighted so they can be clearly seen. Where of Follow-up and Desktop Audits.
several follow-ups are completed the SSF
Follow-up audits are recommended for non-
used for the 1st follow-up, 2nd follow-up etc. The compliances for which corrective actions can only
number of interviews conducted and the sampling be evaluated through interviews and extensive
method used must be clearly stated. documentation reviews and/or site tour.

For all sections in which non-compliances have 9.1.3.1 A full follow-up audit should include a
previously been raised, there should be a clear full review of all areas of the standard
explanation of the evidence reviewed, comments audit process, including the complete
re-sampling of documents, conducting
issue is now considered: interviews and the employment site tour.
The auditor should focus on identifying
changes that address issues raised in the
to bring about an adequate resolution of the initial audit report by using the previous
non-compliance. CAPR, but should also investigate potential
additional issues.
and the non-compliance remains active. 9.1.3.2 The audit should be carried out either
once the deadline for addressing all of the
Progress made – some evidence has been
issues has passed or where urgent actions
received indicating progress, but this is
are necessary to safeguard the safety of
workers.
until further evidence has been made available.
9.1.3.3 Partial follow-up audits generally take
Note: If new non-compliances are found, these
place within six months of the date of
should also be indicated and be highlighted as in an
the initial audit. This can vary – it may be
initial audit. A new CAPR should be issued.
necessary to check with clients.

9.1.3.4 A partial follow-up audit does not include

a full review but only focuses on the issues

9.1.3.5 A desktop follow-up may be used to verify

corrective actions for which it is agreed that
remote approval of evidence submitted by

follow-up cannot be used where corrective

testimony.

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 Sedex Members Ethical Trade Audit (SMETA) Best Practice Guidance (Version 6.0, April 2017)

9.1.4 Follow-up by Training SMETA methodology states that when the CAPR
has been agreed, typically it is not possible to
Where supply chains decide that appropriate
raise objections afterwards. However, there
follow-up will contain some training of supplier
may be cases in which further objections
sites, care must be taken to ensure that there is no
are accepted, such as when information has

The team that conducts an audit should not be of employment has questions that remain
the same team that provides training. This would unanswered, or if the concerns reference the
lead to concerns about the objectivity of the audit recorded information.
team and subsequently the accuracy of the audit
essential that the auditor/audit company has a
system in place to deal with such questions or
potential disputes.
9.2 Appeals and Disputes
The auditor or audit company should clearly
Audit companies must have a system of appeal communicate to the site that:
for sites that, after consideration, believe that
some information has been misunderstood. They and/or their organisation are available
Appeals and disputes should primarily be made after the audit to further clarify or explain
to the audit company (although it may be to the decisions to the employment site and/or audit
auditor directly or another external organisation). requestor as needed.
The site must be provided with a contact with
whom they can communicate following the audit
process.. employment site or audit requestor wish to

The SMETA Audit Report and CAPR remain the complaint by the employment site against the
property of the audit requestor and will only be auditor.
shared with other parties by pre-agreement with
the audit requestor.

The assignment of rights to upload and access

the audit details on the Sedex platform remains
within the control of the audit requestor. Although
Sedex recommends that the auditor uploads the
audit information onto the Sedex system, the audit
requestor retains access rights.

SMETA methodology recommends that an auditor

by the site management, however if agreement

cannot be achieved, it is recommended that the
site management signs in the dispute box of the
CAPR and states their reasons why agreement was
not reached.

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 Note: In addition, there are opportunities on the Sedex
system to both dispute the information uploaded as well as
have an online dialogue with the auditor/audit company.

Anyone observing a SMETA audit can complete a short

questionnaire that allows them to give feedback on the
quality of the SMETA audit. This can be found by following
the link at the end of the CAPR.

This SMETA Best Practice Guidance (BPG) should be

used in conjunction with SMETA Measurement Criteria.
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