Sedex Members Ethical Trade Audit

(SMETA) Measurement Criteria

Version 5.0 December 2014 (Replaces V. 4.0 May 2012). This Measurement Criteria covers both a 2-Pillar SMETA
Audit and a 4-Pillar SMETA Audit which includes the 2 optional pillars of Environment and Business Ethics.

This Measurement Criteria for conducting SMETA audits

has been developed by the current members of the
Sedex Associate Auditor Group (AAG). The Measurement
Criteria covers the mandatory 2 pillars of Labour
Standards and Health and Safety as well as the additional
options of Environment and Business Ethics.
 SMETA Measurement Criteria (Version 5.0, December 2014)

CONTENTS

BACKGROUND 4
Introduction 4
The Audit Process 5
Audit Report Completion 5
Useful Documents 6

MEASUREMENT CRITERIA
BY CLAUSE 7
0. Management Systems 7
1. Employment is Freely Chosen 9
2. Freedom of Association 12
3. Health & Safety 16
4. Child Labour 20
5. Wages & Benefits 24
6. Working Hours 29
7. Discrimination 36

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8. Regular Employment 39
8A. Sub-Contracting & Homeworking 41
9. No Harsh or Inhumane Treatment is Allowed 43
10. Other Issues 45
10A. Entitlement to work 45
10B2. Environment 2-Pillar 47
10B4. Environment 4-Pillar 48
10C. Business Ethics 51
11. Community Benefits 54

MEASURING IMPACT 55

ENCOURAGING WORKER
MANAGEMENT DIALOGUE 58

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 SMETA Measurement Criteria (Version 5.0, December 2014)

SMETA Measurement Criteria

BACKGROUND
Introduction
SMETA guidance has now been split into 2 parts, one describes the audit methodology
(now called the Best Practice Guidance – BPG) and the second part details
Measurement Criteria (this document).
SMETA (Sedex Members Ethical Trade Audit) is the audit methodology created by the Sedex members to give a
central agreed protocol which can be shared with confidence. The methodology is described in the following
two documents:
● SMETA Best Practice Guidance: describes the key stages of a SMETA audit from Self-Assessment
Questionnaire, through Risk Assessment and Audit and up to Audit upload followed by continuous
improvement, which is then measured by follow-up audit.
● SMETA Measurement Criteria (this document): gives clear instruction on the items to be checked at
audit, governed by the standard of the Ethical Trading Initiative ETI Base Code as well as the law.
Sedex members are committed to a process of continuous improvement (see 'The Sedex Model' below) which
includes the important element of auditing.

The Sedex Model

No action
A and AB members join
and ask their suppliers to Verification
join as well. of actions

Risk assessment
based on:
Supply • Country
chain Initial Continuous
• Product area
assessment Improvement
map • Site profile
• Self-assessment / Compliance
Questionnaire Improvement
and actions
required
Key Principles of Sedex:
• Supplier owns own data
• Supplier controls who can see data
Audit
• Company members cannot see into
each others supply chains
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The Audit Process

This describes how an audit should be carried out on the day.
This is clearly set out in the 'SMETA Best Practice Guidance' which should be used in conjunction with this
Measurement Criteria.

Audit Report Completion

An auditor is not only auditing to find non compliances, observations and good practices, they should also be
auditing to record improvements. This should include recording the current system which the site uses to
manage all aspects of its labour standards. This is captured under 'Current Systems and Evidence Examined'.
A site will already have systems in place to enable production or processes to take place and since a
key part of production is the workforce involved, the systems present will include processes to manage
that workforce. By examining and reporting on the existing systems at a site, an auditor will encourage
management to identify any gaps for themselves as well as create their own solutions.
For continuous improvement it is essential that the auditor records what policies, procedures and practices
actually exist at the site. For collaboration on continuous improvement between customers and suppliers it is
necessary to understand the start point and the improvements a site makes as part of its journey towards
compliance. This can often be demonstrated by reviewing a site’s procedures and highlighting any change in
internal procedures and processes. Even though non-compliances may still exist the site may have
implemented a system to monitor non-compliances and to ensure that they move towards compliance on a
gradual basis. It is important that the auditor captures this information.
Thus the auditor should not only be recording non-compliances, observations and good practices, but they
should also pay special attention to the verbal information given at management interviews which will indicate
what processes and controls are already in place. This should then be corroborated by examining the
documentary evidence along with the appropriate responsible managers. It will allow managers to re-examine
their own practices and procedures as well as allowing them to demonstrate where there have been
improvements in their method of management.
How a site manages its labour standards should be recorded in the ‘SMETA Audit Report’ in each section of
'Audit Results by Clause' under 'Current Systems and Evidence Examined'. This should be completed for each
clause of the code even where there are no non-compliances, observations or good examples.

‘Current Systems and Evidence Examined' should be used to positively record what controls and processes are
already in place at the site e.g.
● Are there any policies and if so what are they (upload as appropriate).
● What procedures are already in place.
● What practices are carried out and by which responsible personnel.
● How does the site monitor that its practices are working.
● What training and communication is already carried out to ensure that site personnel are aware of
policies and are able to correctly perform procedures.
As an example under section 4 ‘Child labour shall not be used’ the auditor should investigate and record how the
site checks the ages of workers at recruitment e.g. what is the procedure used; is it written down sufficiently that
another person could take on the role if the responsible person were absent or had left etc.

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The emphasis in this section is on the processes that are in place and whether these constitute an effective
management system which will ensure that non-compliances are avoided i.e. preventative actions not only
corrective actions. The system a site uses should be reported under each code item in the 'Current Systems and
Evidence Examined' box.
These measurement criteria are based on the Ethical Trading Initiative ETI Base Code, but can be adopted and
tailored to use with other codes of conduct. The ETI Base Code is based on international standards and ILO
conventions and this guidance should therefore agree with the majority of codes and standards currently in use.

Note: In addition, for SMETA there are other issue areas such as Management Systems, Entitlement to Work,
Sub-Contracting & Homeworking, Environment (shortened for a 2-Pillar SMETA and extended for a 4-Pillar
SMETA) and Business Ethics. These have been developed by a consultation process involving the membership
and external stakeholders.

Useful Documents
Sites are encouraged to examine their own practices in advance of an audit and make improvements in
advance where appropriate. In this way an audit will be an objective and independent assessment of a site’s
good practice.
To support the process there are a range of documents provided by Sedex and its membership:
● SMETA Best Practice Guidance: which describes the Audit process.
● SMETA Measurement Criteria: (this document) which gives details of the items to be examined during
a SMETA audit.
● SMETA Audit Report: provides a template for recording audit findings in a standardised format that
can be uploaded into Sedex.
● SMETA Corrective Action Plan Report (CAPR): a template for recording a summary of audit findings,
along with corresponding corrective actions.

In addition Sedex has created the two publicly available supporting documents:
● SMETA Pre-Audit Information Pack: which contains information to be sent to a supplier site before a
SMETA audit.
● Supplementary Guidance for Auditing Service Providers.

Additional documents which support the audit process can be found on the member resources of Sedex.
These include:
● SMETA Guide to Social Systems Auditor Competencies: competency requirements for auditors
who practice social audits.
● SMETA Non-Compliance Guidance: recommended issue severities and verification methods.
● SMETA Corrective Action Guidance: suggested ways in which sites may make improvements.
● SMETA Guidance for Auditors for Extended Environment and Business Ethics Assessment:
assessment checks for Auditors.
● SMETA Guidance for Suppliers for Extended Environment and Business Ethics Assessment:
guide for Supplier Sites.
All the above should be used in conjunction with the four core documents.
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MEASUREMENT CRITERIA BY CLAUSE

0. Management Systems

CODE
0.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code.
0.2 Suppliers shall appoint a senior member of management who shall be responsible for compliance with
the Code.
0.3 Suppliers are expected to communicate this Code to all employees.
0.4 Suppliers should communicate this code to their own suppliers and, where reasonably practicable,
extend the principles of this Ethical Code through their supply chain.

Note: 0.4 Is for information only and is not a specific requirement of the code. Failure to communicate the code
to their own suppliers should be recorded as an observation not a non-compliance.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Management Systems'.
Auditors examine policies and written procedures in conjunction with relevant managers, to understand and
record what systems, controls and processes are currently in place to manage the sites compliance to local,
national and international laws and standards as well as client requirements.
In this section the auditor also checks whether the site knows and is up to date with, relevant local law, the ETI
Base Code and the standards required e.g.

● What resources does the site have to manage its labour force, is there a Human resources
department/responsible manager, this information should be recorded under this section.

● Does the site track any indicators such as worker turnover rates, absenteeism, number of grievances
etc. Any available details can be recorded here as well as the appropriate areas of the audit report.

● Whether they are up to date with the local law and how they stay up to date. What kind of relationship
do they have with the local labour office.

● Do they do their own checks internally.

● Who is responsible for the management of labour standards at the site and do they have the correct
level of authority to make improvements.

● Are there any checks performed by local government and if so what are they and what were the results.

● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.

● Are there any certifications at the site, such as ISO 14000, ISO 9000 etc. These should be recorded here.
See below for more detailed information.

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MEASUREMENT CITERIA
Management system investigation and document review, including management interview.
The auditor checks and reports on:
0.1 Whether the site has a social compliance/ethical trade policy and written procedures which meet
the Code and International Labour Standards.
0.2 Looks for specific policies and procedures which ensure the site meets in particular freedom of
association, discrimination and general human rights standards.
0.3 Checks whether the site knows the local laws concerning Labour Standards e.g. age, wages,
hours of work, Health & Safety etc. Whether there is a system in place to keep up to date with all
local laws concerning workplace requirements, Labour Standards, Environment etc.
0.4 Records whether resources are allocated to implement any systems and procedures including
the appointment of a senior responsible manager.
0.5 Reviews whether there is a system to measure the effectiveness of these policies and
procedures, such as by internal audit.
0.6 Checks that the site is aware of specific client requirements such as client’s policy on labour
standards, labelling, quality, environment and shows commitment to work with their clients to
meet these requirements.
0.7 Checks that the ETI Base Code or client specific codes have been communicated to on-site
workers including, local labour laws/labour rights and how this has been done e.g. posters,
worker trainings etc. (In cases where literacy level is low, what method of communication is
used).
0.8 Establishes what action is taken to communicate and implement the code in its own supply chain
e.g. to raw material suppliers.
0.9 Check whether the site has a list of subcontractors (where relevant) and has
communicated/monitored labour standards at these subcontractors.
0.10 Check that the site has all applicable/required land rights, licences and permission.
0.11 In the last 12 months, has the site been subject to (or pending) any fines/prosecutions for non-
compliance to any regulations.

Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system in place, document review and management interview by
worker testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
0.12 Have the codes been communicated and how.
0.13 Has there been any training on labour standards and for non-native speakers or less literate
workers etc. what method of communication was used.

Note: The auditor should check that the management system is appropriate for the size and nature of the
business. Formal documented systems are not necessarily expected for smaller organisations.

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1. Employment is Freely Chosen

CODE
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

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Employment is Freely Chosen'.
Auditors examine policies and written procedures in conjunction with relevant managers, to understand and
record what controls and processes are currently in place to manage employment is freely chosen.
In this section the auditor also checks whether the site knows and is up to date with, relevant local law, the ETI
Base Code and the standards required e.g.

● How are workers recruited – record details in this section – are Agencies/Labour providers used and if
so are they local or in another region/country.

● Does the site check on the hiring procedures of any Labour Agents used. Are they aware of any
deposits paid by workers for their jobs, either at the site or at their place of origin (this should be
confirmed by worker interview).

● How does a worker resign and what notice is required.

● Is there a loan fund and how is it managed.

● Does the site have a policy on e.g. the use of prison labour.

● Do they have a system for checking that no worker’s original papers are withheld e.g. Passports or ID’s
either by the site or any of its labour agents.

● In countries where it is a legal requirement to retain the papers of e.g. country migrant workers, can
workers access their papers if required.

● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
See below for more detailed information.

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MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:

1.1 Contracts:

a. Do all workers have a contract of employment detailing their rights and obligations as well as
notice and grievance procedures.
b. Is the contract in a language understood by the workers.
c. Do all workers have a signed copy of their contract.
d. Can workers voluntarily leave their employment after reasonable notice.
e. Is there a process in place for workers to receive their final salary payment if they do not
return e.g. after Chinese New Year.
f. Are there any clauses in contracts that would restrict workers leaving.
g. Are there any financial arrangements e.g. loans which would restrict workers leaving.
h. Are there clauses in the contract/job description for security guards which allow them to
restrict worker movements.
i. Are workers free to leave at the end of their shift and not unreasonably delayed by e.g.
security checks.
j. Are workers free to refuse overtime and if so how.

1.2 Personnel files:

a. Do employers keep only copies of ID’s Passports and Right to Work checks.
b. Whether originals are returned to workers.
c. If it is a legal requirement to retain original documents, do workers give their written consent
and can they retrieve their documents at any time.
d. Where there are loans to workers are they covered by a signed agreement from both parties
and do they detail repayments, terms and conditions.
e. Is there a procedure in place to either re-assign any outstanding loan to a new employer or a
process for early re-payment, such that a loan does not prevent a worker leaving
employment.
f. Is there a process for preventing worker debt from e.g. recruitment fees and how is this
checked.

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1.3 Wage deductions, any deposits or withholdings (other than mandatory e.g. tax and social
insurance) to establish:
a. That there is a written agreement to the deduction, signed by the worker.
b. That deductions are reasonable and meet the law.
c. That any deductions do not reduce wages to below minimum legal wage.
d. Whether deductions are for disciplinary reasons and whether this is legal.
e. Whether there are any voluntary deductions and if so do they meet the law.
f. Exact details of any voluntary deductions (although they may meet the law they may not
meet the code).
g. That deposits are not taken for workplace essentials such as PPE.
h. That deposits are not a compulsory condition of gaining employment.
i. That any agreed (by the worker) and withheld deposits/withholdings are returned to the
worker as appropriate.
j. That there are no other deductions when commencing, during, or as a condition of
employment.

1.4 Where there is any prison labour (legally required in some countries), the auditor must record the
details of such employment checking:
a. That any prisoners are working voluntarily.
b. That the work is under the control of the legal authority.
c. Pay and hours meet the law.

Note: Any such scheme, where prison labour is voluntary, the workers are paid minimum wage plus overtime
and that access to paid work is not discriminatory should be recorded as an observation and the exact situation
should be documented on the audit report. If the full conditions of any prison labour present cannot be
established, a non-compliance should be raised.

Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system in place, document review and management interview by
worker testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
1.5 Are workers working voluntarily and can they leave their employment after reasonable notice. Do
they know the procedure for giving notice.
1.6 Have any workers made deposits and if so what for and when will they be repaid.
1.7 Do workers pay deposits for essential work items such as PPE.
1.8 Whether they have possession of their original documents e.g. passports/ID’s and if not why not.
1.9 Where workers must surrender their original ID’s for legal reasons, do they know how to retrieve
them.

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1.10 Do workers feel free to leave site during breaks and rest time and at the end of shift.
1.11 Can they refuse to do overtime and if so how.
1.12 Are any searches performed on workers handled with respect and without restricting movement
e.g. leaving at the end of shift.
1.13 Are dormitories secure and do workers feel that they can leave them when they wish.
1.14 If there are hours restrictions e.g. curfews, do workers feel these are reasonable.
1.15 If any workers have loans have they agreed in writing to the amount and the terms and do they
understand and believe them to be reasonable.
1.16 Whether workers have ever noticed other workers who were forced to work at this site.

2. Freedom of Association

CODE
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

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Freedom of Association'.
Interview information is especially important in this area. It is essential to interview any workers who are
designated as "union reps" "worker representatives", "workers committee members". Several countries now
have legal requirements governing the need for mandatory unions, or workers committees. It is essential to
record whether these are effective.

Note: Auditors should always request at least at the opening meeting (and preferably in the pre-audit
communication), that the worker representatives/union representatives are present at the opening meeting and
closing meeting. If workers are not present this must be recorded on the audit report along with reasons why
not.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage the area of freedom of association.
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In this section the auditor also checks whether the site knows and is up to date with, relevant local law, the ETI
Base Code and the standards required e.g.

● Is there a union or any worker representation present at the site and has the site facilitated this.

● What is the local law on freedom of association and is the site aware of it – do they meet it.

● Where worker representation does exist is it effective (confirmed by interview with workers e.g. how
often do they meet with management and what are the outcomes).

● Are meetings documented and communicated to the workforce.

● How workers feel about their representatives, do they know who they are, do they feel fairly
represented.

● Where no worker representation exits what is the on-site communication method between managers
and workers.

● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
It is not acceptable for auditors to record "management have an open door policy" and "no problems in this
area", unless this is confirmed strongly by interviews with all parties and they confirm they are satisfied with this
situation – it may be acceptable in some small units.
Sedex members are increasingly more interested in Freedom of Association as a demonstration of effective
management and worker dialogue which can result in the site and its workers being able to manage and
improve their own labour standards.

Note: Prior to conducting an audit, auditors should:

● Understand the local context in practice, site/sector/regional issues. Be aware of and up to date with,
appropriate local and national laws. Check relevant sources and maintain a relationship with key trade
unions (where they exist) and NGOs in the countries where they carry out audits. N.B. auditors must
not share the site names with outside agencies. International Trade Union Confederation
(www.ituc-csi.org) provides useful information on union activity, campaigns and reported issues
concerning Freedom of Association.

● In the case where the site of employment is very small (i.e. < 30 people, may be governed by a law-
auditor should check) and there may not be a committee or other formal structure the auditor verifies
access to line manager and effectiveness.

● To determine the effectiveness of Freedom of Association, auditors should ensure that union and
worker committee members are included in the worker interview sample.

● Questions to verify effectiveness can include how grievances are raised, to whom, how they are
resolved and if workers feel they are listened to and supported.
See below for more detailed information.

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MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
2.0 Whether it is a legal requirement to have a union and/or a workers committee at the site and
records which one(s).
2.1 Whether there is a site policy on freedom of association.
2.2 Checks whether management recognises and negotiates with any unions present.
2.3 Checks that management places no restriction on the establishment and growth of free and
representative workers organisations – including unions.
2.4 Where the right to freedom of association is restricted under law, workforce rights are recognised by
organising parallel means e.g. workers committees.
2.5 Where unions are legally allowed checks:
a. Whether there is a union on site.
b. If workers are free to join the union if they wish.
c. That union officials are freely elected and allowed to perform their functions – with paid time off
if a legal requirement.
d. If the employer takes deductions for union fees checks that, workers have given written
consent that deductions are legal, recorded on wage slips and paid to the union.
2.6 Where workers are represented by a union or workers committee checks:
a. Whether the worker representatives are volunteers and how they are elected.
b. That workers are aware of their union or worker representatives.
c. That the group which represents workers is independent of management and represents
workers effectively.
d. The meeting minutes of both worker meetings and their meetings with management are
published with agreed actions and responsibilities.
e. That management shows evidence of responding to concerns and proposals raised in the
meetings.
f. Whether there is a collective bargaining agreement and if so what % of the workforce is
covered.
g. What feedback arrangements are made for workers who do not wish to join the union e.g.
other workers groups, suggestion box, worker survey, confidential hot line.
2.7 Where workers are not represented by a union or workers committee and the law allows checks:
a. For any policies or procedures preventing workers from joining or forming a union.
b. The site’s attitude if workers wish to join or form a union.
c. How management and workers communicate in the absence of a union or worker’s
committee.
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d. Examines files to establish whether any disciplinary actions or sackings for workers attempting
to start or join a union.
2.8 Examines the personnel files of any union or worker representatives to check:
a. Whether there are any disciplinary records from management.
b. Any evidence of union or worker representatives being discriminated against.
c. Evidence of union members being dismissed.
d. Whether there is payment for time spent in a representative function.
2.9 Establishes whether there have been any strikes at the site and records the dates and
circumstances at least as observations.

Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm, the management system, document review, and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
2.10 Establish whether any workers are members of a trade union or are aware of a trade union on site.
2.11 Whether they feel free to join a union if they choose.
2.12 Whether workers are aware of their rights to organise and bargain collectively.
2.13 Are workers aware of whom their representatives are.
2.14 If workers elect their representatives freely, either for a union or a workers committee.
2.15 If workers are satisfied with their representatives and feel that they are effective.
2.16 Whether any policies and procedures have been communicated to workers by e.g. briefings,
worker handbook and for non-native speakers or those of limited literacy what was the form of
communication.
2.17 Whether collective bargaining agreements have been circulated to workers.
2.18 If workers are aware of any meeting minutes and actions resulting from committee/union meetings
with management.
2.19 If facilities are provided for trade union activities.
2.20 Whether they know of any discrimination against worker reps.
2.21 Whether they are aware of any strikes/industrial action at the site and if so record the
circumstances.
2.22 Interview worker representatives/union representatives and check:
a. Are they free from management interference.
b. How were they elected and was it by the workforce.
c. Do they feel they are permitted to be effective.
d. Do they have facilities for union duties including paid time off.

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e. Whether there are instances of reps being discriminated against or unfairly dismissed.
f. Whether they have been given any training on how to negotiate with management.
g. Whether they are able to communicate grievances to management including supporting
workers in disputes between co-workers with supervisors etc.
h. Are they able to negotiate with management including collectively bargaining.
i. How often do they meet with managers.
j. What topics are covered.

3. Health & Safety

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.
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.
Note: With reference to the International Labour Organisation (ILO) Occupational Safety and Health Convention
155: “The measures taken to facilitate the cooperation referred to in Article 20 of the Convention should include,
where appropriate and necessary, the appointment, in accordance with national practice, of workers’ safety
delegates, of workers’ safety and health committees and/or joint safety and health committees; in joint safety
and health workers should have at least equal representation with employers’ representatives”.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Health & Safety'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage Health & Safety.
In this section the auditor also checks whether the site knows and is up to date with, relevant local law, the ETI
Base Code and the standards required e.g.

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● What are the local laws, is the site aware of them and how do they keep up to date.

● In many areas there are health & safety inspections by the local labour offices, the auditor should
investigate these and record any relevant information.

● Does the site have a recognised occupational health & safety management system such as OHSAS
180001.

● Whether there is a responsible manager for health & safety and do they have the authority to make
changes.

● Are any procedures written down so that responsibility could be taken by another person if necessary. Do
they do Health & Safety Risk Assessments and if so how.

● What systems are in place to record accidents and any figures available such as number of accidents in
the last 12 months and reductions in accidents and any targets.

● Is there any documentary evidence of these practices and certifications present such as fire inspections,
structural safety, if so what are they. The auditor should record the details in this section.
See below for more detailed information.

MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
3.1 Checks whether there is a Health & Safety policy and procedures in place at the site, appropriate to
the size and complexity, both for the workplace and any associated residential facilities.
3.2 Whether there are appropriate Health & Safety risk assessments/site inspections carried out on a
regular basis, how this is recorded and what actions are taken to minimise the risks/hazards found.
These should cover at least (but not be limited to):
a. Working environment.
b. Machinery chemicals and other hazards.
c. Workers in hazardous roles.
d. Young workers/disabled workers/women and other potentially vulnerable workers.
e. Personal protective equipment, it’s issue and use.
f. Worker facilities and resources e.g. dormitory and canteen.
g. Fire risks, including any locked or barred exits/emergency exits.
h. Accidents and on site injuries.
i. Restricted areas are maintained where appropriate e.g. access to hazardous chemicals
storage areas.

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3.3 Checks whether the following documents are available:

a. Building licenses and construction approval from appropriate authorities.
b. Valid inspection certificates as per local regulations.
c. Machine inspections and maintenance reports.
d. Records of fire drills.
e. Appropriate approval certificates for e.g. water use and disposal, waste disposal, hazardous
waste.
f. Any local inspection certificates by local agencies/government e.g. fire, hazardous
substances, waste water (use and disposal), gas emissions etc.
g. Any prosecutions from relevant authorities and what was the outcome.
h. Safety training records and worker training certificates if appropriate e.g. for fork lift truck
driving.
i. Accident/injury/sickness register and any necessary licenses, certifications for e.g.
performing first aid function and/or related Health & Safety functions.
j. Risk assessment reports and action plans for reducing/eliminating the risks identified.
k. Hazardous waste history and tracking records (e.g. disposal certificates).
l. Blood policy and procedures (linked to first aid/injuries).
m. Needle and blade control policies.
n. Electrical safety certificates and records of maintenance checks.
o. Water test for potability.
p. Records of distribution and maintenance of PPE and whether any charge to workers.
q. Checks purchase records for all necessary protective equipment, ensures that there is a
clear history of this being bought and replaced on a regular basis.
r. Site insurance for e.g. workplace, employer liability, worker accident, fire.
s. Material Safety Data Sheet (MSDS) for each hazardous chemical kept on site.
t. Any necessary approvals/certificates for using hazardous machinery or chemicals.
u. Is there an asbestos policy/procedure.
3.4 Checks if there is a Health & Safety committee and whether workers are represented.
a. Examines any minutes of meetings.
b. Notes if any action taken.
c. Interviews the H&S committee to investigate and record its effectiveness.
3.5 For any machinery on site checks documentation.
a. Machinery safety certificate (if required).

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b. That maintenance records are up to date.

3.6 For Health & Safety training records checks that training is appropriate to the task.
a. Use of machinery.
b. Working with and disposal of chemicals.
c. First aid and safety.
d. Housekeeping.
e. Personal protective equipment.
f. Records of training kept in workers personnel files.
3.7 What action is taken against anyone who disregards Health & Safety rules and if this is disciplinary
does this happen at all levels, workers and management.
3.8 During the site tour, auditor makes appropriate checks on e.g. (but not limited to):
a. Fire evacuation plans for workplace and accommodation.
b. Noise and dust levels and records any risk to workers.
c. At least 2 exits on each floor and all exits are unblocked, unbarred and unlocked.
d. Firefighting equipment is sufficient, up to date and meets local regulations.
e. That accommodation is not attached to the production area.
f. That safety precautions in accommodation and worksite are checked regularly to include,
firefighting equipment, exits and regular fire drills and health and hygiene checks, structural safety
certificates.
g. Sufficient clean and hygienic toilets separated by gender and meeting the law.
h. That workers have free access to toilets.
i. That machines are operated in a safe manner with e.g. correct guarding, "2-button operation",
correct safety precautions, including warning signs as necessary.
j. Electrical installation safety e.g. plugs, wiring, cut outs and other control devices.
k. That ventilation, light, temperature, noise level is appropriate and meets the local laws as well as
sufficient for worker comfort.
l. That any hazardous chemicals have MSDS, adequate storage with precautions for spillage, that
they are properly labelled and that workers are correctly trained to use them.
m. That PPE is being correctly used, is free of charge and that workers are fully trained in correct
usage and benefits.
n. That working areas have adequate space, with sufficient ease of access and exit.
o. That medical facilities are appropriate for the size of site and number of workers and meets legal
requirements.
p. That any childcare facilities are legal and meet any local laws/regulations.

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Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
3.9 Check whether there is a Health & Safety committee and are there worker representatives –
interviews the H&S committee members to record their view of its effectiveness.
3.10 What training have workers received.
3.11 Do they know the trained first aiders are and are there enough trained first aiders on each shift.
3.12 Are they aware of the types of common accidents occurring at this site.
3.13 Do they know what to do in case of accidents.
3.14 The intervals between fire drills.
3.15 Do they feel safe and secure in the workplace and are they happy with the general condition e.g.
canteen, hygiene facilities, housekeeping, accommodation etc.
3.16 Do they use PPE and have they been trained in its correct use. Do they understand the risks of
not using it.
3.17 What arrangements are made for them when they are sick.
3.18 How receptive are managers to any concerns raised on Health & Safety.
3.19 What action is taken against anyone who disregards Health & Safety rules and if this is
disciplinary does this happen at all levels, workers and management.
3.20 Do they have free access to toilets.

4. Child Labour and Young Workers

CODE
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.

Note: Definition of "a child" is in accordance to the ILO Conventions for minimum ages (C138) and child labour
(C182). This states that no person will be employed or engaged in work if they are younger than 15 (or 14 in some
developing countries). Light work may be allowed for 12 and 13 year-olds in most developing countries provided it
does not interfere with schooling. However if the legal minimum age is higher than the ILO conventions then no
person may be employed or work if they are younger than the legal minimum age for work in the country of
manufacture, this also applies to persons engaged in a workplace apprenticeship programme.

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CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Child Labour and Young Workers'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage the area of child labour and young
workers.
One of the ways to prevent child labour is to ensure that hiring practices include thorough checks on ages of
applicants.
In this section the auditor also checks whether the site knows and is up to date with, relevant local law, the ETI
Base Code and the standards required e.g.

● What criteria are used when advertising for new workers.

● What age checks are done at the hiring stage.

● What is the minimum mandatory school leaving age in the area.

● What is the local custom and practice on minimum age of working.

● What documentation is kept to verify age.

● What steps do they take to ensure such documentation valid and not fraudulent.

● What processes are written down, could another person take these responsibilities over if the current
responsible person were sick.

● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
See below for more detailed information.

MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
4.1 Whether the site has a policy on child labour and written procedures on how to ensure that
children are not employed at the site.
4.2 Whether the policy on child labour is clear, communicated to workers and displayed.
4.3 That there are systems in place to check the age of all workers particularly at the point of
recruitment.

Note: This should be systematic and the site should retain documentary evidence such as copies of original ID
cards or other evidence that has been produced. However, this should not be used as an excuse to retain
workers’ identity papers. (See clause 1 'Employment Freely Chosen'). The evidence produced will vary from
country to country and wherever possible should be cross-referenced to an independent source. Management
should also be questioned to check whether they are aware of how to check for fraudulent documents.

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4.4 That all personnel files contain copies of proof of age for each worker such as:
a. Worker ID with photo.
b. Birth certificate.
c. Notary or medical checks/examination prior to employment.
d. National insurance or social insurance numbers.
e. Ration cards.
f. Written documents/affidavits.
g. School leaving certificates.
h. School diplomas.
i. And that such documentation is valid and genuine.
4.5 That no worker is less than 15 years or the law requirement if this is higher. If age 14 is allowed in
accordance with developing country exceptions (ILO convention 138) the lower age may apply.
4.6 That if any historical child labour is found i.e. workers hired at below minimum age that are now
above legal age, the auditor checks whether the current system is sufficiently robust to prevent
this happening in the future.
4.7 That all young workers (up to age 18 years) meet all local legal requirements which may include
(but not be limited to):
a. Registration with local authority.
b. Consent of parent or guardian.
c. Contract and appropriate documents state limitations on type of work e.g. no hazards or
night work.
d. Records of medical examinations in personnel files (annual if required by law).
4.8 That the site keeps a list of young workers and their job roles.
4.9 Check hiring and termination records for the previous 12 months to check if any pattern of
sacking young workers prior to audit.
4.10 Evaluates any training/apprenticeships schemes in operation and records the terms and
conditions.
Checks if these meet the law. This may include but not be limited to:
a. Signature of parent or guardian.
b. Registered with local authority.
c. Pay and benefits according to law e.g. wage rates, hours worked, time as trainee/apprentice,
social security payments and other benefits.
4.11 That the site has a system in place to check age at subcontractors/any homeworkers.
4.12 That any vocational training is of an appropriate nature e.g. does not involve working with
hazardous chemicals or heavy machinery.

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4.13 Checks whether the site has remediation policies and procedures to remove any child labour
found and to support them with educational/vocational training. This should include but not be
limited to:
a. A statement requiring any found child no longer works.
b. A method for keeping the child safe and protected whilst not being at risk and not being
required to work.
c. Requirement for the payment of a stipend.
d. The need to contact the child’s parents.
e. Possible re-allocation of work to an adult family member.
f. Local education programmes for any child found.
4.14 Checks whether any previously found child has been successfully remediated and whether they
meet the conditions in 4.13.
4.15 Where any child is found, the auditor and management must:
a. Agree it is not acceptable to dismiss them.
b. Take immediate action to remove the child from hazards.
c. Agree with management appropriate interim arrangements for the child and a commitment
for remediation.
d. Agree policies and procedures for remediation as per ETI Base Code.
e. Immediately inform the customer and where this would breach confidentiality agreements to
encourage the supplier to initiate a discussion with their customer.
f. Capture the identity and age of the child e.g. ID number, home address and any personnel
details.
4.16 The auditor should ensure that they access all areas in case of hidden problems, please see
Best Practice Guidance section 7 'Audit Execution'.
4.17 Where there are child care facilities, checks that they are staffed appropriately and safe, meeting
local laws and sufficient distance between them and the work place to ensure that the children
are not exposed to hazards or able to enter the workplace.

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Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.

Note: Workers who look particularly young should be prioritized for interview. It is important to err on the side of
caution and assume that a young looking worker is a child until verifiable evidence to the contrary is provided.
This may involve reviewing age documents of the child and verifying they are genuine (it is good practice to ask
their date of birth rather than their age).
4.18 Ask whether there are children working on the site.
4.19 Check whether young workers (up to 18 yrs.) are engaged in hazardous, night or overtime work
or work that would interfere with the necessary legal education.
4.20 Whether any young workers interviewed are comfortable with their employment conditions.
4.21 Whether young workers employment conditions meet the local and international requirements.
4.22 Checks whether workers are satisfied with any child care facilities.
4.23 Are workers clear on the site’s policy towards the employment of children and young workers.

5. Wages & Benefits

CODE
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.

Note: The ETI Base Code requires that workers are paid a living wage, and the minimum requirement is national
legal standard or industry benchmark standards whichever is higher. In addition wages should be enough to
meet basic needs plus some discretionary income. In cases where there is no defined process for establishing
the living wage, the auditor should say so on the audit report and use the minimum legal wage and correct
overtime premiums as the measurement standard. For the purpose of wages and hours review auditors should
focus on workers.

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CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Wages & Benefits'.

Note: For more information on 'Wages & Benefits' please see the ETI website.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage this area of wages.
In this section the auditor also checks whether the site knows and is up to date with, relevant local law, the ETI
Base Code and the customer’s standards required and any supporting documentation/guidance/tools.
Here the auditor also states how the site records and calculates wages for each worker.
For example:
● Which department currently manages wages.
● How does the site calculate and record wages.
● What are the legally required minimum legal wages and overtime premiums – recorded in the 'SMETA
Audit Report' under ‘Audit Scope – Local Law’.
● Are they paid by piece rate or by time rate and if so, how does the site ensure that all workers receive
minimum wages for standard hours and correct legal overtime rates.
● How are deductions made and how does the site ensure these are in line with the law.
● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
See below for more detailed information.

MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
For the purpose of wage and hours review the auditor should focus on workers. This excludes managers and
supervisors but includes production personnel and service workers such as cleaners and security guards.
The auditor checks and reports on:
5.1 Whether all hourly/weekly/monthly paid workers as well as any piece rate workers are paid at
least the legal minimum wage rate (usually stated for standard hours excluding overtime).
5.2 Where it is legally permitted to pay e.g. apprentices/trainees less than the legal minimum wage,
does the site employ these categories of workers and are they paid correctly.
5.3 Where any workers are paid below the minimum rate the auditor should record the amount and
detail how wages compare with any accepted living wage as well as legal minimums.

Note: For ETI compliance it is necessary that employees are paid a living wage and the auditor should seek to
establish if there is a defined local living wage. In the absence of a defined process for establishing the living
wage, the auditor should record no in the audit report ‘is there a defined living wage’ and the measurement will
be against legal minimum wages and correct legal overtime premiums.

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5.4 Where any workers are found to be earning below the minimum legal wage, the auditor should
record, where possible, what % of the total workforce are affected.
5.5 Whether overtime wage rates are paid at the legally required rate for e.g. weekly overtime, weekly
rest day overtime, public holiday and annual leave overtime. Where there is no legal requirement
for premium pay, check that the premiums are in line with industry best practice and record the
actual overtime premium paid including if no overtime premium paid, also whether any premiums
are paid only on certain days e.g. only on rest days/only weekends etc.
5.6 Where local law allows overtime pay below 125%, this must be recorded in the SMETA Audit
Report.
5.7 Where less than 125 % is permitted by law and the site is paying less than 125% premium for
overtime, the exact overtime premium paid should be recorded on the SMETA report in the
appropriate boxes.
5.8 The auditor should also state if there are specific conditions under which less than 125% is being
paid e.g.

a. It is allowed by law.

b. Was it collectively bargained by representatives of the workforce.

c. Are workers paid consolidated wages, i.e. higher than minimum wages for all hours but the
same rate for standard hours and overtime hours.

d. Whether this is written into the contracts.

5.9 AAG strongly recommends that less than 125% OT paid is raised as a NC against the ETI Base Code,
even where it meets the law. The intention is to retain visibility of less than 125% on the Sedex
system, to allow the supply chain to further investigate the situation and agree if any corrective action
is required. Where there is significant evidence that workers are NOT disadvantaged by lower OT
premiums a suitable corrective action maybe “discussed and agreed as acceptable with the
customer” if all parties agree with this, the NC could then be closed.

Note: The auditor must be very clear, when writing the audit report, what is the exact situation and the audit
report has been modified to make this possible. This information can be recorded in the hours table.
5.10 In cases where there is a locally accepted living wage, auditors shall clearly report what the
amount is and how it has been calculated e.g. market basket of goods etc.
5.11 Whether all legally required allowances and benefits are provided to workers e.g. social insurance.
5.12 Whether any legally allowed deductions are correctly calculated such as social security payments,
union dues etc. and promptly paid to the appropriate agency e.g. government/unions.
5.13 Check that wages are not withheld as a deposit and auditor should state the law in relation to this.
5.14 Check whether wages are reduced or deducted as a form of punishment and if yes, is this in line
with national law.
5.15 Carry out wages review in conjunction with the hours review and check the calculation for wages
to ensure accuracy and that wages are in agreement with hours worked and the law. Evidence
should be cross checked through worker interview.

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5.16 Whether all workers are given written and understandable information about their employment
including wages and hours before they enter employment and that they receive understandable
information of their pay for each pay period.
5.17 Whether there is a system in place to ensure workers receive final salary payments especially after
unplanned leaving such as after Chinese New Year.
5.18 Whether workers are paid regularly and in line with the law. If there is a legal requirement for a
minimum wage to be paid in every pay period, does this occur.
5.19 How they are paid e.g. by cash, cheque, bank transfer and not any non-monetary means.
5.20 Check a minimum of 3 pay periods, Peak, Current/Most recent and Low/Random.
5.21 Whether any legally allowed deductions for e.g. housing food etc. reduce wages to below
minimum wages and whether this contravenes the law.
5.22 If deductions are made for company loans check they are lawful and that there is correct loan
accounting.
5.23 Check contracts to establish that:
a. There is a signed copy or letter of engagement for each worker (signed by the worker).
b. Workers have an understandable copy.
c. It includes job description, terms and conditions, length of contract, any probationary period,
leave, notice period, pay, hours, discipline and grievance procedures.
d. The probationary periods do not exceed the law.
e. Contracts meet the local laws.
5.24 Check payslips to establish:
a. Wage rates paid – normal and overtime – meet at least the legal required minimums.
b. Number of hours worked (including standard and overtime hours).
c. Method of calculating wages.
d. Frequency of wage periods and timing of wage periods.
e. Method of payment.
f. Any deductions/withholdings e.g. tax, social insurance, rent, transport etc. meet legal and
code requirements.
g. Whether understandable to workers.
5.25 Check personnel files to establish:
a. There are copies of any legally required documents such as ID, right to work documentation,
work permits etc.
b. That legally allowed deductions have a signed agreement from the worker.
c. Any disciplinary records for e.g. unacceptable behaviour/conduct.
5.26 Check any agency agreements for workers provided by labour providers.

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a. Agreements between the site and the labour provider which state individual responsibilities.
b. Agreements between each appropriate worker and the labour provider.
c. Check that rates paid to the agencies/labour providers are sufficient to pay agency workers
all legal wages as well as agency costs.
5.27 Where it is not possible to verify accuracy of wages and hours records because of e.g.
discrepancy with worker testimony or production records, auditors should make it clear to
management that fraudulent records are seen as a more serious issue than correct records
which do not meet the standard. Sites should be encouraged to show accurate records to allow
for an open and frank discussion with customers on how they can work together to make
improvements.
5.28 Where the discussion fails to reveal correct records the auditor should record the management’s
explanation of why the discrepancy has occurred.
5.29 Where the auditor cannot verify records, it is essential to at least complete the wages and hours
analysis table with the individual records available.

Worker Interviews – to corroborate workplace practices

Note: Information on pay and hours must never be discussed at a group interview. This type of information is
confidential to each worker and therefore can only be discussed in individual interview. However it will be
possible to ask about wages and benefits in more general terms.
Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
5.30 Whether all workers (include all types of workers e.g. permanent, casual temporary, agency, part
time etc.) understand:
a. How their wages are calculated and the pay rates.
b. Whether there are any deductions taken from their wages and if so how much and what for.
c. Whether they are aware of any deductions or fines and have they agreed to them.
d. Do they pay deposits for any type of necessary work equipment and if yes how is it returned
to them.
e. Their wage slips – do they get them and do they understand them.
f. Whether they pay any social insurance and if yes do they know what it covers.
5.31 Whether they are financially stable and are able to earn enough to cover expenses and have
some discretionary income.
5.32 How they receive their wages, by e.g. cash, cheque, bank transfer and are they paid on time.
5.33 Are they able to take legally mandated leave and is it paid according to law, e.g. annual leave,
maternity leave.
5.34 If any have loans from their employer have they signed an agreement and do they believe the
terms and conditions are fair.

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5.35 Are they aware of any of their wages being kept as a deposit. If yes do they know how this will be
returned to them.
5.36 Do they have a copy of their contract and did they sign it.
5.37 Were they aware of the terms and conditions before commencing employment.
5.38 Do they know how they will receive their final salary settlement if they decide to leave after e.g.
Chinese New Year.
5.39 In the case of any fixed term or agency workers are they given opportunities to apply for
permanent positions.

6. Working Hours

CODE
6.1 Working hours must comply with national laws, collective agreements, and the provision of 6.2 –
6.6 below, whichever affords the greater protection for workers. Sub clauses 6.2 – 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 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 collective agreement freely negotiated with a workers’ organisation

representing a significant portion of the workforce.

● Appropriate safeguards are taken to protect the worker’s 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.

Note: *International standards recommend the progressive reduction of normal hours of work, where
appropriate to 40 hours per week without any reduction in workers’ wages as hours are reduced.

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Note: The wording of the ETI working hours’ clause has changed. The ETI has prepared a guidance document
which explains the changes and also responds to some frequently asked questions about the new wording
which can be found on the ETI website.

Auditors should familiarise themselves with this guidance and apply it to the prevailing circumstances at the site
of employment.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Working Hours'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage this area of hours of work.
In this section the auditor also checks whether the site knows and is up to date with, relevant local law, the ETI
Base Code and the standards required. The auditor states how the site records standard hours and overtime
hours for each worker e.g.
● What is the recording system used to measure hours worked, time cards, electronic scan system etc. –
recorded under ‘Working Hours Analysis' in the SMETA Audit Report (‘What timekeeping systems are
used’).
● What are the laws concerning hours of work both standard and overtime limits. Stated in SMETA audit
report under ‘Audit Scope – Local law'.
● How does the site manage overtime hours and how do they ensure that each individual does not exceed
the allowed maximum. What system is in place to ensure that workers can refuse to do overtime.
● What premium is paid for OT, record in both wages and hours table.
● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
● Company policy concerning working hours.
● Employee contracts and handbooks.
● Shift patterns.
● Collective agreements.
● Systems for staying up to date with changes to local legislation and standards.
● Communications with clients, suppliers, employees’ representatives and employees.
● Systems for recording working hours.
● Systems for monitoring and managing working hours.
● Systems for arranging overtime and ability of workers to refuse.
● Health & safety risk assessments for jobs where over 60 hours are being worked.
● Normal production patterns and peaks.
See below for more detailed information.

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MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
For the purpose of wage and hours review the auditor should focus on workers. This excludes managers and
supervisors but includes production personnel and service workers such as cleaners.
The auditor checks and reports on:
6.1 Are there policies and procedures which cover:

a. Terms of employment, standard work hours and days, rest days/leave entitlement.

b. Overtime requirements and pay.

c. Discipline and grievance procedures for lateness and other hours issues.

d. Where deductions are made for lateness what is the amount.

e. Special terms and conditions for young workers (under 18 years)/pregnant women/nursing
mothers, if a legal requirement.

f. Re-work procedures.

g. Shift schedules.

h. New recruits and training hours.

i. Method of recording hours worked.

6.2 Workers contracts or letters of engagement for:

a. Required or contracted/standard work hours. (These should not exceed 48 hours per week
or the law, but if the law allows the company and worker may agree a lower level can be
worked as standard with the ability to request flexible working up to the legal maximum or 48
hours per week. Where national law and the workers contract allows for working hours to be
averaged over a number of weeks, the auditor should take this into account in their
assessment of the required working hours).
b. Rest day and holiday entitlement.
6.3 Overtime requests and conditions.
Overtime premiums which do not meet the law must always be recorded as an NC.
An overtime premium which does meet the law but is lower than 125% must always be recorded on the
appropriate sections of the audit report. If there are circumstances e.g. consolidated pay (standards hours pay
above legal minimum) or collective bargaining agreements etc. which accept lower overtime premiums it is
important to capture this in the audit report. See SMETA Audit Report – 'Working hours analysis'.
The ETI Base Code states that the prevailing standard to be used is the one which affords greater protection for
workers and the ETI Base Code recommends an overtime premium minimum of 125%. However there may be
circumstances where less than 125% does not disadvantage the worker and it is key that the auditor
completes the audit report fully in order that those judgments may be made.

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The recommendation of the AAG is that less than 125% overtime pay, (which does meet the law) should
be raised as an NC against the ETI Base Code to keep visibility on the system. It is key that the auditor
records any other circumstances which may influence the payment of less than 125% e.g. consolidated pay,
collective bargaining agreements etc. This information should be captured on the audit report.
6.4 What is the method for recording of hours, is it accurate and are there any signs of falsified
records (double books).
6.5 Do records of hours worked separate standard/contracted hours and overtime hours.
6.6 Review the hours and wages records of all employees selected for individual interview. The
additional number of records required to meet the recommended sample size to be taken from
the wider population of workers, taking care to include different work sections and worker levels
(but excluding supervisors and managers). A relevant sample is dependent on the risks of the
country and industry. However as a minimum 10 records for up to 100 workers (10% of the
workforce), should be reviewed and thereafter numbers for each pay period selected should be
as described in '6.5.3 Audit Length, Sample Size and Timetable' in the 'SMETA Best Practice
Guidance'.
Measure standard/contracted and overtime hours against the local laws and the ETI Base Code
taking into account issues such as averaging where allowed by local law.

Note: The sample is to be taken over 3 different pay months for all workers – Peak, Current/Most recent and
Low/Random chosen over the last 12 months.
6.7 Where required or standard/contracted hours and/or overtime hours exceed the legal maximum
this must always be recorded as a non-compliance against the law. If the law allows more than
60 total hours per week and if hours greater than 60 per week are found, auditors should:

a. Review the frequency of this and the number of workers affected (see new hours table) and
whether the conditions under which companies may exceed 60 hours per week as
described in 6.5 apply e.g.

● 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.

b. Review any communication with clients concerning reasons for this and their management
processes (record this as good example).

c. Discuss why this is necessary rather than employing more workers.

Note: If it is felt appropriate to raise a non-compliance, an observation or good example on this issue, this
should appear under Regular Employment.
6.8 Review of records from the relevant sample to include and report on (e.g in ‘Current Systems and
Evidence Examined’):
a. Full 12 months hours and wages records in conjunction with time cards and individual pay
records (or a 12 month cycle for seasonal work).

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b. Report on all records analysed of the standard/contracted work week, overtime hours and
any holiday or rest day working.
c. Check whether breaks, holidays and rest periods are in line with the law.
d. Where overtime hours exceed the national law but are within any waivers obtained it is
important to review a 12 month cycle (waivers often permit "annualised hours" i.e. a
maximum number of overtime hours per year).
e. Where possible auditors should check legality of local waivers, are they signed and by
whom.

Note: Apply the sample over 3 different pay months for all workers – Peak, Current/Most Recent and
Low/Random – not a full 12 month cycle. Care must be taken in selecting a “peak” month to check that it is
indeed a true peak.
6.9 For completing the detailed wages and hours records within the audit report the auditor should:
a. Record the TOTAL number of records reviewed.
b. In all cases for wages and hours recording it is important to state the units and time interval
covered, e.g. per day, per week, per month, per year.
c. Find and report on the lowest and highest number of hours worked over all workers. Record
the hours (what is the range of actual hours worked – what is the company’s average).
d. Record the number of workers that are working the highest hours. Clearly state the actual
hours found. Record the extent of the working hours reviewed, are there any individuals who
have higher working hours than others, are there any high working hours by employees of
certain skills/or in certain job roles/departments. Or does it apply to the all employees.
e. Record the frequency (are there any peaks over a course of 12 months. – what patterns exist
if any.) Specify over how many months these peak may occur and name them e.g. May and
November or from September through to January.
f. Examine the total records for the sampled periods to find lowest and highest paid and report
on these together with their hours worked.
6.10 Are there management systems in place to allow workers to volunteer for overtime (note this as
good practice).
6.11 Review contracts and all terms and conditions for signs of compulsory overtime or hours required
to finish the job or compulsory production quotas that cannot be reasonably completed within
the standard/contracted workday. Also check for collective agreements concerning overtime
agreements.
6.12 Check working hours against pay records to ensure no inconsistencies.
6.13 Examine quality records and production records such as broken needle reports, accident reports
etc. to cross check hours records.
6.14 Where inconsistencies are noted, management shall be invited to provide accurate records as
soon as these start to be discovered. An investigation should be undertaken to establish the
underlying cause and whether this is due to poor record keeping, isolated incidents or repeated
occurrences. Sufficient detail to be provided in the audit report.

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Auditors should make it clear to management that fraudulent records are seen as a more serious
issue than correct records which do not meet the standard. Sites should be encouraged to show
accurate records to allow for an open and frank discussion with customers on how they can
work together to make improvements.
6.15 Where the discussion fails to reveal correct records the auditor should record the management’s
explanation of why the discrepancy has occurred.
6.16 Where the auditor cannot verify records, it is essential to at least complete the wages and hours
analysis table with the individual records available. Gather evidence to ascertain the facts and
also the context of any inconsistencies found.
6.17 Auditors should encourage the management to consider the root causes of excessive work
hours. Auditors should capture the view of management on the above and other contributors in
the appropriate section of the SMETA audit report e.g. under the Working Hours Analysis table
‘Comments: (Please state here any specific reasons/circumstances that explain the highest
working hours)’. Wherever possible the management should provide proof of their statements –
this will be useful to customers as they begin to examine how they can support their suppliers in
reducing working hours.
6.18 Where standard hours or overtime hours exceed the legal maximum this must always be
recorded as a non-compliance against the law.
Non-compliance must be recorded also when the total hours worked per week exceeds a
maximum of 60 hours per week unless the conditions meet the terms of ETI Base Code
Clause 6.5.
In this case the issue should be stated as an observation only and the full conditions established
i.e. for hours exceeding 60 hours per week, in order to record an observation ALL the following
criteria should be met:

a. This is allowed by national law.

b. This is allowed by collective agreement freely negotiated with a workers’ organisation

representing a significant portion of the workforce.

c. Appropriate safeguards are taken to protect the worker’s health and safety; and

d. The employer can demonstrate that exceptional circumstances apply such as unexpected
production peaks, accidents or emergencies.

The auditor must record in the observation box, how the above criteria have been established and
substantiated.

The auditor must be very clear when writing the audit report, what the exact situation is and the audit report has
been modified to make this possible.

Note: For more details on sampling see 'SMETA Best Practice Guidance': '6.5.3 Audit Length, Sample Size
and Timetable'.

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Worker Interviews – to corroborate workplace practices

Note: Information on pay and hours must never be discussed at an individual level at a group interview. This
type of information is confidential to each worker and therefore can only be discussed in individual interview.
However it will be possible to ask about wages and benefits in more general terms.
Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
6.19 What are their standard/contracted/required hours and do workers understand this.
6.20 How are they recorded, if a punch card or swipe card system is used, do they do it themselves.
6.21 What are their overtime hours and whether they feel able to refuse to do overtime.
6.22 If remote logging of hours is undertaken how is this verified by the workers. What systems exist
to handle disagreements over hours.
6.23 Are workers able to leave the facility after their required or contracted/standard workday (e.g. if
transportation is provided, is it available for workers who do not perform overtime).
6.24 What are their overtime hours and how often do they work overtime and do they feel able to
refuse to do overtime.
a. What do you think are the reasons for working overtime hours. Are they explained by
management.
b. Is there a process/records to show workers have given separate consent for all overtime (OT)
worked.
6.25 Are they aware of any collective agreements concerning overtime and how these have been
agreed.
6.26 Have they ever worked without recording their hours.
6.27 Are overtime hours ever paid in cash without being recorded.
6.28 Is there a separate system for recording overtime hours and if so what is it.
6.29 During what part of the year is the site busiest.
6.30 What breaks to they get during the day and are they sufficient to eat and rest.
6.31 Whether they get rest days each week and if so how many. When was the last time they had a
day off.
6.32 Are they paid for re-works.
6.33 Have they ever taken work home.
6.34 Are they entitled to annual leave, when can they take it and how do they apply for it.
6.35 Whether they get other types of leave, such as maternity, paternity, illness, compassionate,
marriage or wedding, any other legally required types of leave.
6.36 Are there special arrangements for young or pregnant workers, other types of workers.
6.37 Do they consider the rest and recreational facilities (canteen, break space etc.) satisfactory.

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7. Discrimination

CODE
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.

Note: Prior to the audit the auditor should check relevant sources of discrimination information by maintaining a
relationship with key NGO’s or groups in the relevant countries where they carry out audits.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Discrimination'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand, and
record what controls and processes are currently in place to manage this area of discrimination.
In this section the auditor also checks whether the site knows and is up to date with, relevant local law. The ETI
Base Code and the standards required e.g.

● How does the site advertise for new staff.

● How does the site ensure there is no discrimination in any of its procedures or practices.

● Do the workers feel that they have an equal chance of training and promotion.

● What is the gender and ethnic balance between workers and middle management.

● What is written down for guidance on discrimination.

● What training is given and to whom.

● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
See below for more detailed information.

MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
7.1 Are there policies and procedures in place which cover the need for all workers to be treated
equally in all matters of employment and which cover:
a. Recruitment and employment.
b. Compensation (e.g. Equal pay for equal work).
c. Access to training.

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d. Promotion, benefits and advancements.

e. Termination and retirement.
f. Equal opportunities.
g. Discrimination based on e.g. race, caste gender, origin etc.
h. Any discrimination based on category of worker or type of contract e.g. agency, temporary,
migrant and local workers.
i. And are these communicated to workers in relevant languages or suitably explained where
literacy is low.
7.2 Checks that site practices follow established policies and procedures.
7.3 Examines specifically the recruitment process for:
a. Systems for advertising and hiring new staff e.g. verify the language used in job postings and
the list of job requirements.
b. How the workers are selected for interview.
c. How interviews are conducted by whom and what questions are asked.
d. Policies and requirements for any health checks prior to employment with particular
reference to pregnancy and HIV testing to ensure they do not discriminate; this includes core
workers as well as non-core such as cleaners, subcontractors, security guards.
e. Interview notes and application forms do not indicate discrimination e.g. asking female
workers if they are likely to marry, asking about union membership.
f. Checks contracts to examine potential discrimination e.g. requirement not to have children
for a period.
7.4 Examines the termination policies and practices.
a. Verify disciplinary and notice letters to workers.
b. Investigate why workers have left.
c. Examine specifically termination conditions of any union members.
d. Is there an exit interview and is it effective.
7.5 Check payroll records to ensure:
a. No pay inequality based on unfair or unlawful discrimination.
b. All workers receive all benefits to which they are entitled.
7.6 Check worker grievance procedures. Are there ways in which workers can report discrimination.
a. Suggestion box.
b. Anonymous phone line.
And do the systems:
c. Protect the identity of the worker.

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d. Prevent repercussions against the reporter. An example of preventing repercussions might be

a written non-retaliation commitment that is clearly communicated to workers and which may
include:

● written policies and procedures

● communication and training (that can be easily understood by workers)

● internal monitoring and governance process

● use of an externally managed process

7.7 Checks the breakdown of workers:
a. By ethnic/social group, gender and position.
b. Ensure that any segregation of workers is a local norm and does not interfere with equal
opportunities across all groups.
c. Ensures that all benefits are applied equally to all groups and especially all legal benefits
reference pre and post natal conditions e.g. rest and breaks, nursing breaks and a suitable
quiet space.
7.8 Examines what are the workers’ rights to observe religious holidays, prayer time in work time etc.

Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.

Note: The auditor should arrange some focus groups by ethnic grouping or gender in order to encourage free
speech on these issues. In these cases it is advisable to have someone from the same ethnic group or gender
leading the meeting.
7.9 Are workers aware of any anti-discrimination policies at the site.
7.10 Whether workers feel discriminated against with regard to any aspect of their employment e.g.
pregnancy tests.
7.11 Whether they are aware of any maternity or paternity benefits and whether they are aware of any
workers who have been given this and then being able to return to work afterwards.
7.12 Have they any experience relating to people reporting issues of discrimination and action taken
as a result.
7.13 Do they know how to report discrimination and are they fearful of repercussions.
7.14 Are they able to take religious holidays or any other religious observations such as breaks for
prayer.

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8 Regular Employment

CODE
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.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Regular Employment'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand, and
record what controls and processes are currently in place to manage this area of regular employment.
In this section the auditor also checks whether the site knows and is up to date with, relevant local law, the ETI
Base Code and the standards required e.g.

● What is the contract procedure.

● How are the workers made aware of their contractual rights and obligations.

● Are there any apprentices/trainees at the site.

● What training is given on notice periods etc.

● If labour providers are used how does the site understand their terms and conditions of working.

● How does the site check the labour standards of any labour providers it uses.

● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
See below for more detailed information.

MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
8.1 What proportion of workers are permanent, part time, fixed term contract workers, temporary
workers, and do their terms and conditions meet the law, whether fixed term contracts are
repeatedly used and the legal requirement governing this.
8.2 Checks and records specifically the social security benefits and payments for all types of workers
present, casual, temporary, subcontract, apprentice, trainee, do they meet the law.
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8.3 Is there any evidence of casual, temporary, fixed term contract workers, probationary/trainee
workers being employed on a semi-permanent basis to avoid legal obligations on the part of the
employer, such as payment of social security, annual leave benefits etc.
8.4 Checks hiring and termination records over the last 6 month to see if patterns exist.
8.5 Checks patterns on hiring around peak periods and whether these are normal within the company.

Note: Under some circumstances regular layoffs during quiet periods may be acceptable; the auditor should
state the law in the audit report.
8.6 Records details of seasonal or contract workers and compares this with the national law. The
auditor must clearly state the law in the audit report.
8.7 Check the policy concerning pay in quiet periods and if annualized hours are being used ensure
this is legal and that overtime hours in busy periods are still being paid according to law.
8.8 Checks any service level agreements with agencies in the case of agency workers. What do they
cover and how do they manage workers, how much notice is given, are they paid if they turn up,
are they paid for down time. Do the pay and conditions of agency workers at least meet legal
requirements.
8.9 If contract workers are on site, if possible reviews their contracts and terms and conditions. Do
these meet the legal requirements.
8.10 If any apprentices/trainees on site ensure that all terms and conditions meet the legal requirements.
8.11 Review workers legal right to work and the procedures in place to ensure these comply with legal
and industry requirements, especially when they are supplied by an agency.

Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.

Note: Include all types of workers in the interview process. If there are specific categories such as
temporary/casual/agency it may be advisable to conduct at least one group interview with this worker type only.
In addition at least one group should be made up of workers who have been at the site for minimum of 1 year
and can be classed as "permanent".
8.12 Asks their experience of being hired and what do they expect as the duration of their contract,
e.g. indefinite (permanent workers), fixed term, temporary.
8.13 What is their experience of temporary/casual etc. worker types being able to apply for permanent
positions.
8.14 What do they know of their wage deductions, do they know if they are paying e.g. social security.
8.15 What do permanent works know about the site’s practices towards temporary, casual, agency
workers.
8.16 Ask apprentices/trainees about their terms and conditions and verify if they meet the law (exactly
record the law as appropriate).
8.17 If contract workers are on site, includes a representative sample in worker interviews. Record
what they know of their terms and conditions of employment.
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8A. Sub-Contracting & Homeworking

CODE
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: The aim of this audit is not to carry out a full audit of the sub-contracting, homeworking and/or external
processing (SC,H&EP) supply chain, but to highlight where it is happening with some basic information and
provide visibility. The supplier/retailer can then decide if further work is needed. If this is the case, the
supplier/brand/retailer may wish to do this themselves or pass on to a local NGO.
For more information on homeworking, refer to:

● 'The ETI Homeworkers guidelines toolkit' recommendations for working with homeworkers.

● Homeworkers Worldwide Website.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Sub-Contracting & Homeworking'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage sub-contracting, homeworking and
external processing.
In this section the auditor also checks whether the site knows and is up to date with, relevant local law, the ETI
Base Code and the standards required e.g.

● Do their customers have policies on Sub-Contracting, Homeworking & External Processing

(SC,H & EP).

● Is there a requirement to inform their customers.

● If yes have they done so.

● What processes are in place to control any external working and the external conditions of working.

● If homeworking exists, is the auditor required to include this in the scope of the SMETA (preferably
established in pre-audit stage).

● What is documented.

● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.

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MEASUREMENT CRTIERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
8A.1 If any or all of Sub-Contracting, Homeworking and/or External Processing (SC,H & EP) are being
carried out the auditor must check:
a. That it is with the knowledge and agreement of the main client.
b. Whether the site has a good knowledge of where their products are being made (especially if
an intermediate agent is involved) and if they have systems in place to manage and monitor.
8A.2 If some of (SC,H & EP) is taking place the auditor records the extent by mapping the supply
chain and summarising as well as recording what systems are in place to ensure those workers
are working in good conditions.
8A.3 Requests details of any (SC,H & EP) used in the production process. It should be noted that the
factory may only have details of the agents used as intermediaries and the level of information
available should be noted and recorded in the SMETA audit report.
8A.4 Ascertains, where (SC,H & EP) is in place what systems and policies are in place to manage their
ethical position and has the site carried out any audits there to assess conditions.
8A.5 Checks the existence of terms and conditions of engagement for (SC,H & EP).
8A.6 Records if the country has ratified the ILO Convention on Home Working.
8A.7 Request evidence to show they have communicated the code of conduct.
8A.8 State the location and number of (SC,H & EP) suppliers they are sourcing from and provide the
name of whom through; if via a contractor, sub-contractor or a sub-sub-contractor.
8A.9 Identifies in which part of the production process (SC,H & EP) are used and which period of the
year.
8A.10 Checks the systems in place for setting piece rate pay, gathers evidence of the time and motion
studies to establish rate of pay.
8A.11 Checks if the supplier has implemented systems to carry out random checks on
homeworking/(SC,H & EP) units via QCs to ensure that basic working conditions are acceptable.
8A.12 Look for evidence that the code of conduct has been communicated to any (SC,H & EP).
8A.13 Where management state no (SC,H & EP), this should be corroborated by:
a. Checking production records versus order books to establish whether the site has the
capacity to make the quantities produced.
b. Look at internal production checks to see if it is of product made on site.
c. Quality records to check for signs of outside work.
d. Look at production processes in site tour and establish whether they are all on site.
e. In busy months whether there are enough workers on site to do production normally
outsourced e.g. embroidery.
f. Look at goods out and in to establish if any work or part work is moving out of the site.

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8A.14 Ascertain and notes as a non-compliance where sub-contracting is taking place without express
permission from any retailers concerned.
Worker Interviews – to corroborate workplace practices
Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
8A.15 Question quality team about goods out/in.
8A.16 Discusses processes on site and whether there is a likelihood of producing off site.

9. No Harsh or Inhumane Treatment is Allowed

CODE
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal
abuse or other forms of intimidation be prohibited.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'No Harsh or Inhumane Treatment is Allowed'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage this area of no harsh or inhumane
treatment is allowed.
In this section the auditor checks whether the site knows and is up to date with, relevant local law, the ETI Base
Code and the standards required e.g.

● Are there any policies on harsh treatment.

● What is the disciplinary procedure.
● Is it written down and understood by the workforce.
● Who disciplines workers and by what methods.
● Is any of it recorded.
● Is there a grievance mechanism and is it recorded.
● Does the grievance mechanism include a provision for non-retaliation and does it allow workers to
report issues anonymously.

● Who monitors, oversees and inputs into the grievance mechanism process (internally, externally).
● What training is given and to whom, on the need for fair and humane treatment.
● Is there a mechanism for workers to report harsh treatment and if so what are they. If there is any
documentary evidence of these practices the auditor should record the details in this section.

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MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
9.1 Checks and reports on any policies and procedures concerning disciplinary action e.g.
a. Disciplinary rules and actions.
b. Prevention of harassment/abuse/intimidation.
c. Security practices.
d. Grievance and appeal procedures. This should include but not be limited to checking and
reporting on any:

Non-retaliation policy

Communication and training

Governance and monitoring process.

9.2 Check that policies and procedures are communicated and understood by all levels of personnel
e.g. by posters, training, worker handbook, other means when literacy is low.
9.3 Examines records of disciplinary and grievance activity and reports on actions/outcomes.
9.4 Reviews the contracts of any security guards as well as their job description to ascertain if any
likelihood of harassment or extreme discipline (security should be used to keep the site safe i.e.
intruders out, not keep workers in).
9.5 Where unions/worker reps exist check they are aware of the policies and procedures and have
they agreed them.
9.6 Record if any deductions from wages were made for disciplinary reasons. If legally allowed report
on whether they are clearly documented and that the amount does not take workers below
minimum legal wage.

Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
9.7 Checks that the workers are aware of any policies/procedures and if they are aware of their
grievance rights.
9.8 Discusses with workers whether they think disciplinary procedures and practices are fair, non-
arbitrary and effective.
9.9 Whether workers are aware of any disciplinary cases and what the outcomes have been.
9.10 Checks if workers are aware of any grievance action and what the outcomes of these appeals
have been.
9.11 Checks with workers concerning anecdotal or other evidence of corporal punishment or of verbal
or physical or mental coercion or harassment.

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9.12 Checks whether they know of any complaints about inappropriate disciplinary action and the outcome.
9.13 Checks with workers their view of the security guards (if applicable) and their role.
9.14 Checks with union/worker reps whether they are aware of the disciplinary policies and
procedures and whether they have agreed to them.
9.15 Checks with the workers, do they know how they would report any harsh treatment.

Note: If there are any fears of reprisals, findings should not be reported at the closing meeting but must be
reported to the client please see 'Supplementary Guidance for Dealing with Sensitive Issues Raised at
Audit' on the member’s resources section of the Sedex website.

10. Other Issues

CODE

10A. Entitlement to Work

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.
10A.3 Employment agencies must only supply workers registered with them.
10A.4 The supplier shall implement processes to enable adequate control over agencies with regards
the above points and related legislation.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Entitlement to Work'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and record
what controls and processes are currently in place to manage entitlement to work, migrant and agency labour.
In this section the auditor also checks whether the site knows and is up to date with, relevant local, national and
international law as well as the standards required e.g.

● Are there laws governing this area of the code and is the site up to date.
● Does the site use migrant or agency labour.
● If yes what checks does the site have in place to check on labour conditions for these workers.
● Are any checks documented.
● During interviews what is the perspective of any migrant or agency labour.
● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
See below for more detailed information.
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MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
10A.1 Checks the identification documents of permanent workers and agency workers to ensure they
are entitled to work in the particular country.
10A.2 Checks that the facility is familiar with immigration rules and regulations if they are employing
immigrants/foreign nationals/overseas students.
10A.3 Checks that the facility is aware of the types of official documentation that verify a worker’s right
to work in the country.
10A.4 Check that the facility is using agencies or labour providers who are in compliance with local
legislative requirements (e.g. GLA in UK, responsibilities of main supplier to contract workers in India
etc.).
10A.5 Checks that the facility maintains control of agencies that they may use to provide temporary
labour. This may include regular visits to the agency by the facility or a more formal internal audit
of its processes and systems.
10A.6 Where agencies used are in a different country e.g. to recruit workers from another country,
check what system is in place for the site to check on these agencies’ procedures.
10A.7 Checks that the facility has applicable records relating to any agencies used such as contracts
(Service Level Agreement) or invoices. That appropriate records for agency workers are kept on
site.
10A.8 Checks how the workers were recruited and whether the site is aware of any fees paid by
workers to secure a job.
10A.9 Checks these workers contracts, pay slips, hours and where workers are paid by the agency that
the site keeps copies of these documents.

Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
10A.10 Establishes how the workers were recruited and whether any payments were made or
inducements offered prior to leaving their point of origin.
10A.11 Examines what arrangements were made for the worker to travel from the point of origin.
10A.12 Were there any deductions/arrangement fees for items such as travel, accommodation and
equipment.
10A.13 Whether workers are required to bring their own basic living equipment e.g. mattresses, cooking
utensils.

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10B2. Environment 2-Pillar (Shortened Version)

This version is within the scope of the mandatory 2-Pillar SMETA Audit. For a 4-Pillar audit please use 10B4.
Extended Version.
This is not a full environmental assessment but a check on basic systems and management approach.

CODE
10B2.1 Suppliers must comply with the requirements of local, national and international laws related to
environmental standards.
10B2.2 The supplier should be aware of and comply with their end clients’ environmental requirements.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage standards at the site in this area of
'Environment 2-Pillar (Shortened Version)'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage this area of environment.
In this section the auditor also checks whether the site knows and is up to date with, relevant local, national and
international law as well as the standards required e.g.

● Are there laws governing environment, is the site aware of them and up to date.

● Do they have internal systems for checking they meet the law.

● Are these systems documented.

● Are there any government checks and if so are they documented.

● Are they involved in a process of improvement of their environmental performance.

● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
See below for more detailed information.

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MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
10B2.1 Are there any site policies or procedures concerning environmental issues and how do these
compare with any requirements of international/national/local laws and regulations.
10B.2.2 Whether the facility is aware of any client-specific environmental requirements and has systems in
place to be able to ensure that they meet these.
10B2.3 What management systems and work instructions are in place to ensure compliance with the
relevant legislation. The auditor should report on the extent of systems in place and any external
certification e.g. ISO 14001.
10B2.4 The name and position of the person with responsibility for environmental issues at the site of
employment and whether they understand the legislative requirements.
10B2.5 Whether the site has a list of chemicals used in the manufacturing process and whether they are
aware of how they relate to any client requirements and legislation in the destination countries.
10B2.6 Checks and reports on any inspections from local government bodies, along with details of any
official complaints, legal actions or recommendations.

Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system in place, document review and management interview by
worker testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
10B2.7. Identifies and interviews workers from relevant sections to comment on compliance with legal
requirements related to environmental attributes e.g. discharge of effluent, removal and recycling
of waste.

10B4. Environment 4-Pillar (Extended Version)

Use this section for an extended environmental assessment 4-Pillar SMETA, which includes a recommended
0.25 audit days.
This is not a full environmental audit, but an assessment process over a recommended 0.25 auditor days,
which will support the reviewer in deciding if a full environmental audit is necessary.

CODE
Compliance criteria
10B4.1 Suppliers as a minimum must meet the requirements of local, national and international laws
related to environmental standards.
10B4.2 Where it is a legal requirement suppliers 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 The supplier shall be aware of their end client’s environmental standards/code requirements and
have a system in place to monitor their performance against these.

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Guide for Observations

10B4.4 Suppliers should have completed the appropriate section of the SAQ and made it available to the
auditor.
10B4.5 Suppliers should have an environmental policy, covering their environmental impact, which is
communicated to all appropriate parties, including its own suppliers.
10B4.6 Suppliers shall be aware of the significant environmental impact of their site and its processes.
10B4.7 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 'SMETA Audit Report'
Clause 10B4. and Measurement Criteria below for details).
10B4.8 Suppliers shall seek to make continuous improvements in their environmental performance.
10B4.9 Suppliers shall have available for review any environmental certifications or any environmental
management systems documentation.
10B4.10 Suppliers should have a nominated individual responsible for co-ordinating the site’s efforts to
improve environmental performance.
10B4.11 Has the site recently been subject to (or pending) any fines/prosecutions for non-compliance to
environmental regulations.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Environment 4-Pillar (Extended Version)'. In addition to criteria in 10B2 auditor should add
points below.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage this area of environment.
In this section the auditor also checks whether the site knows and is up to date with, relevant local, national and
international law as well as the standards required e.g.

● Does the site record its uses and discharge of natural resources such as water, energy, waste,
emissions.

● Are these records reviewed regularly and if so at what level.

● Is there a programme of gradual reduction in environmental impacts.

● Is the workforce aware of how they can contribute to reduction in environmental impacts.

● Who manages the site’s environmental performance.

● Does the site have a recognised environmental management system such as ISO 14001, record
appropriate reference numbers and renewal/expiry dates.

● Are there any other sustainability measures/environmental certificates available at the site such as
Forest Stewardship Council (FSC), Chain of Custody (COC) and Marine Stewardship Council (MSC). If
so their reference numbers and date should be recorded here.

● Are there any policies on environment and/or biodiversity*.

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● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
See below for more detailed information.

Note: *For more information on biodiversity, please see 'Sedex Supplier Workbook' or visit the WWF website.

MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
10B4.1 Whether the site has completed the SAQ on Environment and has made it available to the
auditor for pre-review.
10B4.2 If the site is aware of/has access to the local and national regulations covering Environment and
is meeting those requirements.
10B4.3 Whether the site is aware of any client’s environmental standards or codes and is measuring its
performance against those.
10B4.4 Whether the site has a clearly communicated policy, covering Environment and that this policy
has defined procedures for implementation and management of environmental performance. The
auditor should note any internationally recognised certifications present e.g. ISO 14001.
10B4.5 Whether the site has the relevant permits in place for all aspects of its environmental impacts.
This should include recording any prosecutions, recommendations and inspections from local
bodies and whether these have been acted on.
10B4.6 The name and position of any designated person with responsibility for management of
environmental issues. The auditor should comment on the designated person’s understanding of
legislation and client applicable standards and their procedure for keeping up to date.
10B4.7 Whether the site is aware of its main environmental impacts and is measuring these. The auditor
should list what they are and any available measures, in the audit report. The possible list
includes energy use, water use and disposal, waste and emissions to air.
10B4.8 Whether the site is recording its use of environmental resources on a continuous basis. The
auditor should list what they are and record any measurements the site has available, within the
audit report. The possible list includes energy use, water use and disposal, waste and emissions
to air.
10B4.9 Whether the site has a list of chemicals used in the manufacturing process and whether they are
aware of how they relate to any client requirements and legislation in the destination countries.
10B4.10 Checks and reports on any inspections from local government bodies, along with details of any
official complaints, legal actions or recommendations.

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Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
10B4.11 Are workers from the relevant sections, especially those involved with legal compliance e.g.
checking contents of effluent, aware of standards required and do their work procedures ensure
they are met.
10B4.12 Are workers aware of what actions to take when regulations are not met.
10B4.13 Are appropriate workers given any training on environmental issues, including having knowledge
of any site policies and procedures.
10B4.14 Have workers been trained to minimize wasteful resources such as switching off lights or
machinery when not needed.

Note: Additional resources available on the member’s section of the Sedex website.

● 'SMETA Guidance for Auditors for Extended Environment and Business Ethics Assessment'.

● 'SMETA Guidance for Suppliers for Extended Environment and Business Ethics Assessment'.

A full environmental audit check list is available publicly at the GSCP website.

10C. Business Ethics

CODE (NO NON-COMPLIANCES – OBSERVATIONS ONLY)

Note: The aim of the Business Ethics Assessment is to give a better understanding of these issues in global
supply chains and by gathering information as observations and not non-compliances it is hoped that over time
appropriate standards can be agreed.
10C.1 Suppliers should have completed the appropriate section of the SAQ and have made it available
to the auditor.
10C.2 The supplier should have received and acknowledged – preferably in writing – the Business
Ethics policy of the auditor/audit company.
10C.3 Suppliers shall seek to conduct their business ethically without bribery, corruption, or any type of
fraudulent business practice.
10C.4 Suppliers shall be aware of any applicable laws, their end client’s Business Ethics standards/code
requirements and have a system in place to monitor their performance against these.
10C.5 Supplier should have a Business Ethics policy concerning bribery, corruption, or unethical
Business Practice. This should be clearly communicated to all relevant parties.
10C.6 Suppliers should have a designated person responsible for implementing standards concerning
Business Ethics.

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10C.7 Suppliers should have a transparent system in place for confidentially reporting, and dealing with
unethical business practices without fear of reprisals towards the reporter.
10C.8 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.
This is not a full Business Ethics audit, but an assessment process over a recommended 0.25 auditor days,
which will support the reviewer in deciding if a full Business Ethics audit is necessary.

CURRENT SYSTEMS AND EVIDENCE EXAMINED

The auditor checks and reports on the processes used to manage labour standards at the site in this
area of 'Business Ethics'.
Auditors examine policies and written procedures in conjunction with relevant managers to understand and
record what controls and processes are currently in place to manage the area of Business Ethics.
Where the site is uninformed on business ethics issues the auditor should use the time to communicate the
important issues in this area. To assist this communication the AAG have prepared a guidance document for
suppliers on Environment and Business Ethics standards and requirements. The auditor can use this to
stimulate a discussion where they can investigate with the help of the site management any local issues which
may be relevant and this should be captured in this section.
In this section the auditor also checks whether the site knows and is up to date with, relevant local, national and
international law as well as the standards required e.g.

● What policies and procedures are already in place.

● What training (if any) is given.

● Is the site aware of any financial inducements for e.g. order placement.

● What is the local custom and practice, are there advantages for financial inducements for e.g. stock
movement.

● Is the site able to avoid these and if so how.

● Is there any documentary evidence of these practices and if so what are they. The auditor should
record the details in this section.
For more detailed information see below.

MEASUREMENT CRITERIA
Management system investigation and document review including management interview.
The auditor checks and reports on:
10C.1 Whether the site has completed the SAQ in Business Ethics and has made it available to the
auditor for pre-review.
10C.2 If the site is aware of/has access to any local and national regulations covering Business Ethics
and is meeting those requirements.

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10C.3 If the site has relevant licenses and permits in place for correct and legal practice of its business
operations. This should include recording any prosecutions, recommendations and inspections
from local bodies and whether these have been acted on.
10C.4 Whether the site is aware of any client’s Business Ethics standards or codes and is measuring its
performance against those, an example would be codes on corporate giving.
10C.5 Whether the site has received and understood the auditor/Audit Company’s policy on Business
Ethics this should explicitly state the need to avoid bribery during audits and the "zero tolerance"
policy of both the auditor and the site to the giving or accepting of any bribe, either in
remuneration or in kind.
10C.5 Whether the site has a clearly communicated policy, covering Business Ethics and that this policy
has defined procedures for implementation and management of Business Ethics performance.
10C.6 Whether this policy has specific reference to such topics as e.g. bribery issues (excessive gifts
and entertainment), conflict of interest, charitable donations, facilitation payments, political
contributions, the auditor should note any internationally recognised certifications present.
10C.7 Whether the site has communicated its policies on Business Ethics issues, especially to those
workers in high risk departments, such as purchasing or logistics The auditor should check for
any specific training for relevant management and workers.
10C.8 The name and position of any designated person with responsibility for management of Business
Ethics issues. The auditor should comment on the designated person’s understanding of
legislation and client applicable standards and their procedure for keeping up to date.
10C.9 Whether there is a clear communication/training on how to deal with any Business Ethics issues
including how concerns should be communicated and dealt with.
10C.10 Has the site recently been subject to (or pending) any fines/prosecutions for non-compliance to
business ethics regulations.

Worker Interviews – to corroborate workplace practices

Auditor seeks to confirm the management system, document review and management interview by worker
testimony. Discrepancies should be noted, taking care to protect the anonymity of workers.
10C.11 Interviews appropriate personnel to establish if they are aware of the site’s policies concerning
Business Ethics policies and procedures and whether they know how to report their concerns
about any issues.
10C.12 Checks on the level of understanding and any training received by appropriate personnel on how
to deal with Business Ethics issues when confronted with them at work.
10C.13 Whether workers are aware of the disciplinary procedures if they are found to be involved in
unethical business practices e.g. bribery or corruption.

Note: For Business Ethics, interviews should focus on personnel where Business Ethics are most relevant, e.g.
senior management to establish whether there are any policies and procedures to inform employees of its
approach. Interview as appropriate sales personnel, service managers, logistics department, to establish whether:

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1. They are aware of any policies and/or procedures (if present).

2. They have received any basic training on Business Ethics.
3. They are aware of what to do if they are offered any personnel incentives for business, i.e. bribes.
4. Who they report to if they have any other concerns about Business Ethics.
In cases where appropriate personnel cannot be available on the day, or maybe they are in a different location,
it may be possible to establish the above by phone.

Note: Additional resources available on the member’s section of the Sedex website.

● Auditor checklists – 'SMETA Guidance for Auditors for Extended Environment and Business
Ethics Assessment'.

● Guide for Suppliers – 'SMETA Guidance for Suppliers for Extended Environment and Business
Ethics Assessment'.

Useful resources publicly available:

● Transparency International – www.transparency.org

● 'Business Principles for Countering Bribery'

● 'Anti-Bribery Best Practice E-Learning Course'

● ’Business principles for countering bribery (SME edition)’

● Country profiles on risks

● List of countries who have ratified UN convention against corruption

11. Community Benefits

Note: Sedex members wish to understand any positive effects their supply chains are having on the community
in which they operate and SMETA has therefore included this section as an opportunity for sites of employment
to highlight these.
This is the opportunity for the site and its workforce to describe what benefits they bring to the local community
– often there are many, frequently a SMETA audit report does not record them.
Under this section of the audit report the auditor shall document any positive benefits that the factory
management have implemented to aid the community. These may include aspects such as hospitals, schools,
community centre, sports/health programmes, transport to local facilities such as doctors and markets/shops,
AIDS programme etc.
The auditor should seek to quantify the benefits recorded, by the time given e.g. where staff and/or workers
give assistance to a local charitable initiative, by the number of people affected, by the financial input to any
outside organisations and an indication of time which the project took (e.g. an on-going initiative or a single
project). There may be other measurables and the auditors should be guided by the site.
The auditor is not expected to verify these community benefits and evidence may be from management
interviews only. Any examples raised should be detailed on the appropriate section of the SMETA audit report.
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MEASURING IMPACTS
Introduction
Members of Sedex are increasingly interested in this topic and keen to learn whether the work they and their
suppliers are doing on labour standards is making a difference in the workplace.
They are beginning to look to the SMETA audit process to support them in this task, so that an audit not only
reports factual changes and improvements, but also attempts to record any effect of the changes from the
perspective of the people who are present in that workplace.
SMETA already gives some opportunity within its standard documentation of the SMETA audit report to include
some indicators which are linked to the satisfaction of employees and managers with the workplace conditions.
Efforts continue within the membership to improve on this type of reporting and to steer SMETA methodology
towards a greater levels of reporting on the effects that workplace changes have on the people who make
products in global supply chains.
In anticipation of further work this SMETA revision (December, 2014) has included a section on what can
already be reported under the current guidance and audit report structure.

The SMETA Audit Report

Audit Overview
Attitude of workers
This section should record the workers view of "what it is like to work here". The auditor should report on the
main benefits, but also the main challenges from a workers perspective. The group interview is often a useful
tool for obtaining a consensus view.
Individual interviews may reveal more sensitive issues which a worker feels unable to share with management,
colleagues or worker representatives. Since a worker’s confidentiality must be respected it may not be
appropriate to make a direct record of this, but please see 'Supplementary Guidance for Dealing with
Sensitive Issues Raised at Audit' on the member’s resources section of the Sedex website.
The auditor should ask questions such as:

● What is your biggest challenge working here.

● What single thing would you change if you could.

● Have you seem any improvements in your time here and if so what are they.

● Where do you go if you have a problem.

Attitude of Managers
This section should record the management views of "what it is like to work here". Managers are usually
workers too and their views of what are the challenges and any changes made is equally useful.

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Key Information
Management Systems.
Annual Worker Turnover
(Number of workers leaving in the last 12 months as a % of the average total number of workers on site over the year)
This figure for annual worker turnover may give a numerical indication of "what it is like to work here" and it is a
statistic which the site management should keep. A useful question of both management and workers would
be to understand why people leave;
● Is there an exit interview.
● What information is asked for/given at the exit interview.
● What is the turnover norm for the area.
● What challenges does this give the management – training, labour shortages etc.
● An accurate self-analysis supported by the audit process, can lead to awareness for management of
the cost of losing workers and a discussion on how that may be changed.

Worker Interview Summary

What was the most common worker complaint.
This should be viewed as an opportunity for improvement and can be useful to management if they need to
reduce their turnover of labour. An auditor should make every effort to find the common view from the majority
of workers, whilst ensuring the confidentiality of individuals.
What did the workers like the most about working at this site.
This will give a balanced view when compared with the section above.
Any additional comment(s) regarding interviews.
This is an opportunity to record any worker opinions/views which have not been recorded elsewhere. It is
important that the auditor attempts to measure the approx. proportion of workers represented by a particular
recorded statement. A majority view, if resulting in a change, is more likely to affect a bigger proportion of
workers, than a view expressed by a single worker. However the single view should not be missed and the
worker should attempt to discover if that single view represents the view of many workers.

Audit Results by Clause

In each section it is possible to record the effect of current conditions on the people working at the site. As an
example recording the number of work related accidents per year and the trend, will give a picture of the health
& safety practices at the site. Do workers feel safe at the site and if not why not. These can be recorded under
'Current Systems and Evidence Examined', as well as in observations.
Interviews with the managers can be used to record whether the managers responsible for implementation of
standards are authorised to make changes. This can be reported in the 'SMETA Audit Report' under section 0
‘Management systems and code Implementation’.
In each of the clauses, auditors should consider what effect the current conditions have on the people
employed at the site, whether any changes have benefitted the employees and if there is a single change which
would have a significant improvement effect on "what it is like to work here". Often these would not be non-
compliances, but can be reported under observations (which are defined in the BPG as opportunities for
improvement), or in 'Current Systems and Evidence Examined'.
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ENCOURAGING WORKER/
MANAGEMENT DIALOGUE
Introduction
The SMETA methodology places significant emphasis on the need for auditors to accurately report the
mechanisms in place for managers and workers to communicate and negotiate with each other.
Good communications between management and the workforce within a business is crucial for ensuring that
issues relating to the workforce are put forward for the attention of management and resolved in a manner that
meets both worker and management needs. If the voice of the worker is absent from a workplace then it
cannot be run in a way that takes the interests of the workforce into account and a workplace requires effective
structures of worker representation to ensure that concerns are raised in a constructive and representative
manner.
Many companies also find that good communications improve business outcomes: if workers feel listened to,
and their concerns are raised and resolved, they are more likely to feel engaged with the business, less likely to
leave or be absent and work more efficiently. Engaged workers are also more likely to become involved in
putting forward ideas for improving the way the business operates. To meet the ETI Base Code workers should
be allowed to have worker representation via a worker committee, works council or a trade union – and the
prevention of these by an employer should be marked as a non-compliance. In addition, there are a number of
other methods for worker/management dialogue, including staff surveys, employee suggestion schemes,
hotlines, noticeboards and newsletters. The presence of such additional communication methods should be
investigated and noted on the audit report and where there is evidence that they are particularly effective they
should be recorded as good examples.
This section brings together in one chapter both the current opportunities with the SMETA guidance for
recording current worker/management dialogue, as well as sharing some anonymised case studies of how
increased dialogue has had significant business benefits.

The SMETA Guidance

SMETA Best Practice Guidance
Guidance on how to evaluate and measure worker/management dialogue can be found in the SMETA Best
Practice Guidance under:
6.5.1. Information for Workers
Details the need for workers to be informed about the audit process.This type of information can
be provided to the site management as part of the pre-audit – communication with a request to
make it known to workers in advance. Records of whether this has been communicated is
captured as a question on the SMETA audit report (see SMETA audit report information below).

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6.6.3. Required document List

The document review should always include a review of minutes from worker committee and
union meetings. The auditor should note in the audit report whether minutes exist and whether
the minutes demonstrate that issues raised are then resolved from meeting to meeting.
7.0 AUDIT EXECUTION
7.1. Opening meeting
It is important that the worker representatives (Trade Union or worker committee members) are
invited to join the opening meeting, even where this involves them briefly leaving the production
floor.
7.3.3. Planning Interviews

Note: Worker representatives (Trade Union or worker committee members) should always be included within
worker interviews and discussions should include understanding the level of effectiveness of the worker
representation.

SMETA Measurement Criteria

Guidance on how to evaluate and measure worker/management dialogue can be found in the SMETA
Measurement Criteria (this document) under:

2. Freedom of Association
CURRENT SYSTEMS AND EVIDENCE EXAMINED
It is important that worker representation is discussed during the opening meeting and during the worker
interviews. Worker representatives should be present at the opening meeting and be interviewed either as
individuals, or in a group with other representatives – this should be made clear within the pre-audit
communication. Worker representatives will generally be part of the mainstream workforce and may be involved
in day-to-day site operations; however this should not be used to prevent them joining the opening meeting or
interviews.
Minutes from the worker committee or trade union meetings should be reviewed as part of the document
review. In particular, the minutes should be reviewed for information on the frequency of meetings, the seniority
of management attendees, the key issues raised and whether there is evidence that issues are raised and
resolved over time.
It is essential that the audit report states clearly what form of worker representation is in place. If worker
representation is being prevented by an employer this should be marked as a non-compliance against the ETI
Base Code and any evidence to show that worker organisation has been restricted by management must be
recorded – for example if it is clear from discussion that the management are opposed to a worker committee
or trade union. Where countries have legal requirements governing the need for mandatory unions, or workers
committees and these are not in place, this should be marked as a non-compliance against local law as well as
the ETI Base Code.

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The audit report should include the scope of the worker representatives – i.e. is the remit restricted to health &
safety, or does it include all elements of the workplace conditions. Does it include the ability to negotiate on pay
and rewards (in the case of a union – it is expected that the union would be involved in collective bargaining
over pay and other terms and conditions – if this is not the case it should be noted).
It is essential to record not only whether representative structures exist, but also where these are effective
channels for raising and resolving concerns. This can be established through the opening meeting, through the
document review and through the interviews. Evidence can be sought from meeting minutes and from views
put forward by management and worker representatives. During worker interviews the auditor should also
discuss with non-worker representatives their view of worker representation (e.g. are they aware that there is a
committee, do they feel the committee is effective at raising issues). It is important that any representative
structure ensures all elements of the workforce are represented – e.g. different production areas, different ethnic
groups, both male and female. If it is clear that the structures in place are present but not effective, or not
representative of the workforce as a whole, this should be included as an observation.
It is also important to record what other forms of dialogue are in place, for example worker hotlines, staff
surveys, suggestion schemes, visual noticeboards and management/staff briefings. Again, it is important to
establish whether these appear to be effective methods of dialogue.

9. No Harsh or Inhumane Treatment is Allowed

CURRENT SYSTEMS AND EVIDENCE EXAMINED
A site should have in place a grievance procedure to provide a formal method of reporting issues at work. It
should set out the process for raising issues, for investigating these issues and for communication outcomes
back to the worker raising a grievance. Often, the need for a grievance procedure is set out in local law and the
site should demonstrate how their grievance procedure meets local law.
This will give an indication of the effectiveness of upwards dialogue and it can be recorded in the relevant
section of the SMETA report (see below).

SMETA report
Site practices regarding worker/management dialogue can be recorded in the SMETA Report in the following
sections:

Audit Overview
● Audit Attendance

Field A, B, C: Were worker committee/union representatives present at the opening

meeting/closing meeting and audit.

Field D, E: If not present why not.

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Key Information
● Field Q: What form of worker representation/union is there on site.
This gives an indication of the attitude of an employer towards unions – is it "an open attitude".

● Field R: Is there a legal requirement to have a union.

Which gives the reader some local context. Local union contacts will be useful in exploring this
question

● Field T: Is there any other form of effective worker/management communication channel and describe.
This gives the site the opportunity to explain to the auditor the communication channels already in
place with an opportunity to discuss if they are effective.

Audit results by Clause

2. Freedom of Association
CURRENT SYSTEMS AND EVIDENCE EXAMINED
This allows for the auditor to record the systems in place for worker representation and the current effectiveness
of worker/management dialogue within the site, through the process of worker representatives.
Interviews with union/worker reps should be recorded in this section as well as a summary of the content of
many committee meeting minutes. What was raised and what was management’s responses.
What are the views of management, are they satisfied with the level of dialogue, what barriers do they face etc.

9. No Harsh or Inhumane Treatment is Allowed

CURRENT SYSTEMS AND EVIDENCE EXAMINED
This is an opportunity for the auditor to record the presence or absence of discipline and grievance procedures:

● Do they exist.

● Are they communicated.

● Are they used and to what extent.

● What are common complaints and have they been acted on.
Effective operation of a discipline and grievance procedures, as well as the number of grievances recorded can
be a measure of the quality of worker/management dialogue.

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Case Studies
Case study 1: Perception becomes reality (The importance of good
communication)
During an audit a worker shared with an auditor that he had not received an increase in wages when moved
from a trainee to worker. It was the standard practice at the site that workers who successfully completed 6
months in post would move from trainee to worker with an associated increase in wages. This worker had been
with the site for just over 6 months and claimed this had not happened.
Examination of the records showed that the increase in wages had indeed happened, but this had not been
effectively communicated to the worker in question. It was the normal practice that a staff member in the wages
office would write to all workers who qualified to move up and congratulate them on the promotion as well as
inform them of their wages increase. The person responsible for this process had been absent on sick leave for
2 months and no one had picked up their responsibilities. As a result several workers had not received
confirmation letters and were not aware of their promotions and increased wages.

Case study 2: Effective worker committees (the business case).

During a visit to a site in Bangladesh an auditor interviewed members of the workers committee. In spite of an
80% female workforce all the members of the committee were male and all from the on-site dye house.
Interviews confirmed that they had not met with management in 6 months and they were dissatisfied that their
request for protective overalls in the dye house appeared to have been ignored.
Interviews with management showed that the overalls issue was being examined – but not actioned and that
they did not see any benefits coming from the worker committee management meetings, which they felt were
simply a series of complaints from the workers. In addition they were finding it difficult to engage with their
largely female work force who did not volunteer to be part of the committee.
Confidential interviews with the female workers showed they were reticent about meeting with males who were
not of their family (a cultural norm).
It was noted by the auditor that the turnover of workers was 5% per month and absenteeism was on average
10%. This was leading to excessive training costs for new recruits as well as poor production rates because of
unplanned absenteeism.
The site management decided to partner with a local NGO currently working on providing crèche services for
sites in Bangladesh.
The NGO visited the site to meet with worker representatives. As part of that meeting (and with the agreement
of managers), the Local NGO explained to workers (and managers) the local laws governing employment, i.e.
the rights of workers, but also the responsibilities of workers towards their employers. This included the need to
come to work and the long term consequences of unplanned absences, if the commercial viability of the
enterprise were affected.
As a result of the involvement of the NGO:
● A workers committee and management meeting was established meeting every month.
● A separate committee was formed for the female workers, who met with a female member of
management.

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● Overalls for appropriate workers were made on site.

● Absenteeism was reduced to 5%.
● Turnover of workers was reduced to 2%.

Case Study 3: Employee Forums.

One company developed an employee forum for communication and consultation. Elections are held once
every 2 years in order to nominate a representative for the group whose role is to represent their colleagues,
collect the views of others during meetings and subsequently feedback to their fellow employees.
These elections are held every 2 years in order for the team to become balanced in this time. Representatives
from different areas of the company will undoubtedly have different views as to what should be a priority.
Therefore, a team that is in place for 2 years will have significant time to establish the involvement of different
team members.
Best Practice Guidelines were issued to HR Managers, all Employee Reps and Line Managers to help give
people direction and establish their roles within the team.
Employee forum training was also offered to elected representatives so as to ensure they were aware of their
roles and had adequate training on how to communicate effectively. The training included modules such as how
to be a forum rep, communication skills, representation skills and team building activities.
The supplier is a large group containing many individual sites. Therefore, it is possible that if a company is part
of a large group; the individual Site Employee Forums, could contribute to a Group Forum. This is an initiative in
place within this supplier’s group, where the Group Forum rewards the most effective and proactive site if it
demonstrates good creativity in new ideas.
The meetings are chaired by the Operations Director. This is important as it shows that all level of employment
are involved in the meetings, including senior management.

This document should be used in conjunction with the SMETA Best Practice Guidance Version 5.0,
December 2014.

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The SMETA Best Practice Guidance and Measurement Criteria, as well as SMETA Audit
Report and CAPR has been produced for guidance only.

Other programme reporting formats will also be recognised, including, but not limited
to, WRAP, SA8000 and company specific reports.

Sedex has developed a suit of publications and multi-media resources to help drive
improvements in ethical and responsible business practices.
See more at Sedex Resources page.

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