Version 6.

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Audit Details
Sedex Company ZC: 1024761 Sedex Site Reference: ZS: 1015350
Reference: (only available on Sedex
(only available on Sedex System)
System)

Business name Noman Terry Towel Mills Ltd.

(Company name):
Site name: Noman Terry Towel Mills Ltd.
Site address: Purbo Vawal, Country: Bangladesh
(Please include full Mirzapur, Gazipur
address) Sadar, Gazipur-1703
Site contact and job Md. Sultan Salah Uddin, AGM (Compliance)
title:
Site phone: +8801719435260 & Site e–mail: salahuddin.com@nttml.com
+8801701212545
SMETA Audit Pillars: Labour Health & Environment Business Ethics
Standards Safety (plus 4-pillar
Environment 2-
Pillar)
Date of Audit: 19th & 20th April, 2022

Audit Company Name & Logo:

Report Owner (payer):

Noman Terry Towel Mills Ltd.

GSCS International Ltd.

Audit Conducted By

Affiliate Audit Purchaser

Company Retailer

Brand owner NGO Trade Union

Multi– Combined Audit (select all that apply)

stakeholder

If you have any concerns or queries about this SMETA report or the associated SMETA
audit, please contact grievance@sedex.com.

To confirm the validity of this report, please visit

https://www.sedex.com/audit-verifier/

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Audit Content:
(1) A SMETA audit was conducted which included some or all of Labour Standards, Health &
Safety, Environment and Business Ethics. The SMETA Best Practice Version 6.1 was applied.
The scope of workers included all types at the site e.g. direct employees, agency workers,
workers employed by service providers and workers provided by other contractors. Any
deviations from the SMETA Methodology are stated (with reasons for deviation) in the
SMETA Declaration.

(2) The audit scope was against the following reference documents
2-Pillar SMETA Audit
• ETI Base Code
• SMETA Additions
• Universal rights covering UNGP
• Management systems and code implementation,
• Responsible Recruitment
• Entitlement to Work & Immigration,
• Sub-Contracting and Home working,
4-Pillar SMETA
• 2-Pillar requirements plus
• Additional Pillar assessment of Environment
• Additional Pillar assessment of Business Ethics
• The Customer’s Supplier Code (Appendix 1)

(3) Where appropriate non-compliances were raised against the ETI code / SMETA Additions
& local law and recorded as non-compliances on both the audit report, CAPR and on
Sedex.

(4) Any Non-Compliance against customer code shall not be uploaded to Sedex. However,
in the CAPR these ‘Variances in compliance between ETI code / SMETA Additions/ local
law and customer code’ shall be noted in the observations section of the CAPR.

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SMETA Declaration
I declare that the audit underpinning the following report was conducted in accordance
with SMETA Best Practice Guidance and SMETA Measurement Criteria.

(1) Where appropriate non-compliances were raised against the ETI code / SMETA Additions & local law
and recorded as non-compliances on both the audit report, CAPR and on Sedex.

(2) Any Non-Compliance against customer code alone shall not be uploaded to Sedex. However, in
the CAPR these ‘Variances in compliance between ETI code / SMETA Additions/ local law and
customer code’ shall be noted in the observations section of the CAPR.

Any exceptions to this must be recorded here (e.g. different sample size): Nil

Auditor Team (s) (please list all including all interviewers):

Lead auditor: Md. Hasan (RA 21703925)
Lead auditor APSCA status: In good standing
Team auditor: Md. Mehadi Hassan (ASCA 21704658) and Naznin Kabir Tithi (ASCA
21704432)

Interviewers: Md. Hasan (RA 21703925), Md. Mehadi Hassan (ASCA 21704658) and Naznin
Kabir Tithi (ASCA 21704432)

Report writer: Md. Hasan

Report reviewer: Farida Parvin

Date of declaration: 20th April, 2022

Note: The focus of this ethical audit is on the ETI Base Code and local law. The additional elements will not be audited in
such depth or scope, but the audit process will still highlight any specific issues.

This report provides a summary of the findings and other applicable information found/gathered during the social audit
conducted on the above date only and does not officially confirm or certify compliance with any legal regulations or
industry standards. The social audit process requires that information be gathered and considered from records review,
worker interviews, management interviews and visual observation. More information is gathered during the social audit
process than is provided here. The audit process is a sampling exercise only and does not guarantee that the audited
site prior, during or post–audit, are in full compliance with the Code being audited against. The provisions of this Code
constitute minimum and not maximum standards and this Code should not be used to prevent companies from
exceeding these standards. Companies applying this Code are expected to comply with national and other
applicable laws and where the provisions of law and this Code address the same subject, to apply that provision which
affords the greater protection. The ownership of this report remains with the party who has paid for the audit. Release
permission must be provided by the owner prior to release to any third parties.

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Summary of Findings
Area of Non–Conformity Findings
Issue (Only check box when there is a non– Record the number (note to auditor, summarise in as few words as
(please click on the issue title to go direct conformity, and only in the box/es where the of issues by line*: possible NCs, Obs and GE)
to the appropriate audit results by clause) non–conformity can be found)
Note to auditor, please ensure that when issuing
the audit report, hyperlinks are retained. ETI Base Additional Customer NC Obs GE
Local Law
Code Elements Code

0A Universal Rights covering UNGP 0 0 None Observed

0B Management systems and 01 0 03 Summary of Non-compliance:

code implementation 1. The workers were not aware of the ETI code of
conduct. Noted that the facility arranged the
training on ETI code of conduct, but which was
not well effective to the workers.

Summary of Good Examples:

1. The factory management had repaired 2 km
road for local community.

2. The factory management had constructed a

Mosque for Muslim community.

3. The factory arranges Hepatitis-B Vaccination

Program for all employees with the coordination
of Incepta & Popular Centre.

1. Freely chosen Employment 0 0 0 None Observed

2 Freedom of Association 0 0 0 None Observed

3 Safety and Hygienic Conditions 03 0 0 Summary of Non-compliances:

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1. Around 60% of eye guards with overlock

machines were found misplaced at sample
sewing section of 1st floor of the building-1.

2. a) Around 40% workers were not using

earplugs while working at texpa hamming
sections of 5th floor & 6th floor of the building-1.
b) Around 40% workers were not using earplugs
while working at sizing section of the shed-1.
c) Around 35% workers were not using earplugs
while working at warping section of the shed-1.
d) Around 30% workers were not using earplugs
while working at twisting section of the shed-5.
e) around 85% heavy trolley loaders were not
using safety shoes while moving trolleys one
process to another process inside the factory
premises.

3. (a) Approximately 45% of the firefighters &

rescuers were not properly aware about the
types of fire extinguishers, types of fire, uses of
fire equipment, rescue procedures and his/her
duties during fire.
(b) Approximately 35% of the first aiders were
not well aware about first aid medicines, kits and
preliminary treatment procedures.

4 Child Labour 0 0 0 None Observed

5 Living Wages and Benefits 0 0 03 Summary of Good Examples:

1. The factory provides attendance bonus BDT
500 for all workers as per factory policy.

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2. The factory provides free educational

resources to the adult workers for adult
education program.

3. The factory provides new born baby gift to all

the new mothers.

6 Working Hours 0 0 0 None Observed

7 Discrimination 0 0 0 None Observed

8 Regular Employment 0 0 0 None Observed

8A Sub–Contracting and 0 0 0 None Observed

Homeworking

9 Harsh or Inhumane Treatment 0 0 0 None Observed

10A Entitlement to Work 0 0 0 None Observed

10B2 Environment 2-Pillar NA NA NA Not applicable as it is a 4-Pillar Audit

10B4 Environment 4–Pillar 01 0 03 Summary of Non-compliance:

1. Waste water test report was expired on 23rd
January 2022. Noted that the facility had
already applied to the concerned authority for
conducting waste water test on 7th March, 2022.

Summary of Good Examples:

1. The factory has installed 200 kWh solar panels,
which are being used in entire stitching building.

2. The factory has implemented rainwater

harvesting system, which is reducing
groundwater extraction.

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3. The factory is using less water consuming Dyes

chemicals in production process, which are
reducing water consumption.

10C Business Ethics 0 0 0 None Observed

General observations and summary of the site:

Noman Terry Towel Mills Ltd was located at Purbo Vawal, Mirzapur, Gazipur Sadar, Gazipur-1703, Bangladesh. The site was established in the year of 2012. This
periodic audit was conducted by three auditors, assessed the factory operation against ETI base code and Local law requirements on a sampling basis in
two days. The scope of this audit was based on 4-Pillar SMETA systems.
The factory specialized in manufacturing of all kinds of Terry Towels. Main Process is Yarn Dyeing, Yarn Dyeing Finishing, Warping, Sizing, Weaving, Terry Dyeing,
Terry Dyeing Finishing, Cutting, Sewing, Embroidery, Finishing & Packing. The total factory area was around 1,356,644.687 square feet and the production
area was around 763,009.15 square feet. The factory has no obvious peak/ off peak season. Production capacity is around 2,400 ton per month.
In view of facilities, the factory has 05 buildings & 12 sheds.
Total man power of the factory is 6,998. On the day of audit, there were 6,545 workers (Male-3,500 & Female-3,045) in the factory in which 5,818 production
workers and 727 non-production workers. All workers were local. Weekend of the factory is as per rotation basis. The general working hours of the facility has
four shifts e.g. ‘G’ Shift-1 starts from 08:00 to 17:00, ‘G’ Shifts-2 starts from 09:00 to 18:00, ‘G’ Shifts-3 starts from 11:00 to 20:00 with 60 minutes meal break for
each shifts & roster weekend and G’ Shifts-4 (only for Ramadan Month) starts from 6:30 to 15:00 with 60 minutes break and roster weekend of this shift. There
are double shifting working hours in a day of the facility e.g. Shift-1 starts from 08:00 to 17:00, Shift-2 starts from 20:00 to 5:00, Shift-3 starts from 09:00 to 18:00
and Shift-4 starts from 21:00 to 6:00 with 60 minutes break and roster weekend for each shift. There are triple shifting working hours in a day of the facility e.g.
Shifts-1 starts from 06:00 to 14:30, Shift-2 starts from 14:00 to 22:30, Shift-3 starts from 22:00 to 06:30, Shifts-4 starts from 05:00 to 13:30, Shift-5 starts from 13:00 to
21:30 and Shift-6 starts from 21:00 to 05:30 with 30 minutes break & roster weekend for each shift. Security has three shifts per eight hours each with roster break
& weekend.
Auditors entered the facility at 09:40 on 19 April 2022 and conducted an opening meeting with facility management as per the ETI Base Code. Workers
representative was present in the meeting and they assured full co-operation to this audit.
Based on documents review, employees’ interview and site tour, the positive and negative findings are as follows:
1. The factory provided company registration No. C-80010/09, with life time validity started from 07th October, 2009.
2. All employees were recruited directly by the factory. All of the employees provided the copy of their personal ID cards, birth certificate, and educational
certificate (if any) and characterize certificate to the factory before they started working. Both copy of ID cards, birth certificate, educational certificate,
characterize certificate and latest individual photos are kept properly in their personnel files.

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3. The emergency evacuation floor plan was posted on the wall of each floor.
4. No child labour or young worker was found during audit.
5. Neither migrant workers nor agency workers were found in the facility.
6. No forced labour, discrimination & harsh or inhumane treatment were found during the audit.
7. Suggestion boxes were available for employees to complain or feedback their working condition. Also, they could communicate with their supervisors, top
management directly and through worker representatives.
8. The factory conducted fire drill that included fire extinguishers exercise and evacuation exercise every month at production area.
9. Md. Abdus Sattar, Asst. Manager (Fire & Safety) is responsible for Health & Safety.
10. Total 62 workers [twenty-two (22) individual workers and forty (40) - eight groups of five workers] were interviewed in the confidential room. Employees’
attitudes were positive and polite during the audit and employees showed the favourable attitude toward the factory via workers interviews. Note: Covid-19
pandemic situations going through all over the world. In that case, we have to manage our activities by maintaining our safety. When we conducted workers
interview, everyone maintains social distance. We also noticed that all the workers in the factory were aware of all those things about what they need to be
concerned during this corona period. Also, the factory has formed own task force, SOP, risk assessments about Covid-19. They are monitoring these issues
regularly.
11. Fire-fighting facilities were well equipped.
12. Drinking water and toilet were available and accessed easily.
13. Per payroll record review and interviews with management all workers were paid by monthly wage system. Wages were paid once a month within first 7
working days of the following pay period. All the employees’ wages were paid by bank & Mobile Banking System (Rocket). No delay of wage was identified
through documents review, worker interview and management interview.
Negative findings:
One non- compliance was found in the area of “Management systems and Code implementation”, three non- compliances were found in the area of “Safety
and Hygienic Conditions” & one non- compliance was found in the area of “10B4: Environment 4–Pillar”. For other areas, no violations were noted.
Good examples:
Three good examples were found in the area of “Management systems and Code implementation”, three good examples were found in the area of “Living
Wages Are Paid” & three good examples were found in the area of “Environment 4-Pillar”.
The closing meeting was started at 16:45 on 20 April 2022 and corrective action plan was discussed. A copy of the CAP was given to Md. Sultan Salah Uddin,
AGM (Compliance). Auditors thanked for good cooperation & behaviour, organization and friendly working environment and left company at 17:15 on 20
April 2022.

*Please note the table above records the total number of Non-compliances (NC), Observations (Obs) and Good Examples (GE). This gives the reviewer an
indication of problem areas but does not detail severities of each issue – Reviewers need to check audit results by clause.

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Site Details
Site Details

A: Company Name: Noman Terry Towel Mills Ltd.

B: Site name: Noman Terry Towel Mills Ltd.

C: GPS location: Purbo Vawal, Mirzapur, Latitude: 24.085479

(If available) Gazipur Sadar, Gazipur-1703, Longitude: 90.358116
Bangladesh

D: Applicable business and other Factory License No. 15637/Gazipur, issued by Bangladesh
legally required licence numbers and Government, which is valid till on 30th June, 2022.
documents, for example, business
license number, liability insurance, any Trade License No. 162432000160, issued by Mirzapur Union
other required government inspections Parishad, which is valid till on 30th June, 2022.

Fire License No. DD/DHAKA/22270/2010, issued by Bangladesh

Fire Service & Civil Defence, which is valid till on 30th June, 2022.

Certificate of Incorporation No. C-80010/09 with life time validity

started from 7th October, 2009.

E: Products/Activities at site, for The factory specialized in manufacturing of all kinds of Terry
example, garment manufacture, Towels.
electricals, toys, grower, cutting,
sewing, packing etc The main production process is Yarn Dyeing, Yarn Dyeing
Finishing, Warping, Sizing, Weaving, Terry Dyeing, Terry Dyeing
Finishing, Cutting, Sewing, Embroidery, Finishing & Packing.

F: Site description: Noman Terry Towel Mills Ltd was located at Purbo Vawal,
(Include size, location, and age of site. Mirzapur, Gazipur Sadar, Gazipur, Bangladesh. The site was
Also, include structure and number of established in the year of 2012. The total factory area was
buildings) 1,356,644.687 square feet and the production area was
763,009.15 square feet.

In view of facilities, the factory has 05 buildings & 12 sheds. Floor

wise descriptions are as under:

Building Description:
Building No. 01 Description Remark, if any
Finished goods
store, medical
Ground Floor room, child care Nil
room & loading
area.
Sample sewing
section, cutting
First Floor section, finishing Nil
section & office
room.

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Cutting section,
Second Floor finishing section & Nil
office room.
Cutting section &
Third Floor Nil
finishing section.
Fourth Floor Fabric roll store. Nil
Cutting section &
Fifth Floor Nil
finishing section.
Cutting section &
Sixth Floor Nil
finishing section.
Temporary Dining
Seventh Floor hall & training Nil
room.
Is this a shared
No Nil
building?

Building No. 02 Description Remark, if any

Ground Floor Embroidery Nil
section.
First Floor Accessories store. Nil
Is this a shared
No Nil
building?

Building No. 03 Description Remark, if any

Ground Floor Office room. Nil
First Floor Lab Nil
Is this a shared
No Nil
building?

Building No. 04 Description Remark, if any

Ground Floor Boiler room & Nil
generator.
First Floor Compressor room, Nil
exhaust boiler &
chiller plant.
Rooftop Cooling tower for Nil
generator.
Is this a shared
No Nil
building?

Building No. 05 Description Remark, if any

Ground Floor Chemical store, Nil
grey fabrics store
& yarn store.
First Floor Yarn store & Nil
general store.
Is this a shared
No Nil
building?

Shed No. 01:

Sizing section & warping section.

Shed No. 02:

Multipurpose storage.

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Shed No. 03:

Terry weaving, grey fabric inspection & terry dyeing.

Shed No. 04:

Chemical store.

Shed No. 05:

Twisting section, hard winding section & soft winding section.

Shed No. 06:

Yarn dyeing section.

Shed No. 07:

Dining hall.

Shed No. 08:

ETP area.

Shed No. 09:

Buster fire hydrant pump.

Shed No. 10:

Ground Floor: New finished goods store, accessories store.
Mezzanine Floor: Finished goods store.

Shed No. 11:

Temporary carpenter, mason, thai fitter & plumber room.

Shed No. 12:

Temporary wastage area.

F1: Visible structural integrity issues (large cracks) observed?

Yes
No
F2: Please give details: No visible large cracks were observed on
the day of audit.

F3: Does the site have a structural engineer evaluation?

Yes
No
F4: Please give details: The site has a structural engineer
evaluation form Alliance & Accord.

G: Site function: Agent

Factory Processing/Manufacturer
Finished Product Supplier
Grower
Homeworker
Labour Provider
Pack House
Primary Producer
Service Provider
Sub–Contractor

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H: Month(s) of peak season: Round the year same.

(if applicable)

I: Process overview: Production Capacity: The production capacity is around 2,400

(Include products being produced, main ton per month.
operations, number of production lines,
main equipment used) Main Product: The factory specialized in manufacturing of all
kinds of terry towels.

The Main production process: The main production process is

dyeing, Yarn Dyeing Finishing, Warping, Sizing, Weaving, Terry
Dyeing, Terry Dyeing Finishing, Cutting, Sewing, Embroidery,
Finishing & Packing.

Main Equipment: Yarn Dyeing machine= 42 sets, Soft. W(Fadish)

machine= 6 sets, Soft. W(SSM) machine= 4 sets, Hard. W(Faddish)
machine= 15 sets, Hard. W(SSM) Machine= 01 set, Hydro
machine= 03 sets, RF Dryer machine= 03 sets, Utility machine:
generator= 10 sets, boiler= 08 sets, compressor= 15 sets, chiller
machine= 05 sets, AC plant= 08 sets, terry Dyeing machine= 28
sets, Loop Dryer machine= 04 sets, Anglada (Dryer) machine= 04
sets, Pentek(T.D) machine= 02 sets, Shearing machine= 01 sets,
Hydro machine= 08 sets, Roof Opener machine= 04 sets,
Weaving machines: Tsudakoma 9200i Master Terry (2017)= 20
sets, Tsudakoma Zax-210= 217 sets, Tsudakoma Professional= 101
sets, Toyota-280(T710) machine= 06 sets, Dornier Jacquard
Double machine= 06 sets, Dornier Jacquard Single machine= 06
sets, Picanol Terry Plus Jacquard Single machine= 01 set, Picanol
Terry Plus Jacquard Double machine= 01 set, Picanol Terry Plus
machine= 02 sets, Stitching machine: Single Needle Sewing
machine= 1011 sets, Two Needle machine= 63 sets, O.L (3
Thread) C.S (Manual) machine= 28 sets, O.L (5 Thread) C.S
(Manual) machine= 68 sets, Flat Lock machine= 10 sets, Kansari
C.S (Manual)= 08 sets, Vertical Single Needle L.S (Manual)= 40
sets, Bartack machine= 07 sets, Bottom Attach machine= 01 sets,
Bottom Hole machine= 01 sets, Others Stitching machines: Texpa
Long Cutting machine= 03 sets, Texpa Long Hemming Two
Needle= 04 sets, Texpa Long Hemming Single Needle= 08 sets,
Hasima= 08 sets, Hasima Hand Needle Detector= 03 sets, Auto
Printed label Cutting machine= 01 set, math Cutting machine=
06 sets, Rib Cutting machine= 01 set, Wrapping machine= 01 set,
Bail Press machine= 02 sets, I lot machine= 02 sets, Auto Tag Gan
machine= 01 set, Number Sticker machine= 11 sets, Heat Sealing
machine= 08 sets, Auto CAD GTR machine= 02 sets, Embroidery
(Jintel) machine= 06 sets, direct warping machine= 11 sets,
Sectional warping Machine= 02 sets, Sizing machine= 10 sets,
Muratec(Doubler) machine= 02 sets, PS Versa(Doubler)
machine= 01 sets, SSM(Doubler) machine= 01 sets,
Volkmann(TFO) machine= 17 sets, Muratec(TFO) machine= 12
sets.

J: What form of worker representation / Union (name)

union is there on site? Worker Committee
Other (specify)
None

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K: Is there any night production work at Yes

the site? No

L: Are there any on site provided worker Yes

accommodation buildings e.g. No
dormitories L1: If yes, approx. % of workers in on site accommodation

M: Are there any off site provided Yes

worker accommodation buildings No
M1: If yes, approx. % of workers- Approximately 7% of total
workers live in factory off site accommodation building.

N: Were all site-provided Yes

accommodation buildings included in No
this audit N1: If no, please give details: Not applicable

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Audit Parameters

A: Time in and time out Day 1 Time in: 09:40 Day 2 Time in: 09:30 Day 3 Time in: NA
Day 1 Time out: 17:20 Day 2 Time out: 17:15 Day 3 Time out: NA

B: Number of auditor days used: 4.5 Man-days (3 Auditors in 2 days)

C: Audit type: Full Initial

Periodic
Full Follow–up
Partial Follow–Up
Partial Other
If other, please define:

D: Was the audit announced? Announced

Semi – announced: Window detail: 4 weeks
Unannounced

E: Was the Sedex SAQ available for Yes

review? No
If No, why not

F: Any conflicting information Yes

SAQ/Pre-Audit Info to Audit No
findings? If Yes, please capture detail in appropriate audit by clause

G: Who signed and agreed CAPR Md. Sultan Salah Uddin, AGM (Compliance)
(Name and job title)

H: Is further information available Yes

(If yes, please contact audit company No
for details)

I: Previous audit date: 6th May, 2021

J: Previous audit type: Periodic (2-Plilar)

K: Were any previous audits Yes No

reviewed for this audit
N/A

Audit attendance Management Worker Representatives

Senior Worker Committee Union

management representatives representatives

A: Present at the opening meeting? Yes No Yes No Yes No

B: Present at the audit? Yes No Yes No Yes No

C: Present at the closing meeting? Yes No Yes No Yes No

D: If Worker Representatives were not Not applicable, worker representative was present.
present please explain reasons why
(only complete if no worker reps present)

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E: If Union Representatives were not The facility has no trade union and it is not required by local law.
present please explain reasons why:
(only complete if no union reps present)

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Worker Analysis
The term "migrant worker" refers to a person who is engaged or has been engaged in a remunerated activity in a country of which they are not a national or
permanent resident or has purposely migrated on a temporary basis to another in-country region to seek and engage in a remunerated activity.

Worker Analysis

Local Migrant*
Total

Permanent Temporary Agency Permanent Temporary Agency Home workers

Worker numbers –
3849 0 0 0 0 0 0 3849
Male

Worker numbers –
3149 0 0 0 0 0 0 3149
female

Total 6998 0 0 0 0 0 0 6998

Number of Workers
34 0 0 0 0 0 0 34
interviewed – male

Number of Workers
28 0 0 0 0 0 0 28
interviewed – female

Total – interviewed
62 0 0 0 0 0 0 62
sample size

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A: Nationality of Management Bangladeshi

B: Please list the nationalities of all Nationalities: Was the list completed during peak season?
workers, with the three most common B1: Nationality 1: __Bangladeshi__ Yes
nationalities listed first. B2: Nationality 2: ____NA____ No
Please add more nationalities as applicable to B3: Nationality 3: ____NA____
site. Add more rows if required.
If no, please describe how this may vary during
peak periods: Not Applicable

C: Please provide more information for C: approx % total workforce: Nationality 1 __100%___ Bangladeshi_____
the three most common nationalities. C1: approx % total workforce: Nationality 2 ___0%_____
C2: approx % total workforce: Nationality 3 ___0%_____

D: Worker remuneration D: ___0____% workers on piece rate

(management information) D1: __0____% hourly paid workers
D2: __100__% salaried workers

Payment cycle:
D3: ___0____% daily paid
D4: ___0____% weekly paid
D5: __100___% monthly paid
D6: ___0____% other
D7: If other, please give details: Not Applicable

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Worker Interview Summary

A: Were workers aware of the audit? Yes

No

B: Were workers aware of the code? Yes

No

C: Number of group interviews: Total group interviews 40 workers (08 group of

(Please specify number and size of groups. Please see SMETA 05 workers)
Best Practice Guidance and Measurement Criteria. If the
auditor was not able to follow the BPG, please state within the
declaration)

D: Number of individual interviews D1: Male: 12 D1: Male: 10

(Please see SMETA Best Practice Guidance and Measurement
Criteria)

E: All groups of workers are included in the scope of this Yes

audit such as; Direct employees, Casual and agency No
workers, Workers employed by service providers such as
security and catering staff as well as workers supplied by If no, please give details: Not Applicable
other contractors.
Note to auditor: please record details of migrant /agency/contractor
workers in section 8 – Regular Employment, under Responsible
Recruitment

F: Interviews were done in private and the confidentiality Yes

of the interview process was communicated to the No
workers?

G: In general, what was the attitude of the workers Favourable

towards their workplace? Non–favourable
Indifferent

H: What was the most common worker complaint? No complaint was raised by any sample
workers against facility because they were
happy with their working environment.

I: What did the workers like the most about working at this Facility workplace condition is comfortable,
site? timely payment of wages and benefit. Good
relationship with facility management.

J: Any additional comment(s) regarding interviews: Nothing to Report.

K: Attitude of workers to hours worked: Total working hour is within standard and
overtime is fully voluntary.

L. Is there any worker survey information available?

Yes
No
L1: If yes, please give details: Facility conducts worker survey once in a year on grievance, disciplinary &
discrimination.

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M: Attitude of workers:
(Include their attitude to management, workplace, and the interview process. Both positive and negative information should be
included) Note: Do not document any information that could put workers at risk

The factory allowed the auditors from GSCS International Ltd. to conduct confidential worker interviews. The
workers were chosen freely without any influence by the factory management: 62 workers (08 groups of 05
workers and 22 individuals) were randomly selected by auditor from different sections for interview. The
workers showed a cooperative attitude during the interview process. Based on workers interview, they
expressed their positive attitude to the management and payment system. All workers were satisfied with
working conditions and benefits.

The effective evidences were collected by workers’ interview; the following information was summarized:
1. Workers said that they were not required to lodge “deposits” or their identity cards at the recruitment and
were free to leave or resign after reasonable notice.
2. All interviewees reflected that worker could complain to management or worker committee
representatives directly or by writing letters through suggestion box and all interviewed workers were aware
of workers’ representatives.
3. All workers stated that factory provided induction training for new workers and regular safety training for
all workers. Workers said they had participated in fire drills at the production area every month, and most of
them knew how to use the fire equipment.
4. All interviewees confirmed that the factory had checked their ID cards or birth certificate to verify their
ages. They never seen or heard any child labour less than 18 years old employed in this factory.
5. All interviewed workers said that they were paid by monthly wage system. Wages were paid once a
month within first 07 working days of the following pay period. All the employees’ wages were paid by bank
& Mobile Banking System (Rocket). No delay of wage was identified through worker interview and
management interview.
6. All workers were local. Weekend of the factory is as per rotation. The general working hours of the facility
has four shifts e.g. ‘G’ Shift-1 starts from 08:00 to 17:00, ‘G’ Shifts-2 starts from 09:00 to 18:00, ‘G’ Shifts-3 starts
from 11:00 to 20:00 with 60 minutes meal break for each shifts & roster weekend and G’ Shifts-4 (only for
Ramadan Month) starts from 6:30 to 15:00 with 60 minutes break and roster weekend of this shift. There are
double shifting working hours in a day of the facility e.g. Shift-1 starts from 08:00 to 17:00, Shift-2 starts from
20:00 to 5:00, Shift-3 starts from 09:00 to 18:00 and Shift-4 starts from 21:00 to 6:00 with 60 minutes break and
roster weekend for each shift. There are triple shifting working hours in a day of the facility e.g. Shifts-1 starts
from 06:00 to 14:30, Shift-2 starts from 14:00 to 22:30, Shift-3 starts from 22:00 to 06:30, Shifts-4 starts from 05:00
to 13:30, Shift-5 starts from 13:00 to 21:30 and Shift-6 starts from 21:00 to 05:30 with 30 minutes break & roster
weekend for each shift. Security has three shifts per eight hours each with roster break & weekend.
7. The interviewed workers said that they could obtain the job based on their working experiences and
abilities. The female workers or male workers’ wages were calculated at the same for the same work based
on their performance.

N: Attitude of worker’s committee/union reps:

(Include their attitude to management, workplace, and the interview process. Both positive and negative information
should be included) Note: Do not document any information that could put workers at risk

During Interview, the workers representatives expressed that the facility management was nice to them,
they could freely express their opinions, will, advice and suggestion without any fear or concern and they
could make grievance if necessary. No negative information was observed during the audit.

O: Attitude of managers:
(Include attitude to audit, and audit process. Both positive and negative information should be included)

The management was found to be well versed with the requirements of social audit, management was very
co-operative and transparent during the course of the audit. They were receptive towards findings. The
management approach was found to be positive.

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Audit Results by Clause

0A: Universal Rights covering UNGP
(Click here to return to summary of findings)

0.A. Guidance for Observations

0.A.1 Businesses should have a policy, endorsed at the highest level, covering human rights impacts and
issues, and ensure it is communicated to all appropriate parties, including its own suppliers.
0.A.2 Businesses should have a designated person responsible for implementing standards concerning
Human rights
0.A.3 Businesses shall identify their stakeholders and salient issues.
0.A.4 Businesses shall measure their direct, indirect, and potential impacts on stakeholders (rights holders)
human rights.
0.A.5 Where businesses have an adverse impact on human rights within any of their stakeholders, they
shall address these issues and enable effective remediation.
0.A.6 Businesses shall have a transparent system in place for confidentially reporting, and dealing with
human rights impacts without fear of reprisals towards the reporter.

Note for auditors and readers. This is not a full Human Rights Assessment, but instead a check on
the business’s implementation of processes to meet their Universal rights covering UNGP
responsibilities.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what releva nt
procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
• The facility had a policy, endorsed at the highest level, covering human rights impacts and issues,
and it is communicated to all appropriate parties, including its own suppliers.
• The responsible person for implementation and monitoring is Md. Sultan Salah Uddin- AGM
(Compliance).
• The facility measured their direct, indirect, and potential impacts on stakeholders (rights holders)
human rights.
• Where businesses have an adverse impact on human rights within any of their stakeholders, they
address these issues and enable effective remediation.
• The facility had a transparent system in place for confidentially reporting, and dealing with human
rights impacts without fear of reprisals towards the report.
• The facility has policy and procedures for human rights.
• It is communicated to all appropriate parties, including suppliers through the responsible person.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. Documentation files were reviewed. It stipulates complying with Human Rights, written policies and
procedure that being provided individually to employees.
2. Letter of Authorization on implementing Human Rights
3. Impact for Human Rights assessment report
4. Management interview and employee interview

Any other comments: None

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A: Policy statement that expresses commitment to Yes

respect human rights? No
A1: Please give details: The facility had posted the
policy about respecting Human Rights in the policy
board stated that child labour shall not be used,
Forced Labour shall not be used, no discrimination is
practised, no harsh or inhumane treatment is allowed,
disciplinary action taken, working hours etc.

B: Does the business have a designated person Yes

responsible for implementing standards No
concerning Human Rights?
Please give details:
Name: Md. Sultan Salah Uddin,
Job title: AGM (Compliance)

C: Does the business have a transparent system in Yes

place for confidentially reporting, and dealing No
with human rights impacts without fear of reprisals C1: Please give details: The facility had established a
towards the reporter? transparent system in place for confidentially
reporting and dealing with human rights impacts
without fear of reprisals towards the reporter by
means of suggestion box, making the contact way of
management in policy board and public areas in the
facility.

D: Does the grievance mechanism meet UNGP Yes

expectations? (Legitimate, Accessible, No
Predictable, Equitable, Transparent, Rights- D1: If no, please give details: Not applicable
compatible, a source of continuous learning and
based on stakeholder engagement)

E: Does the business demonstrate effective data Yes

privacy procedures for workers’ information, No
which is implemented?
E1: Please give details: The facility established an
effective data privacy procedure for workers’
information to protect the workers’ privacy
information.

Findings

Finding: Observation Company NC Objective evidence

Description of observation: observed:
None Observed Not Applicable
Local law or ETI/Additional elements / customer specific requirement:
Not Applicable
Comments:
Not Applicable

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Good examples observed:

Description of Good Example (GE): Objective Evidence

None Observed Observed:
Not Applicable

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Measuring Workplace Impact

Workplace Impact

A: Annual worker turnover: A1: Last year: 2021 A2: This year: 2022
Number of workers leaving in last 12 months as a % __3.08__ % __3.41__ %
of average total number of workers on site over the
year (annual worker turnover)

B: Current % quarterly (90 days) turnover: 3.41%

Number of workers leaving from the first day of the
90 days period through to the last day of the 90
day period / [(number of employees on the 1st day
of 90 day period + number of employees on the
last day of the 90 day period) / 2]

C: Annual % absenteeism: C1: Last year: 2021 C2: This year: 2022
Number of days lost through job absence in the __4.24__ % __4.06__ %
year /
[(number of employees on 1st day of the year +
number employees on the last day of the year) / 2]
* number available workdays in the year

D: Quarterly (90 days) % absenteeism: 4.06%

Number of days lost through job absence in the
period /
[(Number of employees on 1st of the period +
Number of employees on the last day of the
period) / 2]
* Number of available workdays in the month

E: Are accidents recorded? Yes

No
E1: Please describe: The factory maintains records of major &
minor accidents and injuries regularly.

F: Annual Number of work related F1: Last year: 2021-63 F2: This year: 2022-74
accidents and injuries per 100 workers: Number: 1.05% Number: 1.23%
[(Number of work related accidents and
injuries * 100) / Number of total workers]

G: Quarterly (90 days) number of work 1.23%

related accidents and injuries per 100
workers:
[(Number of work related accidents and injuries *
100) / Number of total workers]

H: Lost day work cases per 100 workers: H1: Last year: 0 H2: This year: 0
[(Number of lost days due to work accidents and
work related injuries * 100) / Number of total
workers]

I: % of workers that work on average I1: 6 months I2: 12 months

more than 48 standard hours / week in __0__% workers __0__% workers
the last 6 / 12 months:

J: % of workers that work on average J1: 6 months J2: 12 months

more than 60 total hours / week in the __0__% workers __0__% workers
last 6 / 12 months:

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0B: Management system and Code Implementation

(Click here to return to summary of findings)

0.B.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code.
0.B.2 Suppliers are expected to be operating legally in premises with the correct business licenses and
permissions and to have systems to ensure that all relevant land rights have been complied with
0.B.3 Suppliers shall appoint a senior member of management who shall be responsible for compliance
with the Code.
0.B.4 Suppliers are expected to communicate this Code to all employees.
0.B.5 Suppliers should communicate this code to their own suppliers and, where reasonably practicable,
extend the principles of this Ethical Code through their supply chain.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers,
to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what
relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence
checked should detail any documentary or verbal evidence shown to support the systems.

Current systems:
• Responsibility for meeting the legal and client code requirements is taken Md. Sultan Salah
Uddin- AGM (Compliance).
• The workers were not aware of the ETI code of conduct. Noted that the facility arranged training
on ETI code of conduct, but which was not well effective to the workers.
• The facility communicated this code of conduct (COC) to the suppliers.
• The facility management is conducting internal social compliance audit regularly and take
necessary corrective action based on report.
• The facility arranged mid-level management training for all mid-level management employees
such as supervisors, quality in charge, production officers, etc.
• The facility conducts orientation training for all new employees.
• Implementation of any necessary changes is then given to the individual department heads
after agreement with the facility manager.

One non-compliance and three good examples were found in the areas of “Management system & Code
implementation. For details, please refer to contents of ‘Non-compliance’ and ‘Good Example’.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
• Employee handbook.
• Facility Code of Conduct (COC).
• All policies of facility.
• Legal license (Factory, Fire, Trade)
• Internal audit records.
• Management employee training, training attendance record
• Meeting records.

Any other comments: None

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Management Systems:

A: In the last 12 months, has the site been subject to Yes

any fines/prosecutions for non–compliance to any No
regulations? A1: Please give details: In the last 12 months the
site has not been subjected to any fines or
prosecutions for non-compliance to any
regulations.

B: Do policies and/or procedures exist that reduce the Yes

risk of forced labour, child labour, discrimination, No
harassment & abuse? B1: Please give details: It was noted through
documentation review, facility has policies and
procedures for reduce the risk of forced labour,
child labour, discrimination, harassment & abuse.

C: If Yes, is there evidence (an indication) of effective Through documents review and workers
implementation? Please give details. interview, the written policies (no forced labour,
no child labour, non-discrimination, working
hours, health & safety, harassment and abuse)
were communicated to the workers as much as
factory mid-level management & workers were
informed through PA system and notification
board.

D: Have managers and workers received training in Yes

the standards for forced labour, child labour, No
discrimination, harassment & abuse? D1: Please give details: All the managers and
workers in the facility have received orientation
training where standards for forced labour, child
labour discrimination are covered. However, the
facility did not provide anti-harassment training to
their workers.

E: If Yes, is there evidence (an indication) that training Yes

has been effective e.g. training records etc.? Please No
give details E1: Please give details: Training records were
found including picture and attendance sheet.

F: Does the site have any internationally recognised Yes

system certifications e.g. ISO 9000, 14000, OHSAS No
18000, SA8000 (or other social audits). F1: Please give details: The site has internationally
Please detail (Number and date). recognised system certifications e.g. BSCI, which
is valid till 7 October 2023 and ISO 28000: 2007,
which is valid till 20 March 2023, ISO 9001, 14001,
45001, which is valid till 01 November 2024 and
WRAP, which is valid till 19 January 2023.

G: Is there a Human Resources manager/department? Yes

If Yes, please detail. No
G1: Please give details: Facility has a dedicated
Human Resources department consisting 42
members and is headed by Md. Mohammad
Yasin- Executive Director.

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H: Is there a senior person / manager responsible for Yes

implementation of the code No
H1: Please give details: Responsibility for meeting
the legal and client code requirements is taken
by Md. Sultan Salah Uddin- AGM (Compliance).

I: Is there a policy to ensure all worker information is Yes

confidential? No
I1: Please give details: The factory had adopted
a policy decision where by all employees of the
company will be required to maintain
confidentiality with regard to the affairs of the
company & it's greater.

J: Is there an effective procedure to ensure Yes

confidential information is kept confidential? No
J1: Please give details: The facility has an
effective key control procedure to keep the
information confidential.

K: Are risk assessments conducted to evaluate policy Yes

and procedure effectiveness? No
K1: Please give details: Facility conducted risk
assessment evaluates effectiveness of every
policy and procedure department wise.

L: Does the facility have a process to address issues Yes

found when conducting risk assessments, including No
implementation of controls to reduce identified risks? L1: Please give details: The facility has an internal
system to raise the issue found the risk assessment
and to implement the way of reduction it.

M: Does the facility have a policy/code which require Yes

labour standards of its own suppliers? No
M1: Please give details: The facility established a
policy/code which requires labour standards of its
own suppliers.

Land rights

N: Does the site have all required land rights licenses Yes
and permissions (see SMETA Measurement Criteria)? No
N1: Please give details: Facility has building
approval from concern authority.

O: Does the site have systems in place to conduct Yes

legal due diligence to recognize and apply national No
laws and practices relating to land title? O1: Please give details: The facility has anti-
corruption committee, anti-bribery policy to
support due diligence in applying national laws
and practices relating to land title.

P: Does the site have a written policy and procedures Yes

specific to land rights. No

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If yes, does it include any due diligence the company P1: If yes, how does the company obtain FPIC:
will undertake to obtain free, prior and informed Not Applicable
consent, (FPIC) even if national/local law does not
require it

Q: Is there evidence that facility / site compensated Yes

the owner/lessor for the land prior to the facility being No
built or expanded. Q1: Please give details: The facility land is owned
by the facility owner.

Yes
R. Does the facility demonstrate that alternatives to a No
specific land acquisition were considered to avoid or R1: Please give details: Not Applicable as the
minimize adverse impacts? facility are using own land and buildings.

S: Is There any evidence of illegal appropriation of land Yes

for facility building or expansion of footprint. No
S1: Please give details: It was noted through land
ownership agreement review and management
interview that the facility did not go through
illegal appropriation of land for facility building.

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI/Additional Elements NC against Local Law observed:
NC against customer code: 1. Based on training
records review and
It was noted during training records review and workers & management workers & management
interview that the workers were not aware of the ETI code of conduct. Noted interview
that the facility arranged the training on ETI code of conduct, but which was not
well effective to the workers.

Local law and/or ETI requirement:

In accordance with Additional Elements 0.B.4: Suppliers are expected to
communicate this Code to all employees.

Recommended corrective action: It is recommended that the factory

management shall conduct awareness training on ETI base code for all the
workers and ensure the effectiveness of ETI codes among all the workers.

Action by: Md. Sultan Salah Uddin, AGM (Compliance)

Timescale: 30 Days.

Observation:

Description of observation: Objective evidence

None observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable

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Comments:
Not Applicable

Good Examples observed:

Description of Good Examples (GE): Objective evidence

observed:
1. The factory management had repaired 2 km road for local community. 1. Based on documents
review and
2. The factory management had constructed a Mosque for Muslim community. management interview

3. The factory arranges Hepatitis-B Vaccination Program for all employees with 2. Based on documents
the coordination of Incepta & Popular Centre. review and
management interview

3. Based on documents
review and workers &
management interview

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1: Freely Chosen Employment

(Click here to return to summary of findings)

ETI
1.1 There is no forced, bonded or involuntary prison labour.
1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free
to leave their employer after reasonable notice.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what releva nt
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
• The factory has a policy which prohibits forced labour and this was also available for review.
• Age verification documents (National ID card copy, educational certificate, nationality
certificates) were available in employee personal files.
• Service book is provided to every employee.
• Overtime is voluntary.
• The terms and conditions of employment state that the workers are free to leave the workplace
outside of their working hours. Facility also has a written policy regarding this.
• The facility did not require any payment for work tools, PPE, IC/staff card, training, etc.
• The facility does not use any prison labour.
• The above was confirmed in management and employees’ interviews.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. Personnel files
2. Factory policy, rules and regulations, and training records etc.
3. Resignation records
4. Factory rules
5. Employee handbook
6. Management and worker interview

Any other comments: None

A: Is there any evidence of Yes

retention of original documents, No
e.g. passports/ID’s A1: If yes, please give details and category of workers affected: Not
Applicable

B: Is there any evidence of a loan Yes

scheme in operation No
B1: If yes, please give details and category of worker affected: Not
Applicable

C: Is there any evidence of Yes

retention of wages /deposits No
C1: If yes, please give details and category of worker affected: Not
Applicable

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D: Are there any restrictions on Yes

workers’ freedom to terminate No
employment? D1: Please describe finding: Facility has a policy mentioning workers
are free to terminate employment from the facility with 60 days’
notice period.

E: If any part of the business is UK Yes

based or registered there & has a No
turnover over £36m, is there a Not applicable
published a ‘modern day slavery E1: Please describe finding: Not applicable as the yearly turnover of
statement? the factory was less than £36m.

F: Is there evidence of any Yes

restrictions on workers’ freedoms No
to leave the site at the end of the F1: Please describe finding: No evidence of any restrictions on
work day? workers freedoms to leave the site at the end of the workday.

G: Does the site understand the Yes

risks of forced / trafficked / No
bonded labour in its supply chain Not applicable
G1: If yes, please give details and category of workers affected: The
facility established a policy about forbidden of forced / trafficked /
bonded labour and implemented strict management system to
control the risk of forced / trafficked / bonded labour in its supply
chain. The facility sent agreement of commitment to its suppliers, and
operated social responsibility audit on suppliers to control the risk of
forced / trafficked / bonded labour in its supply chain.

H: Is the site taking any steps Yes

taking to reduce the risk of forced No
/ trafficked labour? H1: Please describe finding: Factory had provided training and
awareness session to all employees to reduce the risk of forced /
trafficked labour.

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law: NC against customer observed:
code: Not Applicable
Not Applicable
Local law and/or ETI requirement
Not Applicable
Recommended corrective action:
Not Applicable

Observation:

Description of observation: Objective evidence

None observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

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Good Examples observed:

Description of Good Example (GE): Objective evidence

None Observed observed:
Not Applicable

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

(Click here to return to summary of findings)
(Click here to return to Key Information)

ETI
2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to
bargain collectively.
2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational
activities.
2.3 Workers’ representatives are not discriminated against and have access to carry out their
representative functions in the workplace.
2.4 Where the right to freedom of association and collective bargaining is restricted under law, the
employer facilitates, and does not hinder, the development of parallel means for independent and free
association and bargaining.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what releva nt
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
• All the employees are allowed to form or join the trade union of their choice.
• There is no trade union in the facility, but there is a Participation Committee formed by election.
• Participation Committee was formed by election on 1st March, 2022.
• Last meeting of the committee was held on 23th March, 2022.
• Meeting minutes are posted in notice board and recorded in a register.
• There are 20 members from workers’ side and 10 from management side with a total of 30 members.
• PC members are not treated less favourably than other workers.
• PC members are allowed to carry out their duties within working hours without affecting their pay.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. Freedom of association policy review
2. Facility management interviews
3. Worker interview
4. Complain box register (Suggestions from the complaint box and actions taken)
5. Participation Committee formation record review and its meeting records review, grievance handling
policy & procedure.

Any other comments: None

A: What form of worker Union (name)

representation/union is there on Worker Committee
site? Other (specify)
None

B: Is it a legal requirement to have a Yes

union? No

C: Is it a legal requirement to have Yes

a worker’s committee? No

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D: Is there any other form of Yes

effective worker/management No
communication channel? (Other D1: Please give details: The factory management has provided
than union/worker committee e.g. H&S, complain box in the toilet area through which workers can raise their
sexual harassment) suggestion / complaints. Workers can also approach the
management directly for any grievances which confirmed the
interviewed workers.

D2: Is there evidence of free elections?

Yes
No

E: Does the supplier provide Yes

adequate facilities to allow the No
Union or committee to conduct E1: Please give details: The PC members are able to perform their
related business? responsibility without any management intervention.

F: Name of union and union Not Applicable F1: Is there evidence of free elections?
representative, if applicable: Yes No N/A

G: If there is no union, is there a Participation G1: Is there evidence of free elections?

parallel means of consultation with Committee Yes No N/A
workers e.g. worker committees?

H: Are all workers aware of who Yes No All workers are well aware of their
their representatives are? representatives.

I: Were worker representatives freely Yes No I1: Date of last election: 01 March 2022
elected?

J: Do workers know what topics can Yes No

be raised with their representatives?

K: Were worker Yes No

representatives/union If Yes, please state how many: One worker representative was
representatives interviewed? interviewed during audit.

L: Please describe any evidence 20 worker representatives were elected by the workers among the
that union/worker’s committee is workers to represent each section of the facility. The last
effective? communication meeting was held on 23th March, 2022 with topic of
Specify date of last meeting; topics discussion about topic of the upcoming festival holidays and the
covered; how minutes were working hour after the upcoming festival holidays etc. Meeting
communicated etc. minutes was shared with all workers through posting the meeting
minutes on communication board.

M: Are any workers covered by Yes No

Collective Bargaining Agreement
(CBA)?

If Yes, what percentage by trade M1: __NA__% workers covered by M1: __NA__% workers covered
Union/worker representation Union CBA by Union CBA

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M3: If Yes, does the Collective Yes

Bargaining Agreement (CBA) No
include rates of pay?

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law NC against customer observed:
code: Not Applicable
None Observed
Local law and/or ETI requirement:
Not Applicable
Recommended corrective action:
Not Applicable

Observation:

Description of observation: Objective evidence

None Observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

Good Examples observed:

Description of Good Example (GE): Objective evidence

None Observed observed:
Not Applicable

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3: Working Conditions are Safe and Hygienic

(Click here to return to summary of findings)
(Click here to return to Key Information)

ETI
3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing
knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent
accidents and injury to health arising out of, associated with, or occurring in the course of work, by
minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.
3.2 Workers shall receive regular and recorded Health & Safety training, and such training shall be
repeated for new or reassigned workers.
3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food
storage shall be provided.
3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for Health & Safety to a senior
management representative.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detai l
any documentary or verbal evidence shown to support the systems.

Current systems:
1. General Health and Safety Management
• Md. Abdus Sattar, Asst. Manager (Fire & Safety Officer) looks after Health & Safety issues for the
site.
• Potable water was freely available in all areas.
• Enough clean toilets 428 (290 for male and 138 for female) segregated by gender were always
available for workers.
• Ventilation, temperature and lighting were adequate for the production processes.
• Minutes of meetings show that there are every month Health and Safety meeting held. Last
meeting was held on 22 March 2022.

2. Fire Safety
• Enough assembly area was found in front of the facility building.
• Firefighting equipment was adequate.
• The facility management posted the evacuation plans on every production floor with local
language.
• PA system, smoke detection system & fire alarming system were covered throughout the factory.

3. Fire Drill Information:

Type of Fire Drill Date Time No. of Participant Conducted By
Day (External) 30.11.2021 02:22 Min 4605 Mohammad Abdul Hamid
Miah, Deputy Asst. director,
FSCD, Gazipur (Zone-01)
Day (Internal) 12.03.2022 02:22 Min 4154 Md. Abdus Sattar, Asst.
Manager (Fire & Safety
Officer)
Night (Internal) 12.03.2022 01:50 720 Md. Abdus Sattar, Asst.
minutes Manager (Fire & Safety
Officer)

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Name of Training Date Participant Name of Trainer

Md. Rubel Ahamad, Asst. Officer
1. New Workers Orientation Training 24.03.2022 10
(Compliance)
Md. Ahamed Sheikh, Asst. Engineer
2. Machine Safety Training 24.03.2022 03
(Mechanical)
Airin Rahman Rakhi, Welfare Officer
3. PPE Training 10.03.2022 14
(Compliance)
Md. Abdus Sattar, Asst. Manager
4. Fire Fighting Training 29.03.2022 28
(Fire & Safety Officer)
Airin Rahman Rakhi, Welfare Officer
5. Health & Safety Training 13.03.2022 16
(Compliance)
Rubaia Ahammad, Welfare Officer
6. E.T.I Base Code Training 06.03.2022 16
(Compliance)
Taposh Mohanto, Senior Officer
7. Chemical Handling Training 10.03.2022 14
(ECR)
Rubaia Ahammad, Welfare Officer
8. Abuse and Harassment Training 15.03.2022 18
(Compliance)
Airin Rahman Rakhi, Welfare Officer
9. Grievance Procedure Training 09.03.2022 14
(Compliance)
10. Environmental Management Md. Masud Rana, Officer
23.03.2022 16
Training (Compliance)
11. Mid-Level Management
15.03.2022 15 A.K Jilani, Sr. Officer (Compliance)
Training

4. Electrical & Machine Safety

• All electrical equipment was maintained in good condition such as sockets, plugs, switches and
main fuse boards.
• Facility checks all electric channels, distribution board and electric connection daily and monthly
schedule wise.
• Facility maintains a scheduled maintenance plan for doing maintenance of all machines.

5. Chemical Safety
• Facility uses chemicals for their production process and provided training and Personal Protection
Equipment. MSDS, label and secondary containment were found with all the chemicals.

6. Medical Services
• There were 64 first aid boxes in the facility.
• Facility has appointed 02 doctors and 07 nurses who are available in working time of the facility.
• Facility has a medical room.

7. Dormitory
• The site provides offsite dormitory facilities to the employees.

Three non-compliances were found in the area of “Working Conditions are Safe and Hygienic”. For details,
please refer to contents of ‘Non-compliance’.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. License review (Fire license, Trade license, Factory license)

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2. Building approval plan and layout approval plan

3. Group insurance
4. Drinking water test report
5. Injury record and analysis report
6. Machine and electric maintenance record
7. Training record (Fire training, First aid training, PPE training and Health and safety training).
8. Fire drill record
9. Health and safety committee register
10. Fire equipment and electric equipment checking record.

Any other comments: None.

A: Does the facility have general and Yes

occupational Health & Safety policies No
and procedures that are fit for purpose A1: Please give details: Factory had adopted health & safety
and are these communicated to policy which covers PPE, machine safety device, fire safety (fire
workers? extinguisher, freighting equipment, hose pipe etc.), emergency
pathway, evacuation drill, housekeeping, first aid, electrical
safety etc. Last training was conducted on 13 March 2022.

B: Are the policies included in workers’ Yes

manuals? No
B1: Please give details: The facility provides workers manual to
the workers where all the policies and applicable government
law are included.

C: Are there any structural additions Yes

without required permits/inspections No
(e.g. floors added)? C1: Please give details: There were no structural additions
without prior permits/ inspections.
D: Are visitors to the site informed on Yes
H&S and provided with personal No
protective equipment D1: Please give details: The site kept dedicated PPE(s) for visitors.
While any visitor visits in the factory generally, they brief the
visitor about H&S policy and provide PPE(s) as and when
required.

E: Is a medical room or medical facility Yes

provided for workers? No
E1: Please give details: The company provides medical facility
If yes, do the room(s) meet legal to the workers and it meets the legal requirements.
requirements and is the size/number of
rooms suitable for the number of
workers.
F: Is there a doctor or nurse on site or Yes
there is easy access to first aider/ No
trained medical aid? F1: Please give details: The facility has 02 doctors & 07 nurses
are appointed for medical treatments of the employees. They
also provide training to the first aiders.
G: Where the facility provides worker Yes
transport - is it fit for purpose, safe, No
maintained and operated by G1: Please give details: Not applicable.
competent persons e.g. buses and
other vehicles?

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H: Is secure personal storage space Yes

provided for workers in their living No
space and is fit for purpose? H1: Please give details: The factory provides secure personal
storage space in their living space to the workers and it fits for
purpose.
I: Are H&S Risk assessments are Yes
conducted (including evaluating the No
arrangements for workers doing I1: Please give details: Workers risk assessment is done on a
overtime e.g. driving after a long shift) monthly basis according to the training schedule.
and are there controls to reduce
identified risk?
J: Is the site meeting its legal obligations Yes
on environmental requirements No
including required permits for use and J1: Please give details: The facility meets all the legal obligations
disposal of natural resources? on environmental requirement including required permits for
use and disposal natural resources like water, gas etc.
K: Is the site meeting its customer Yes
requirements on environmental No
standards, including the use of banned K1: Please give details: Factory did not use banned chemicals
chemicals? and follows the entire customer requirement on environmental
standard.

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law NC against customer code: observed:
1. Based on plant tour
It was noted during plant tour that Around 60% of eye guards with overlock NC Picture No. 01
machines were found misplaced at sample sewing section of 1st floor of the
building-1.

Local law and/or ETI requirement

In accordance with ETI Base Code 3.1: A safe and hygienic working environment
shall be provided, bearing in mind the prevailing knowledge of the industry and
of any specific hazards. Adequate steps shall be taken to prevent accidents
and injury to health arising out of, associated with, or occurring in the course of
work, by minimising, so far as is reasonably practicable, the causes of hazards
inherent in the working environment.

In accordance with The Bangladesh Labour Act, 2006, Section 63 (1- d, 3): 1) In
every establishment the following shall be securely fenced by the safeguards of
substantial construction which shall be kept in position while the part of
machinery required to be fenced are in mention or in use, namely- (d) unless
they are in such position or of such construction as to be as safe to every person
employed in the establishment as they would be if they were securely fenced-
(iii) every dangerous part of any machinery:

Recommended corrective action: It is recommended that the facility

management should ensure the usage of machine safety guards with all
overlock machines during work.

Action by: Md. Sultan Salah Uddin, AGM (Compliance)

Time scale: 30 Days.

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2. Description of non–compliance: 2. Based on plant tour

NC against ETI NC against Local Law NC against customer code: NC Picture No. 02, 03,
04, 05 & 06
It was noted during plant tour that-

a) Around 40% workers were not using earplugs while working at texpa hamming
sections of 5th floor & 6th floor of the building-1.
b) Around 40% workers were not using earplugs while working at sizing section of
the shed-1.
c) Around 35% workers were not using earplugs while working at warping section
of the shed-1.
d) Around 30% workers were not using earplugs while working at twisting section
of the shed-5.
e) around 85% heavy trolley loaders were not using safety shoes while moving
trolleys one process to another process inside the factory premises.

Local law and/or ETI requirement

In accordance with ETI Base Code 3.1: A safe and hygienic working environment
shall be provided, bearing in mind the prevailing knowledge of the industry and
of any specific hazards. Adequate steps shall be taken to prevent accidents
and injury to health arising out of, associated with, or occurring in the course of
work, by minimising, so far as is reasonably practicable, the causes of hazards
inherent in the working environment.

In accordance with The Bangladesh Labour Rules, 2015, Rule 67 (2 & 3): 2) In
addition to the arrangement of safety and health protection measures
mentioned in Sub-section (1), the concerned manufacturing institute must
provide necessary equipment, including safety shoes, helmets, goggles, masks,
hand gloves, ear muffs, ear plugs, waist belts, aprons etc. and arrange training
programs for the workers in using these materials and ensure their usage. 3) No
worker can be employed in the relevant works without ensuring safety and
health protection measures and the training related therewith. In addition,
personal safety equipment must be preserved in accordance with Information
Form-23.

Recommended corrective action: It is recommended that the facility

management should provide appropriate PPE(s) to the workers of the
mentioned areas and ensure of wearing appropriate PPE(s) while they are
working in the production floors.

Action by: Md. Sultan Salah Uddin, AGM (Compliance)

Time scale: 30 Days.

3. Description of non–compliance: 3. Based on workers

NC against ETI NC against Local Law NC against customer code: interview
It was noted through workers interview that-

(a) Approximately 45% of the firefighters & rescuers were not properly aware
about the types of fire extinguishers, types of fire, uses of fire equipment, rescue
procedures and his/her duties during fire.

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(b) Approximately 35% of the first aiders were not well aware about first aid
medicines, kits and preliminary treatment procedures.

Local law and/or ETI requirement

In accordance with ETI Base Code 3.1: A safe and hygienic working environment
shall be provided, bearing in mind the prevailing knowledge of the industry and
of any specific hazards. Adequate steps shall be taken to prevent accidents
and injury to health arising out of, associated with, or occurring in the course of
work, by minimising, so far as is reasonably practicable, the causes of hazards
inherent in the working environment.

In accordance with The Bangladesh Labour Rules 2015, Rule 55 (10): If possible,
all workers or at least 18% of the workers employed in each department have to
be trained on fire-fighting, emergency rescue operation, first aid and the usage
of portable fire-repellent instruments. And the security has to be ensured by
dividing the trained workers into fire-fighting team, rescue team and first aid
team (6% members in each team) and the records related herewith have to be
preserved in accordance with Form- 22.

Recommended corrective action: It is recommended that the facility

management shall arrange firefighting, rescue and first aid trainings on regular
basis to prepare them aware on firefighting requirements, rescue procedures
and first aid treatment procedures in case of emergency situations.

Action by: Md. Sultan Salah Uddin, AGM (Compliance)

Time scale: 30 Days.

Observation:

Description of observation: Objective evidence

None Observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

Good Examples observed:

Description of Good Example (GE): Objective Evidence

None Observed Observed:
Not Applicable

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4: Child Labour Shall Not Be Used

(Click here to return to summary of findings)
(Click here to return to Key Information)

ETI
4.1 There shall be no new recruitment of child labour.
4.2 Companies shall develop or participate in and contribute to policies and programmes which provide
for the transition of any child found to be performing child labour to enable her or him to attend and
remain in quality education until no longer a child.
4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO Standards.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detai l
any documentary or verbal evidence shown to support the systems.

Current systems:
• The facility has established a practice that they will never employ and use any child labour.
• The facility verifies all workers’ original national ID card, birth certificate etc. at the time of recruitment
and keeps the photocopies of workers’ ID cards, birth certificate in their personal files.
• Factory verifies the workers age through registered doctor.
• Sampling basis employees’ personal files was taken for review. Each employee file included a bio-
data sheet, recent photo, birth registration certificate / photocopied national identification card and
other documents.
• There was no child or young employee observed in the facility.
• It was evident during the documents review; the age of youngest worker is 18+ years old (DOB: 1st
January 2004 & DOJ: 7th March 2022). During the facility walkthrough, there were no concerns
regarding child labour observed.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. The procedure of recruiting regulation was available for review, the personnel files with ID or birth
certificate copy were available for review, the contracts with all the employees were available for audit,
and the roster had established by the factory.
2. Document review
3. Management interview
4. Worker interview
5. On-site observation during floor visit

Any other comments: None

A: Legal age of employment: 14+ years with significant restriction

B: Age of youngest worker found: 18+ years

C: Are there children present on the work Yes

floor but not working at the time of No
audit?

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D: % of under 18’s at this site (of total 0%

workers)

E: Are workers under 18 subject to Yes

hazardous work assignments? No
(Go to clause 3 – Health and Safety) E1: If yes, give details: Not Applicable

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law NC against customer observed:
code: Not Applicable
None Observed
Local law and/or ETI requirement:
Not Applicable
Recommended corrective action:
Not Applicable

Observation:

Description of observation: Objective evidence

None Observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

Good Examples observed:

Description of Good Example (GE): Objective Evidence

None Observed Observed:
Not Applicable

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5: Living Wages are Paid

(Click here to return to summary of findings)
(Click here to return to Key information)

ETI
5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards
or industry benchmark standards, whichever is higher. In any event wages should always be enough to
meet basic needs and to provide some discretionary income.
5.2 All workers shall be provided with written and understandable information about their employment
conditions in respect to wages before they enter employment and about the particulars of their wages
for the pay period concerned each time that they are paid.
5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from
wages not provided for by national law be permitted without the expressed permission of the worker
concerned. All disciplinary measures should be recorded.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detai l
any documentary or verbal evidence shown to support the systems.

Current systems:
• Based on the Gazette Garments Notifications, the actual lowest minimum wage in the facility is BDT
5,710 per month.
• Time keeping by biometric system.
• All workers are provided with written and understandable information about their employment
conditions in respect to wages before they enter employment and about the particulars of their
wages for the pay period concerned each time that they are paid.
• Each employee was given a pay slip and signed for their wages.
• All employees were paid within 7 working days of the following month.
• Employees are aware of their minimum wage.
• Wages have been recorded according to documents checked.
• According to the documents which were provided by the HR & Accounts Department and during
the workers interview, it was noted that factory provides all kinds of leave. Maternity leave and earn
leave benefits are provided to the employees as per law. Moreover, employees were allowed to
take 14 days’ sick leave; 10 days’ casual leave according to law and 11 days’ festival leave.

Three good examples were found in the area of “Living wages and benefits”. For details, please refer to
contents of good examples.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. Document review
2. Worker interview
3. Management interview
4. Local and national laws
5. Wages and benefits policy
6. Local legal minimum wage documents
7. Payroll records from April 2021 to the audit day
8. Leave records
9. Social group insurance and payment receipts from the local labour department
10. Labour contracts for all employees
11. Resignation records

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12. Payslips of all workers interviewed

13. Overtime records

Any other comments: None.

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law NC against customer observed:
code: Not Applicable
None Observed
Local law and/or ETI requirement:
Not Applicable
Recommended corrective action:
Not Applicable

Observation:

Description of observation: Objective evidence

None Observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

Good Examples observed:

Description of Good Example (GE): Objective Evidence

Observed:
1. The factory provides attendance bonus BDT 500 for all workers as per factory Payroll records review
policy. and workers &
management interview
2. The
factory provides free educational resources to the adult workers for adult
education program.

3. The factory provides new born baby gift to all the new mothers.

Summary Information
Criteria Local Law Actual at the Is this part of a
(Please state legal Site Collective
requirement) (Record site Bargaining
results against the Agreement?
law)

A: Standard/Contracted work hours: Legal maximum: A1: 08 hours per A2:

(Maximum legal and actual required working hours 08 hours per day day Yes
excluding overtime, please state if possible per day, 48 hours per 48 hours per No
week, and month)
week week

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B: Overtime hours: Legal maximum: B1: 02 hours/ B2:

(Maximum legal and actual overtime hours, please 2 hours/ day and day and Yes
state if possible per day, week, and month) 12 hour/ week 12 hour/ week No

C: Wage for standard/contracted hours: Legal minimum: C1: The site C2:
(Minimum legal and actual minimum wage at site, Grade-1: 8977 provides: Yes
please state if possible per hr, day, week, and month) BDT/Month Grade-1: 8977 No
Grade-2: 8275 BDT/Month
BDT/Month Grade-2: 8275
Grade-3: 7924 BDT/Month
BDT/Month Grade-3: 7924
Grade-4: 7303 BDT/Month
BDT/Month Grade-4: 7303
Grade-5: 7033 BDT/Month
BDT/Month Grade-5: 7033
Grade-6: 6763 BDT/Month
BDT/Month Grade-6: 6763
Grade-7: 6520 BDT/Month
BDT/Month Grade-7: 6520
Grade-8: 6250 BDT/Month
BDT/Month Grade-8: 6250
Grade-9: 6061 BDT/Month
BDT/Month Grade-9: 6061
Grade-10: 5710 BDT/Month
BDT/Month Grade-10: 5710
Trainee / BDT/Month
Apprentice: Trainee /
4100 BDT/Month Apprentice:
4100 BDT/Month

D: Overtime wage: Legal minimum: D1: D2:

(Minimum legal and actual minimum overtime wage Legal minimum: Legal Yes
at site, please state if possible per hr, day, week, and 200% of basic minimum: 200% No
month) wages of basic wages

Wages analysis:
(Click here to return to Key Information)

A: Were accurate records shown at Yes

the first request? No

A1: If No, why not? Not applicable

B: Sample Size Checked 62 samples from the month of May 2021 (Random month)
(State number of worker records 62 samples from the month of November 2021 (Random month)
checked and from which 62 samples from the month of March 2022 (Current month)
weeks/months – should be current,
peak, and random/low. Please see
SMETA Best Practice Guidance and
Measurement Criteria)

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C: Are there different legal Yes If Yes, please give details: The Government has
minimum wage grades? If Yes, No announced the pay structure, which was
please specify all. implemented from 24th April, 2018 for the workers of
the Textile Industries. The Gazette Notification has
been published on 3rd May, 2018. There are two
separate pay structures; for the textile workers
(Schedule A).

For the workers (Schedule A):

Grade Basic House Medical Conv Gross
Wage Rent eyance Salary
1 6020 2107 550 300 8977
2 5500 1925 550 300 8275
3 5240 1834 550 300 7924
4 4780 1673 550 300 7303
5 4580 1603 550 300 7033
6 4380 1533 550 300 6763
7 4200 1470 550 300 6520
8 4000 1400 550 300 6250
9 3860 1351 550 300 6061
10 3600 1260 550 300 5710
Appren
4100
tice

2. For the staff level (Schedule B):

Grade Basic House Medical Conv Gross
Wage Rent eyance Salary
1 8100 2835 550 300 11785
2 6540 2289 550 300 9679
3 5500 1925 550 300 8275
4 4460 1561 550 300 6871
5 3940 1379 550 300 6169
6 3600 1260 550 300 5710
Appren
4100
tice

D: If there are different legal Yes D1: If No, please give details:
minimum grades, are all workers No
graded and paid correctly? N/A

E: For the lowest paid production Below E1: Lowest actual wages found: The actual lowest
workers, are wages paid for legal min minimum wage in the facility was BDT 5710 per
standard/contracted hours Meet month. This is government declaring legal minimum
(excluding overtime) below or Above wage.
above the legal minimum?

F: Please indicate the breakdown of F1: ____0____% of workforce earning under minimum wage
workforce per earnings: F2: __12.71__% of workforce earning minimum wage
F3: __87.29__% of workforce earning above minimum wage

G: Bonus Scheme found: Bonus Scheme found:

Please specify details: 1. The facility provides festival bonus 100% of basic salary during Eid
Ul Fitr and Eid Ul Azha (each) as per factory policy.

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2. The factory provides attendance bonus BDT 500 for all workers as
per factory policy.

H: What deductions are required by As per section 125 of the Bangladesh Labour Law, 2006, factory may
law e.g. social insurance? deduct wages for un-authorized absence, for fines, housing facility,
Please state all types: advance payments, loans, income tax, provident fund, etc.
However, the factory is deducting only for un-authorized absence.

I: Have these deductions been Yes I1: Please list all 1. Absent deduction in case of
made? No deductions that worker is absent as per law.
have been made.
Please describe: The factory
deducted for absent.

I2: Please list all 1. Social group insurance

deductions that
have not been Please describe: The factory did
made. not made deduction for social
group insurance.

J: Were appropriate records Yes

available to verify hours of work and No
wages?

K: Were any inconsistencies found? Yes K1: Type

(if yes describe nature) No
Poor record keeping
Isolated incident
Repeated occurrence:

L: Do records reflect all time Yes

worked? (For instance, are workers No
asked to attend meetings before or L1: Please give details: Facility shows all real records which reflect all
after work but not paid for their scenario. Factory had provided accurate and complete payroll &
time) attendance records to the auditors for review where all working
hours were recorded.

M: Is there a defined living wage: Yes

This is not normally minimum legal No
wage. If answered yes, please state M1: Please specify amount/time: Factory did not define living wages
amount and source of info: as it is not required by law. However, factory is providing the
Please see SMETA Best Practice minimum wage as Minimum Cotton Wage textile gazette for “Textile
Guidance and Measurement Criteria. Industry” published on 24 April, 2018.

M2: If yes, what was the calculation ISEAL/Anker Benchmarks

method used. Asia Floor Wage
Figures provided by Unions
Living Wage Foundation UK
Fair Wear Wage Ladder
Fairtrade Foundation
Other – please give details: Not applicable

N: Are there periodic reviews of Yes

wages? If Yes give details (include No

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whether there is consideration to N1: Please give details: At least 5% of basic wages shall be increased
basic needs of workers plus yearly.
discretionary income).

O: Are workers paid in a timely Yes

manner in line with local law? No

P: Is there evidence that equal rates Yes

are being paid for equal work: No
P1: Please give details: Based on employees’ interview, copy of
appointment letter issued to the employees and wage records, it
was noted that equal rates are paid for equal work.

Q: How are workers paid: Cash

Cheque
Bank Transfer
Other
Q1: If other, please explain: Mobile Banking (Rocket)

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6: Working Hours are not Excessive

(Click here to return to summary of findings)
(Click here to return to Key Information)

ETI
6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6
below, whichever affords the greater protection for workers. Sub–clauses 6.2 to 6.6 are based on
international labour standards.

6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per
week.

6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the
following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It
shall not be used to replace regular employment. Overtime shall always be compensated at a premium
rate, which is recommended to be not less than 125% of the regular rate of pay.

6.4 The total hours worked in any 7-day period shall not exceed 60 hours, except where covered by
clause 6.5 below.

6.5 Working hours may exceed 60 hours in any 7-day period only in exceptional circumstances where all
of the following are met:
– this is allowed by national law;
– this is allowed by a collective agreement freely negotiated with a workers’ organisation
representing a significant portion of the workforce;
– appropriate safeguards are taken to protect the workers’ health and safety; and
– The employer can demonstrate that exceptional circumstances apply such as unexpected
production peaks, accidents or emergencies.

6.6 Workers shall be provided with at least one day off in every 7-day period or, where allowed by
national law, 2 days off in every 14-day period.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detai l
any documentary or verbal evidence shown to support the systems.

Current systems:
• In this audit, auditor had randomly selected production record, such as: Material in/out records,
daily production reports, and crosschecked these records with payroll records and attendance
records, no inconsistency was noted. In addition, through employees’ interviews, no
inconsistency was noted either.
• Through employees’ interview, overtime is voluntary.
• Time cards are completed electrically.
• All overtime is compensated at a premium rate for all employees.
• The time frame of the records reviewed are as follows:
62 samples from the month of May 2021 (Random month)
62 samples from the month of November 2021 (Random month)
62 samples from the month of March 2022 (Current month)
According to time records and worker interview basic working hours were 8 hours per day and a max 48
hours per week. Maximum OT 2 hours per day and 12 hours per week were found in the three sample
months. The employee works for 06 days in a week. Weekend of the factory is as per rotation basis. The
general working hours of the facility has four shifts e.g. ‘G’ Shift-1 starts from 08:00 to 17:00, ‘G’ Shifts-2 starts
from 09:00 to 18:00, ‘G’ Shifts-3 starts from 11:00 to 20:00 with 60 minutes meal break for each shifts & roster

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weekend and G’ Shifts-4 (only for Ramadan Month) starts from 6:30 to 15:00 with 60 minutes break and
roster weekend of this shift. There are double shifting working hours in a day of the facility e.g. Shift-1 starts
from 08:00 to 17:00, Shift-2 starts from 20:00 to 5:00, Shift-3 starts from 09:00 to 18:00 and Shift-4 starts from
21:00 to 6:00 with 60 minutes break and roster weekend for each shift. There are triple shifting working hours
in a day of the facility e.g. Shifts-1 starts from 06:00 to 14:30, Shift-2 starts from 14:00 to 22:30, Shift-3 starts
from 22:00 to 06:30, Shifts-4 starts from 05:00 to 13:30, Shift-5 starts from 13:00 to 21:30 and Shift-6 starts from
21:00 to 05:30 with 30 minutes break & roster weekend for each shift. Security has three shifts per eight hours
each with roster break & weekend.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. Employee interview
2. Management interview
3. Local and national laws
4. Factory policy on working hours
5. Attendance and wages records from April 2021 to the audit day.
6. Electronic attendance system
7. Sample pay slips with recorded hours all workers interviewed
8. Quality and production records to cross check hours
9. Workers contracts

Any other comments: None

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law NC against customer observed:
code: Not Applicable
None observed
Local law and/or ETI requirement:
Not Applicable
Recommended corrective action:
Not Applicable

Observation:

Description of observation: Objective evidence

None observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

Good Examples observed:

Description of Good Example (GE): Objective Evidence

None Observed Observed:
Not Applicable

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Working hours’ analysis

Please include time e.g. hour/week/month
(Go back to Key information)

Systems & Processes

A. What timekeeping Describe: Attendance and work timings (including OT) record was maintained
systems are used: time by Electronic (Biometric system).
card etc.

B: Is sample size same as Yes

in wages section? No
B1: If no, please give details: Not applicable

C: Are Yes C1: If NO, please give details including % and which type of
standard/contracted No workers do NOT have standard hours defined in
working hours defined in contracts/employment agreements.
all Please give details: Not applicable
contracts/employment
agreements?

D: Are there any other Yes D1: If YES, please complete as appropriate:
types of No
contracts/employment
agreements used? 0 hrs Part time 0 hrs Other

If “Other”, Please define:

Not applicable

E. Do any Yes E1: If yes, please detail hours, %, types of workers affected
standard/contracted No and frequency
working hours defined in Please give details: Not applicable
contracts/employment
agreements exceed 48
hours per week?

F: Are workers provided F2: Please F3: Is this allowed by local law?
with at least 1 day off in select all Yes
every 7-day-period, or 2 applicable: No
in 14-day-period? 1 in 7 days
2 in 14 days
No
If ‘No’, please
explain:

Maximum number of days worked without a day off (in sample):

The factory worked maximum 6 days in a week without a day off.

Standard/Contracted Hours worked

Yes G1: If yes, % of workers & frequency:

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G: Were standard No Not applicable

working hours over 48
hours per week found?

H: Any local Yes H1: If yes, please give details:

waivers/local law or No
permissions which allow Not applicable
averaging/annualised
hours for this site?

Overtime Hours worked

I: Actual overtime hours Highest OT hours:

worked in sample (State 32 hours in the month of May 2021 (Random month)
per day/week/month) 52 hours in the month of November 2021 (Random month)
54 hours in the month of March 2022 (Current month)

J: Combined hours Yes

(standard or contracted No
+ overtime hours = total)
over 60 found?
Please give details:

K: Approximate ___38.18___%
percentage of total
workers on highest
overtime hours:

L: Is overtime voluntary? Yes L1: Please detail evidence e.g. Wording of contract /
No employment agreement / handbook / worker interviews /
Conflicting refusal arrangements: Based on the factory policy, rules and
Information regulations, and training records, employee handbook and
workers and management interview it was noted that the
overtime is voluntary in this factory.

Overtime Premiums

M: Are the correct legal Yes M1: Please give details of normal day overtime premium as
overtime premiums No a % of standard wages: 200% of basic wages
paid? N/A – there
is no legal
requirement to
OT premium

N: Is overtime paid at a Yes N1: If yes, please describe % of workers & frequency: 100%
premium? No workers receive 200% of basic wages as overtime rate every
month, if they need to do overtime works.

O: If the site pays less No

than 125% OT premium Consolidated pay (May be standard wages above minimum legal wage, with
and this is allowed under no/low overtime premium)
local law, are there other Collective Bargaining agreements
considerations? Please Other

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complete the boxes O1: Please explain any checked boxes above e.g. detail of consolidated pay
where relevant. / CBA or Other

Not applicable

P: If more than 60 total Overtime is voluntary

hours per week and this Onsite Collective bargaining allows 60+ hours/week
is legally allowed, are Safeguards are in place to protect worker’s health and safety
there other Site can demonstrate exceptional circumstances
considerations? Please Other reasons (please specify)
complete the boxes
where relevant. P1: Please explain any checked boxes above e.g. detail of consolidated pay
/ CBA or other:

Not applicable

Q: Is there evidence that Yes

overtime hours are being No
used for extended Q1: If yes, please give details: Not Applicable
periods to make up for
labour shortages or
increased order
volumes?

R: If sufficient workers Yes

cannot be hired, are No
new working time
arrangements explored
to ensure that overtime is
the exception rather
than the rule.

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7: No Discrimination is Practiced
(Click here to return to summary of findings)

ETI
7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or
retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual
orientation, union membership or political affiliation.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what releva nt
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
• There is no discrimination in hiring, compensation, access to training, promotion, termination or
retirement based on race, caste, national origin, religion, age, disability, gender, marital status,
sexual orientation, union membership or political affiliation.
• Gender discrimination was also absent in the facility; both female and male workers were distributed
in all types of work.
• There was no evidence of sexual harassment.
• There was an internal grievance process, all sampled employees were aware of the grievance
channels in case they encountered any discrimination cases.
• The factory provides the same wage amount to male/female employees of the same rank.
• There is no restriction for formation of trade union in the factory.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. The hiring and termination procedure, leave application records and employee handbook.
2. Payroll records
3. Attendance records
4. Termination records
5. Training records
6. Employment contracts were provided for review and they showed that male and female employees
were on the same pay grade.
7. Management interview and employee interview

Any other comments: None

A: Gender breakdown of Management A1: Male: __90__ %

+ Supervisors (Include as one combined A2: Female__10__ %
group)

B: Number of women who are in skilled 0%

or technical roles e.g. where specific
qualifications are needed i.e. machine
engineer / laboratory analyst:

C: Is there any evidence of Hiring

discrimination based on race, caste, Compensation
national origin, religion, age, disability, Access to training
Promotion

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gender, marital status, sexual orientation, Termination or retirement

union membership or political affiliation? No evidence of discrimination found

C1: Please give details: As per documents review,

management & works interview, there was no evidence of
discrimination based on race, caste, national origin, religion,
age, disability, gender, marital status, sexual orientation, union
membership or political affiliation.

Professional Development

A: What type of training and development All workers are given H&S training, different types of machine
are available for workers? operation and quality assurance training.

B: Are HR decisions e.g. promotion, Yes

training, compensation based on No
objective, transparent criteria?
If no, please give details: Not applicable.

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law NC against customer observed:
code: Not Applicable
None Observed
Local law and/or ETI requirement:
Not Applicable
Recommended corrective action:
Not Applicable

Observation:

Description of observation: Objective evidence

None Observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

Good Examples observed:

Description of Good Example (GE): Objective Evidence

None Observed Observed:
Not Applicable

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8: Regular Employment Is Provided

(Click here to return to summary of findings)
(Click here to return to Key Information)

ETI
8.1 To every extent possible work performed must be on the basis of recognised employment relationship
established through national law and practice.
8.2 Obligations to employees under labour or social security laws and regulations arising from the regular
employment relationship shall not be avoided through the use of labour–only contracting, sub–
contracting, or home–working arrangements, or through apprenticeship schemes where there is no real
intent to impart skills or provide regular employment, nor shall any such obligations be avoided through
the excessive use of fixed–term contracts of employment.

Additional Elements: Responsible Recruitment

8.3 Suppliers have full understanding of the entire recruitment process and assess all labour recruiters and
intermediaries against legal and/or ethical requirements.
8.4 There are effective management systems in place to identify and monitor the hiring and
management of all migrant workers, contract workers, agency workers, temporary or casual labour The
supplier shall implement processes to enable adequate control over agencies with regards the above
points and related legislation.
8.5 Employment agencies must only supply workers registered with them.
8.6 Workers pay no recruitment fee at any stage of the recruitment process.
8.7 Worker contracts accurately reflect the agreed payment and terms in the recruitment process and
are understood and signed by workers.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detai l
any documentary or verbal evidence shown to support the systems.

Current systems:
• All employees were recruited by the factory directly.
• No labour agency was used to hire workers. No temporary worker, apprenticeship schemes or home
worker was identified by the auditors.
• All workers getting signed labour contract and ID card during their recruitment.
• Factory maintains service books for all workers.
• Factory has policy to provide all kinds of compensation and benefits to the employees
• If any employees want to leave the job, he or she may leave giving 60 days’ notice prior to leave as
per law.
• No temporary worker, apprenticeship schemes or home worker was identified by the auditors.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. Factory policy, rules and regulations, employees’ personnel files, employees’ ID card, pay slips etc.
2. Management interview and employee interview
3. The hiring and termination records.
4. Worker interview.

Any other comments: None

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Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law NC against customer observed:
code: Not Applicable
None observed
Local law and/or ETI requirement:
Not Applicable
Recommended corrective action:
Not Applicable

Observation:

Description of observation: Objective evidence

None observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

Good Examples observed:

Description of Good Example (GE): Objective Evidence

None observed Observed:
Not Applicable

Responsible Recruitment

All Workers

A: Were all workers presented Terms & Conditions presented

with terms of employment at the Understood by workers
time of recruitment, did they Same as actual conditions
understand them and are they
same as current conditions? A1: If any are unchecked, please describe finding and specific
category(ies) of workers affected: Not Applicable.

B: Did workers’ pay any fees, Yes

taxes, deposits or bonds for the No
purpose of B1: If yes, please describe details and specific category(ies) of workers
recruitment/placement? affected: Not Applicable.

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C: If yes, check all that apply: Recruitment / hiring fees

Service fees
Application costs
Recommendation fees
Placement fees
Administrative, overhead or processing fees
Skills tests
Certifications
Medical screenings
Passports/ID’s
Work / resident permits
Birth certificates
Police clearance fees
Any transportation and lodging costs after employment offer
Any transport costs between work place and home
Any relocation costs after commencement of employment
New hire training / orientation fees
Medical exam fees
Deposit bonds or other deposits
Any other non-monetary assets
Other –
C1: If other, please give details: Not Applicable

D: If any checked, give details: Not Applicable

Migrant Workers:
The term "migrant worker" refers to a person who is engaged or has been engaged in a remunerated activity in a
country of which they are not a national or permanent resident or has purposely migrated on a temporary basis to
another in-country region to seek and engage in a remunerated activity

A: Type of work undertaken by Not applicable as no migrant worker was found in this factory.
migrant workers:

B: Please give details about B1: Total number of (in country recruitment agencies) used:
recruitment agencies for migrant
workers: B2: Total number of (outside of local country) recruitment
agencies used: Not applicable as factory had recruited all
workers directly.

C: Are migrant workers’ voluntary Yes Yes

deductions (such as for remittances) No No
confirmed in writing by the worker and C1: Please describe C1: Please describe finding:
is evidence of the transaction supplied finding: Not Applicable.
by the facility to the worker? Not Applicable.

Yes
D: Are Any migrant workers in skilled, No
technical, or management roles D1: If yes, number and example of roles: Not Applicable.

Migrant Workers (this should include all

migrant workers including permanent
workers, temporary and/or seasonal
workers)

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NON-EMPLOYEE WORKERS

Recruitment Fees:
A: Are there any fees? Yes
No
B: If yes, check all that Recruitment / hiring fees
apply: Service fees
Application costs
Recommendation fees
Placement fees
Administrative, overhead or processing fees
Skills tests
Certifications
Medical screenings
Passports/ID’s
Work / resident permits
Birth certificates
Police clearance fees
Any transportation and lodging costs after employment offer
Any transport costs between work place and home
Any relocation costs after commencement of employment
New hire training / orientation fees
Medical exam fees
Deposit bonds or other deposits
Any other non-monetary assets
Other

B1 – If other, please give details: Not Applicable.

C: If any checked, give Not Applicable.
details:

Agency Workers (if applicable)

(workers sourced from a local agent who are not directly paid by the site, but paid by the agency, Usually the
agencies are paid by the site and the wages of the individual workers are paid by the agency.)

A: Number of agencies used A1: Names if available: Not Applicable

(average):

B: Were agency workers’ age / Yes

pay / hours included within the No
scope of this audit? Not applicable

C: Were sufficient documents for Yes

agency workers available for No
review? Not applicable

D: Is there a legal contract / Yes

agreement with all agencies? No

D1: Please give details: Not Applicable

E: Does the site have a system for Yes

checking labour standards of No
agencies?
If yes, please give details. E1: Please give details: Not Applicable

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Contractors:
Note: contractors in this context are generally individuals who supply several workers to a site. Usually the contractors
are paid by the site and the wages of the workers are paid by the contractor. Common terms include, gang bosses,
labor provider,

Yes
No
A: Any contractors on site?
A1: If yes, how many contractors are present, please give details:
Not Applicable

B: If Yes, how many workers supplied

Not Applicable
by contractors?

C: Do all contractor workers Yes

understand their terms of No
employment? C1: Please describe finding: Not Applicable

D: If Yes, please give evidence for

Not Applicable
contractor workers being paid per law:

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8A: Sub–Contracting and Homeworking

(Click here to return to summary of findings)
(Click here to return to Key Information)

8A.1 There should be no sub–contracting unless previously agreed with the main client.
8A.2 Systems and processes should be in place to manage sub–contracting, homeworking and external
processing.
Note to auditor on homeworking:
Report on whether it is direct or via agents. How many workers, relationship with site and what control
systems are in place.
Note to auditor on subcontracting: auditor should use this section for subcontractors of part made or
wholly made finished goods, this section should not be used for raw material manufacturers unless
instructed otherwise by customers

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what releva nt
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
• As per the facility documents review, management, workers interview and factory tour, there was no
sub-contractor or home working used by facility currently.
• Therefore, no apparent concern was detected regarding this section.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. Site tour (Calculation on total production and estimated capacity)
2. Materials in/out records
3. Management interview
4. Worker interview

Any other comments: None

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI/Additional Elements NC against Local Law observed:
NC against customer code: Not applicable
None observed
Local law and/or ETI /Additional Elements requirement:
Not applicable
Recommended corrective action:
Not applicable

Observation:

Description of observation: Objective evidence

None observed observed:
Local law or ETI/Additional elements requirement: Not applicable

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Not applicable
Comments:
Not applicable

Good Examples observed:

Description of Good Example (GE): Objective Evidence

None observed Observed:
Not applicable

Summary of sub–contracting – if applicable

Not Applicable please x

A: Has the auditor made a simple Yes

calculation to compare capacity No
with workers’ work load in order to A1: Please describe:
identify possible unrecorded work
or undeclared sub-contracting

B: If sub–contractors are used, is Yes

there evidence this has been No
agreed with the main client? B1: If Yes, summarise details:

C: Number of sub–
contractors/agents used:

D: Is there a site policy on sub– Yes

contracting? No
D1: If Yes, summarise details:

E: What checks are in place to

ensure no child labour is being
used and work is safe?

Summary of homeworking – if applicable

Not Applicable please x

A: If homeworking is being used, is Yes

there evidence this has been No
agreed with the main client? A1: If Yes, summarise details:

B: Number of homeworkers B1: Male: B2: Female: Total:

C: Are homeworkers employed Directly C1: If through agents, number of

direct or through agents? Through Agents agents:

D: Is there a site policy on Yes

homeworking? No

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E: How does the site ensure

worker hours and pay meet local
laws for homeworkers?

F: What processes are carried out

by homeworkers?

G: Do any contracts exist for Yes

homeworkers? No

G1: Please give details:

H: Are full records of homeworkers Yes

available at the site? No

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9: No Harsh or Inhumane Treatment is Allowed

(Click here to return to summary of findings)

ETI
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal
abuse or other forms of intimidation shall be prohibited.
Additional elements:
9.2 companies should provide access to a confidential grievance mechanism for all workers

A: Are there published, anonymous Yes

and/or open channels available for No
reporting any violations of Labour A1: Please give details: Through direct supervisors,
standards and H&S or any other management, suggestion box and worker committee
grievances to a 3rd party? representatives.

B: If Yes, are workers aware of these Workers can share their concern with Welfare Officer; drop to
channels and have access? Please give their complaint into suggestion box and even go to the top
details. management.

C: If yes, what type of mechanism is used Suggestion box and Welfare Officer.
e.g. hotline, whistle blowing mechanism,
comment box etc. Please give details.
D: Which of the following groups is there Workers
a grievance mechanism in place for? Communities
Suppliers
Other

D1: Please give details: All workers were aware of these

processes; suggestion box was known by the workers. Also,
workers can share their concern with union and participation
committee representatives; drop their complains into
suggestion box and even go to the top management.
E: Are there any open disputes? Yes
No
E1: If yes, please give details: Not Applicable

F: Does the site encourage its business Yes

partners (e.g. suppliers) to provide No
individuals and communities with access
to effective grievance mechanisms (e.g. F1: If no, please give details: The factory had no procedure to
helplines or whistle blowing mechanism) encourage to business partners to established grievance
mechanism.
G: Is there a published and transparent Yes
disciplinary procedure? No

G1: If no, please explain: Not Applicable.

H: If yes, are workers aware of these the Yes

disciplinary procedure? No

H1: If no, please give details Not Applicable

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I: Does the disciplinary procedure allow Yes

for deductions from wages (fines) for No
disciplinary purposes (see wages
section)? I1: If yes, please give details: Absent deduction in case of
worker is absent as per law.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what releva nt
procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
• The facility has established anti-harassment or inhumane treatment policy. The policy states that
physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal
abuse or other forms of intimidation shall be prohibited.
• Anti-harassment issue is also covered in employee training.
• Through the factory management and employees’ interview, it was noted that no physical abuse
happened in the factory.
• There is an internal process for grievance, which is through grievance box where an employee can
report any grievances (harassment, discrimination etc.) anonymously, any received complaint will
be handled by management, without any reprisal for the worker in question.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. The relevant policy on prevention of harassment and abuse.
2. Internal grievance procedure documentation.
3. Training records.
4. Management interview and employee interview.

Any other comments: None

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law NC against customer observed:
code: Not Applicable
None Observed
Local law and/or ETI requirement:
Not Applicable
Recommended corrective action:
Not Applicable

Observation:

Description of observation: Objective evidence

None Observed observed:
Local law or ETI requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

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Good Examples observed:

Description of Good Example (GE): Objective Evidence

None Observed Observed:
Not Applicable

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10. Other Issue areas: 10A: Entitlement to Work and Immigration

(Click here to return to NC–table)

Additional Elements
10A.1 Only workers with a legal right to work shall be employed or used by the supplier.
10A.2 All workers, including employment agency staff, must be validated by the supplier for their legal
right to work by reviewing original documentation.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detai l
any documentary or verbal evidence shown to support the systems.

Current systems:
• Per document review, factory management representation and worker interview, it was observed that
all workers in the factory were Bangladeshi and 100% were local workers and no permission is required
for working from one district to another district.
• All workers had the proper legal rights to work in this region.
• All of them were recruited directly by the factory and no agency was involved in factory’s recruitment
processes.
• No agency staff or foreign worker was used by the factory.
• There were not any deductions for items such as equipment.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
1. Hiring procedure
2. Personnel files
3. Worker handbook
4. Worker interview
5. Management interview

Any other comments: None

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI/Additional Elements NC against Local Law observed:
NC against customer code: Not Applicable
None Observed
Local law and/or ETI /Additional Elements requirement:
Not Applicable
Recommended corrective action:
Not Applicable

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Observation:

Description of observation: Objective evidence

None Observed observed:
Local law or ETI/Additional Elements requirement: Not Applicable
Not Applicable
Comments:
Not Applicable

Good examples observed:

Description of Good Example (GE): Objective Evidence

None Observed Observed:
Not Applicable

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10. Other issue areas 10B4: Environment 4–Pillar

(Click here to return to summary of findings)
To be completed for a 4–Pillar SMETA Audit and remove the previous page which is 10B2 environment 2
pillar

B.4. Compliance Requirements

10B4.1 Businesses as a minimum must meet the requirements of local and national laws related to
environmental standards.
10B4.2 Where it is a legal requirement, businesses must be able to demonstrate that they have the
relevant valid permits including for use and disposal of resources e.g. water, waste etc.
10B4.3 Businesses shall be aware of their end client’s environmental standards/code requirements
10B4.4 Suppliers should have an environmental policy, covering their environmental impact, which is
communicated to all appropriate parties, including its own suppliers.
10B4.5 Suppliers shall be aware of the significant environmental impact of their site and its processes.
10B4.6 The site should measure its impacts, including continuous recording and regular reviews of use and
discharge of natural resources e.g. energy use, water use (see 4–pillar audit report and audit checks for
details).
10B4.7 Businesses shall make continuous improvements in their environmental performance.
10B4.8 Businesses shall have available for review any environmental certifications or any environmental
management systems documentation
10B4.9 Businesses should have a nominated individual responsible for co–ordinating the site’s efforts to
improve environmental performance.
B4. Guidance for Observations
10B4.10 Suppliers should have completed the appropriate section of the SAQ and made it available to
the auditor.
10B4.11 Has the site recently been subject to (or pending) any fines/prosecutions for noncompliance to
environmental regulations.

Note for auditors and readers. This environment section is intended to take not more than 0.25 auditor
days. It is an assessment only and the main requirement is to establish whether a site is meeting
applicable environmental laws and/or has any certifications or environmental management systems in
place. Following this assessment, the client/supplier may decide a full environmental audit is required (see
also best practice guidance/environment and guidance for auditor)

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detai l
any documentary or verbal evidence shown to support the systems.

Current systems:
• Factory management has appointed a designated person named Md. Masud Rana, Officer
(Environment).
• Production process of the factory is Yarn Dyeing, Yarn Dyeing Finishing, Warping, Sizing, Weaving,
Terry Dyeing, Terry Dyeing Finishing, Cutting, Sewing, Embroidery, Finishing & Packing. Facility uses
chemical for their production process and provided training and Personal Protection Equipment.
MSDS, label and secondary containment found with all the chemicals. Factory management has
conducted training on minimal uses of water, energy and natural resource to all employees.
• Factory management has the agreement with waste collect company for the disposal of general
wastages like wastage fabrics, poly, cone, chemical containers, metal, cartons, papers etc. Factory
management is aware about the environmental impact of their business activities.

One non-compliance and three good examples were found in the areas of “10B4: Environment 4–Pillar”.
For details, please refer to contents of ‘Non- Compliance’ & ‘Good Example’.

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Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
Environmental policy and procedure, training record, different types of records for energy and water
consumption, license, chemical inventory etc.

Any other comments: None

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI NC against Local Law NC against customer code: observed:
1. Based on documents
It was noted through documents review and management interview that waste review and
water test report was expired on 23rd January 2022. Noted that the facility had management interview
already applied to the concerned authority for conducting waste water test on
7th March, 2022.

Local law and/or ETI requirement

In accordance with Additional Elements 10B4.1: Businesses as a minimum must
meet the requirements of local and national laws related to environmental
standards.

In accordance with The Environment Clearance Certificate, Condition No. 9: The

facility shall conduct the waste water test (before and after the waste water
treatment) once in every three months (four times in a year) and submit the said
test report to the Department of Environment during the factory operation
(translated).

Recommended corrective action: It is recommended that the facility

management shall collect the updated waste water test report from concerned
authority as soon as possible.

Action by: Md. Sultan Salah Uddin, AGM (Compliance)

Time scale: 30 Days.

Observation:

Description of observation: Objective evidence

None observed observed:
Local law or ETI/Additional elements requirements: Not applicable
Not applicable
Comments:
Not applicable

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Good examples observed:

Description of Good Example (GE): Objective Evidence

Observed:
1. The factory has installed 200 kWh solar panels, which are being used in entire Based on plant tour,
stitching building. documents review and
management interview
2. The factory has implemented rainwater harvesting system, which is reducing
groundwater extraction.

3. The factory is using less water consuming Dyes chemicals in production

process, which are reducing water consumption.

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Environmental Analysis
(Site declaration only – this has not been verified by auditor. Please state units in all cases below.)

A: Is there a manager responsible for Environmental Md. Masud Rana- Officer (Compliance)
issues (Name and Position):

B: Has the site conducted a risk assessment on the Yes No

environmental impact of the site, including B1: Please give details: The factory had conducted
implementation of controls to reduce identified risk assessment on the environmental impact of the
risks? site, including implementation of controls to reduce
identified risk.

C: Does the site have a recognised environmental Yes No

system certification such as ISO 14000 or C1: Please give details: The site has a recognised
equivalent? Please give details. environmental system certification e.g. ISO 14001,
which is valid till on 01 November 2024.

D: Does the site have an Environmental policy? Yes No

(For guidance, please see Measurement criteria) D1: If yes, is it publicly available? During audit, policy
was found available.

E: If yes, does it address the key impacts from their Yes No

operations and their commitment to improvement? E1: Please give details: Factory had environmental
policy and procedure. Environment procedures
defined for implementation and management of
environmental performance.

F: Does the site have a Biodiversity policy? Yes No

(For guidance, please see Measurement criteria)

G: Is there any other sustainability systems Yes No

present such as Chain of Custody, Forest G1: Please give details: No such system was found
Stewardship Council (FSC), Marine
Stewardship Council (MSC) etc.?
Please gives details.
(For guidance, please see Measurement criteria)

H: Have all legally required permits been shown? Yes No

Please gives details. H1: Please give details: Factory showed legal
permits.

I: Is there a documentation process to record Yes No N/A

hazardous chemicals used in the manufacturing I1: Please give details: Facility uses chemicals for their
process? production process. Documented records for
hazardous chemicals are maintained.

J: Is there a system for managing client’s Yes No

requirements and legislation in the destination J1: Please give details: Factory has valid
countries regarding environmental and chemical Environment Clearance Certificate No. 22- 70798,
issues? valid until 01 September 2022. Facility has not used
any banned chemicals for their production process.

K: Facility has reduction targets in place for Yes No

environmental aspects e.g. water consumption K1: Please give details: Facility has set up target to
reduce water, electricity and diesel consumption.

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and discharge, waste, energy and green-house Different types of records for energy and water
gas emissions: consumption include continuous recording and
regular reviews of use and discharge of natural
resources e.g. energy use, gas use.

L: Facility has evidence of waste recycling and is Yes No

monitoring volume of waste that is recycled. L1: Please give details: The facility did not recycle the
waste. They handed over the waste to nominated
vendor/ waste collector.

M: Does the facility have a system in place for Yes No

accurately measuring and monitoring consumption M1: Please give details: Facility has system in place
of key utilities of water, energy and natural for accurately measuring and monitoring
resources that follows recognised protocols or consumption of key utilities of water, energy and
standards? natural resources that follows recognised protocols
or standards.

N: Has the facility checked that any Sub- Yes No

Contracting agencies or business partners N1: Please give details: Facility kept copy of Waste
operating on the premises have the appropriate collector license.
permits and licences and are conducting business
in line with environmental expectations of the
facility?

Usage/Discharge analysis

Criteria Previous year: Please Current Year: Please

state period: January state period: January
2021 to December 2021 2022 to March 2022

Electricity Usage:
2,560,210 Kw/hrs 208,120 Kw/hrs
Kw/hrs

Renewable Energy Usage: 229,676 Kw/hrs 60,062 Kw/hrs

Kw/hrs

Gas Usage:
42,006,839.40 m3 9,016,684 m3
Kw/hrs

Has site completed any carbon Footprint Analysis? No No

If Yes, please state result N/A N/A

Water Sources: Ground Water & Ground Water &

Please list all sources e.g. lake, river, and local water
authority.
Rain Water Rain Water

Water Volume Used:

1,843,237 m3 424,789.63 m3
(m³)

Water Discharged:
Through ETP Through ETP
Please list all receiving waters/recipients.

Water Volume Discharged:

1,689,361 m3 374,855 m3
(m³)

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Water Volume Recycled: No No

(m³)

Total waste Produced

1,498,015.3 Kg 522,409.85 Kg
(please state units)

Total hazardous waste Produced:

450,120.75 Kg 86,305.95 Kg
(please state units)

Waste to Recycling:
No No
(please state units)

Waste to Landfill:
No No
(please state units)

Waste to other:
No No
(please give details and state units)

Total Product Produced

16,272,476 Kg 365,600 Kg
(please state units)

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10C: Business Ethics – 4-Pillar Audit

(Click here to return to summary of findings)
To be completed for a 4–Pillar SMETA Audit

10C. Compliance Requirements

10C.1 Businesses shall conduct their business ethically without bribery, corruption, or any type of
fraudulent Business Practice.
10C.2 Businesses as a minimum must meet the requirements of local and national laws related to bribery,
corruption, or any type of fraudulent Business Practices.
10C.3 Where it is a legal requirement, businesses must be able to demonstrate that they comply
with all fiscal legislative requirements.
10C.4 Businesses shall have access to a transparent system in place for confidentially reporting, and
dealing with unethical Business Ethics without fear of reprisals towards the reporter.
10C.5 Businesses should have a Business Ethics policy, covering bribery, corruption, or any type of
fraudulent Business Practice,
10C.6 Businesses should have a designated person responsible for implementing standards concerning
Business Ethics
10C.7 Suppliers should ensure that the staff whose job roles carry a higher level of risk in the area of
ethical Business Practice e.g. sales, purchasing, logistics are trained on what action to take in the event of
an issue arising in their area.

10C. Guidance for Observations

10C.8 Businesses should communicate their Business Ethics policy, covering bribery, corruption, or any
type of fraudulent Business Practice to all appropriate parties, including its own suppliers.
10C.9 Has the site recently been subject to (or pending) any fines/prosecutions for non-compliance to
Business Ethics regulations. If so is there evidence that sustainable corrective actions have been
implemented

Note for auditors and readers. This Business Ethics section is intended to take not more than 0.25 auditor
days. It is an assessment not an audit.

Current Systems and Evidence Examined

To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail
any documentary or verbal evidence shown to support the systems.

Current systems:
• Md. Sultan Salah Uddin- AGM (Compliance) was the designated person responsible for implementing
standards concerning Business Ethics, and that site practices were conducted without any corruption
and/or bribery.
• The company established a business ethics policy to communicate both externally and internally and
provide training on business ethics.
• There is an internal grievance process on site.

Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):

Details:
• The company business ethics policy including Bribery & Corruption
• Training records
• Worker handbook
• Reports from Anonymous email account
• Management interview

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• Worker interview

Any other comments: None

Non–compliance:

1. Description of non–compliance: Objective evidence

NC against ETI/Additional Elements NC against Local observed:
NC against customer code: Not applicable
None Observed
Local law and/or ETI/Additional Elements requirement:
Not applicable
Recommended corrective action:
Not applicable

Observation

Description of observation: Objective evidence

None Observed observed:
Local law or ETI/Additional elements requirement: Not applicable
Not applicable
Comments:
Not applicable

Good examples observed:

Description of Good Example (GE): Objective Evidence

None Observed Observed:
Not Applicable

A: Does the facility have a Business Ethics Internal Policy

Policy and is the policy communicated and Policy for third parties including suppliers
applied internally, externally or both, as
appropriate? A1: Please give details: The factory has a Business Ethics
Policy and the policy communicated and applied both
internally and externally. The both communication and
application performed through training, notice board and
providing policy requirement to external stake holders.
B: Does the site give training to relevant Yes
personnel (e.g. sales and logistics) on No
business ethics issues?
B1: Please give details: The site provided training records
about sales and logistics member on business ethics for
review.
C: Is the policy updated on a regular (as Yes
needed) basis? No

C1: Please give details: Factory has updated regular basis

business ethics policy and procedure.

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D: Does the site require third parties Yes

including suppliers to complete their own No
business ethics training
D1: Please give details: Site has conducted training on anti-
corruption and bribery policy to their own supplier and
employees.

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Other findings
Other Findings Outside the Scope of the Code

None Observed

Community Benefits
(Please list below any specific community benefits that the site management stated that they were involved in, for
example, HIV programme, education, sports facilities)

None Observed

Appendix 1
Comparison between ETI code and Customer's Supplier's Code. Any areas where a site complies with the
Customer's Supplier Code, but not with the ETI code are discussed at the audit close out meeting and
recorded on the CAPR. Note to supplier "for this customer it may not be necessary to complete corrective
actions where NC's DO NOT meet the ETI code, but DO meet your customer's code. If the audit is shared
with other customers who work to the ETI code or an equivalent international standard, corrective actions
will be necessary."
Not Applicable please x

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Photo Form

Factory Name Factory Main Gate Factory Building

Roof Top Lightning Arrester Solar Panels

Yarn Dyeing Section Yarn Dyeing Finishing Section Soft Winding Section

Twisting Section Warping Section Sizing Section

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Weaving Section Fabric Inspection Section Fabric Dyeing Section

Fabric Dyeing Finishing Section Cutting Section Sewing Section

Embroidery Section Finishing Section Packing Section

Yarn Store Grey Fabric Area Finished Fabric Area

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Accessories Store Finished Goods Area Emergency Evacuation Plan

Fire Extinguishers Auto Fire Extinguisher Fire Hose Pipe

Firefighting Equipment Fire Hydrant Pump Pillar Hydrant Connection

Smoke Detection System Flame Detection System Sprinkler System

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PA System Fire Alarm Switch Fire Alarm Bell

Gong Bell Fire Monitoring Panels Exit Sign

Emergency Exit Sign Emergency Light Fog Light

Fire Rated Door Fire Hose Pipe Checking Notice Board

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Policy Board ETI Base Code Poster Awareness Poster

Risk Related Awareness Poster Awareness Poster (COVID-19) Electric Shock: First Aid Procedures

First Aid Box Medical Room Child Care Room

Drinking Water Facility Personal Lockers (For Workers) Lunch Bell

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Dining Hall Canteen Attendance Machines

Grievance Box Pest Control System Facility Staircase

ETP WTP Boiler

Exhaust Gas Boiler (EGB) Generator Compressor

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Chiller Machine Transformer Sub-station

Non-compliance photo

Eye guard with overlock machine Worker was not using earplugs Worker was not using earplugs
was misplaced at sample sewing while working at texpa hamming while working at sizing section
section section NC Picture No. 03
NC Picture No. 01 NC Picture No. 02

Worker was not using earplugs Worker was not using earplugs Heavy trolley loaders were not
while working at warping section while working at twisting section using safety shoes while working
NC Picture No. 04 NC Picture No. 05 NC Picture No. 06

Audit company: GSCS International Ltd. Report reference: BD2022140063 Date: 19th & 20th April, 2022 86
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Audit company: GSCS International Ltd. Report reference: BD2022140063 Date: 19th & 20th April, 2022 87