Self- Assessment Questionnaire

Company Name :

Facility Name :

Core SAQ Type : Facility SAQ

Core SAQ Version : January 2021

The full RBA SAQ is completed within our online tool (RBA-Online), and the official proprietary scoring is only 
provided after submission to the system. When completing the SAQ online, it has dependencies built in so 
some questions are only applicable depending on answers to previous questions. This PDF is provided for 
informational purposes only. Please contact RBA for more information.

Note : Please answer in column F

General Facility Info
FI - Facility Information & Contact
FI1.1 Company Name:
FI1.2 Facility Name (Business License Name):
FI1.3 Facility Address:
FI1.4 Facility City:
FI1.5 Facility State or Province:
FI1.6 Facility Country:
FI1.7 Facility Postal Code:
FI1.8 Please choose your PRIMARY Deliverables:
FI1.9 Main Contact name for EICC audit:
FI1.10 Contact Telephone Number:
FI1.11 Contact Email:
FI1.12 Social and Environmental Responsibility Contact Name:
FI1.13 Contact Position or Title:
FI1.14 Contact Telephone Number:
FI1.15 Contact Email:
FI1.16 Company Headquarters Address (if different from above)(Enter N/A if not applicable):
FI1.17 Notes and Comments on any question in this section: (answer required, If none enter N/A)
FC-Facility Characteristics
What are the principal Product based activities performed at your facility? (To select multiple rows hold down the Ctrl
FC1.1 key and click additional choices):
FC1.2 Please describe Other Manufacturing:
What are the principal Service based activities performed at your facility (To select multiple rows hold down the Ctrl
FC1.3 key and click additional choices):
FC1.4 Please describe Other Services:
FC1.5 How many males are directly employed at your facility?
How many direct male workers, including both local and foreign or migrant workers (please exclude
FC1.6 supervisors/executive/ management/professional)?
FC1.7 How many male production supervisors?
FC1.8 How many male executive/ management / professionals?
FC1.9 How many females are directly employed at your facility?
How many direct female workers including both local and foreign or migrant workers (please exclude
FC1.10 supervisors/executive/ management/professional)?
FC1.11 How many female production supervisors?
FC1.12 How many female executive/ management / professionals?
FC1.13 How many male workers employed at your facility are under the age of 18?
FC1.14a How many female workers employed at your facility are under the age of 18?
FC1.14b What is the procedure to confirm the age of workers, to determine if are under the age of 18?
FC1.14c What is the procedure to remove young workers from working, and provide assisgtance and remedy ?
How many male indirect, contract or dispatch workers are employed at your facility (both local and foreign, persons
FC1.15 not under a direct contract to the facility and not management level)?
How many female indirect, contract or dispatch workers are employed at your facility (both local and foreign, persons
FC1.16 not under a direct contract to the facility and not management level)?
 How many male foreign or migrant workers are employed at your facility? Please exclude foreign employees working
FC1.17 at supervisory, executive or management level.
How many female foreign or migrant workers are employed at your facility? Please exclude foreign employees
FC1.18 working at supervisory, executive or management level.
FC1.19 How many student workers are employed at your facility? (refer to guidance text for the full definition)
FC1.20 How many interns are employed at your facility? (refer to guidance text for the full definition)
FC1.21 How many apprentices are employed at your facility? (refer to guidance text for the full definition)
FC1.22 Is your facility site owned or leased?
FC1.23 Please include the year your company began operations at this location.
During the last 12 months, were there any public demonstrations, protests, or adverse media reports involving your
FC1.24 facility’s operations or business conduct?
FC1.26 How many buildings do you have at this facility?
FC1.27 What is the total property size in square meters (SQM)?
FC1.28 What is the total floor space (under roof, including all floors) in square meters (SQM)?
FC1.29 Notes and Comments on any question in this section: (answer required, if none enter N/A)

FC1.30 How many people are employed onsite at your facility (under the business license, NOT limited to one customer)?
List the number of foreign or migrant workers by nationality: (example: 45 from country A, 60 from country B, etc.).
FC1.31 Note that the the total number should equal the total of FC1.17 plus FC1.18.
List the main languages spoken by workers (including migrant workers). Please exclude foreign employees working at
FC1.32 supervisory, executive or management level.
FOS - Onsite-Location Services
FOS1.1 Do any of your processes include the use or storage of polychlorinated biphenyls (PCB)?
FOS1.2 Do your onsite-location services include a Clean Room?
FOS1.3 Please describe:
FOS1.4 Do your onsite-location services include Waste Water or Solid Waste Treatment or Processing?
FOS1.5 Please describe:
FOS1.6 Do you have an onsite Emergency Response team?
FOS1.7 Please describe:
FOS1.10 Do your onsite-location services include a fire brigade?
FOS1.11 Please describe:
FOS1.12 Do your onsite-location services include power generation?
FOS1.13 Please describe:
FOS1.14 Do your onsite-location services include a hospital/infirmary?
FOS1.15 Please describe:
FOS1.16 Do your onsite-location services include a Crèche/Nursery?
FOS1.17 Please describe:
FOS1.18 Are there any other onsite-location services?
FOS1.19 Please describe:
FOS1.20 How many canteen/catering personnel does your facility have?
FOS1.21 Notes and Comments on any question in this section: (answer required, if none enter N/A)
Do you have any on-site combustion? (gas or coal-fired boilers, on-site electricity or steam generation, gas or coal-fired
FOS1.22 incinerators, etc.)
FOS1.23 Please describe:
FOS1.24 Do you use diesel fuel, gasoline, or propane in a vehicle fleet you own?
FOS1.25 Please describe
FOS1.26 Does your facility have on-site service providers?
FOS1.27 Please describe:

Labor
FLBR - Labor Risk Elements
What percentage of the workers employed at your facility have a written and signed employment agreement or
FLBR1.1 contract?
FLBR1.1a What percentage of these workers with contracts have contracts which are in their native language?
FLBR1.1b What percentage of these workers with contracts were provided before leaving their country of origin?
FLBR1.2 What percentage of the workers employed at your facility are contract or dispatch workers?
Does your facility use third-party workforce recruiters or labor agents in any way to provide foreign or migrant
FLBR1.3 workers?
FLBR1.3a Please specify how many third-party workforce recruiting agencies are used.
Who pays the recruiting, hiring, transportation and other fees including any initial and ongoing fees such as
FLBR1.4 transportation, testing, training, passports, levies, etc.?

Are all initial and ongoing fees related to recruiting hiring, transportation for transportation, testing, training,
FLBR1.4a passports, levy's etc. which are paid by the foreign or local workers reimbursed by the company?
FLBR1.4b Notes/ Comments about Partial Reimbursement of Fees
Are any workers required to deposit money or to turn over / hand in valuables or their personal identity documents
FLBR1.6 (example: passports) for the company to store?
FLBR1.7 How are your employees paid?
 During the last 12 months, has your facility hired or utilized any young workers (under 18) or persons under an
FLBR1.8 apprenticeship, internship, or as a student worker?
If you use Young Workers (under 18), apprentices, interns, or student workers, does your facility have comprehensive
FLBR1.9 employment policies in place for these types of workers in accordance with local law?
FLBR1.10 Does your facility employ young workers (over the local legal minimum age but under 18)?
FLBR1.11 What percentage of your total workforce is under 18?
Does your facility ensure that workers under age 18, even if over the legal minimum age, do not perform any overtime,
FLBR1.12 night work or hazardous work?
FLBR1.13 What are the average weekly work hours of the busiest workers in your facility?
FLBR1.14 Do all your workers have regular rest days (at least one day off every seven-days)?

FLBR1.15 Do all of your workers have regular breaks or are they allowed to rest when they choose during their working hours?
FLBR1.16 On what basis do workers accept overtime work?
Are the wages and benefits for ANY worker at your facility less than the legal minimums OR if there is no legal
FLBR1.17 minimum is it less than industry standard?
FLBR1.18 Are any of your workers paid according to a piece rate?
FLBR1.19 Do you pay workers for overtime hours above the base wage rate?
Do you have procedures to ensure that base wage, overtime, and other wages are calculated correctly, AND only
FLBR1.20 lawful deductions are made?
FLBR1.21 Are wage calculations clearly communicated to workers using a pay stub or similar documentation?
FLBR1.22 Does your facility use fines or pay deductions as a disciplinary measure?
Does your facility investigate causes of employee misconduct and apply such remedies as discussion, explanation,
training, progressive discipline, etc.; before using job or grade demotion, suspension, or termination as a disciplinary
FLBR1.23 method?
FLBR1.24 Are workers permitted time off for medical needs?
Do your facility’s job postings include statements of non-discrimination and are they free from any criteria which
FLBR1.26 would be discriminatory?
Is your facility equipped with accommodations for Disabled persons (e.g. access to worksites, use of toilets, elevators,
FLBR1.27 cafeteria, etc.)?
Does your facility conduct medical testing of job applicants prior to hiring or promotions, other than for local legal
FLBR1.28 requirements or routine drug tests?
FLBR1.28a Does your facility allow pregnancy or virginity testing of job applicants ?
During the last 12 months, were any workers asked to leave the company, fired, moved to a lower paying job, or
FLBR1.29 demoted due to medical or maternity leave?
Are there any facility imposed restrictions or prohibitions, other than by the requirements of country or local laws,
FLBR1.30 concerning workers creating or joining any labor organizations in your facility?

FLBR1.31 Do workers at your facility participate democratically in the selection of representatives for labor organizations?
During the last 12 months, were any workers disciplined or in any way penalized for joining, refusing to join, or quitting
FLBR1.32 any organization?
Do you have any of these types of labor organizations present: Independent Trade Union, Government Union, other
FLBR1.33 external employee representation organization?
FLBR1.34 Notes and Comments on any question in this section: (answer required, if none enter N/A)
FLBR1.35 How much are the fees paid by the worker?
Who is responsible for safekeeping of travel documents (e.g. passport or visa) for foreign and migrant workers at your
FLBR1.36 facility?
Prior to hiring and/or job offering does your facility require job applicants to provide or disclose ANY of the following:
Ethnic Origin, Religion, Political Affiliation, Marital Status, Pregnancy Status, Sexual Orientation, Gender Identity and
Expression, National Origin, Covered Veteran’s Status, Protected Genetic Information, Medical History, Physical
FLBR1.37 Disability, Union Membership Information?
FLBR1.38 Does your facility allow workers the right to peaceful assembly?
FLBR1.39 Does your facility allow employees to Bargain Collectively?
FLBR1.40 Does you Facility have a Collective Bargaining Agreement in place?
FLBC - Labor Control Elements
Is a management representative assigned responsibility for assuring and facilitating compliance with current LABOR
FLBC1.1 laws, regulations and codes for this facility?
FLBC1.2 Name of management representative:
FLBC1.3 Position or Title:
FLBC1.4 Email:

Does your facility adhere to a written LABOR policy (or statement of commitment) endorsed by senior management
that includes all the RBA Code LABOR elements: Freely Chosen Employment, Child Labor Avoidance, Working Hours,
FLBC1.5 Wages & Benefits, Humane Treatment, Non-Discrimination and Freedom of Association?
FLBC1.6 How will you make the LABOR policy available?
FLBC1.8 Please provide contact name and email address and/or URL:
FLBC1.9 Which of the seven (7) RBA Code LABOR elements are NOT included?
Has your facility implemented a SUPPLIER code of conduct that covers LABOR standards including all the RBA Code
LABOR elements: Freely Chosen Employment, Child Labor Avoidance, Working Hours, Wages & Benefits, Humane
FLBC1.10 Treatment, Non-Discrimination, and Freedom of Association?
 Do you place a contractual requirement on your SUPPLIERS (including labor agencies) to be in compliance with current
FLBC1.11 LABOR laws, regulations, or codes of conduct?
Has your facility implemented a policy stating that government issued identification and personal documentation are
FLBC1.12 not to be held by the company?
If required by law to hold identificaiton, has your facility implemented a procedure to return identification to workers
FLBC1.12b immediately upon request?

Has your facility implemented a program to monitor your supply chain for forced or bonded labor (including debt
FLBC1.13 bondage) or exploitative indentured labor, involuntary prison labor, slavery, or trafficking of persons?
FLBC1.13a Do you monitor your supply chain for the use of any workers that are seeking asylum?
FLBC1.13b Please provide information about the nationality of the asylum seeking workers
Has your facility implemented a policy and procedure allowing workers to resign without penalty after giving no more
FLBC1.14 than 30 days notice?
Do you review or require copies of documentation from workers to verify that they are of Legal working age before
FLBC1.15 they begin work?

Does your facility have a system or documented procedure for discovering workers that may be below minimum age
FLBC1.16 and taking corrective actions (Including policy to assist underage workers found working in the facility)?
Is there a policy and procedure in place at your facility to ensure access to educational needs for workers below the
FLBC1.17 age for compulsory education?
Has your facility implemented a policy prohibiting the employment of workers under the age of 15 (or older per your
FLBC1.18 or your customers local regulatory requirements)?

Has your facility implemented a system and/or documented procedure to verify that your suppliers do not use under-
FLBC1.19 age workers under the age of 15 (or older per your or your customers or regulatory requirements)?
Does your facility place a limit on the number of hours that workers can work for the following: Per Day / Week /
FLBC1.20 Month?

FLBC1.21 Is there a policy on legal regular hours, overtime, and facility working hours that is communicated to all workers?
Do you have a process to track and act accordingly when workers are approaching the legal working hour limits or 60
FLBC1.22 hours/week (whichever is lower)?

FLBC1.23 Are records on workers' regular and overtime working hours kept on a daily basis and retained for at least 12 months?
Do your workers review for accuracy and approve the hours they worked for each pay period in the native language(s)
FLBC1.24 of the workers or language(s) which the workers understand
Do you provide all workers upon hire in a language(s) that they can easily understand, a written description of
employment policies including: method for calculating wages, terms of payment and government deductions,
FLBC1.25 employer-provided housing and meals, and disciplinary fines?
Do you have a method for establishing worker wages to be based on the type of work, consistent with market wages,
FLBC1.26 and compliant with the legal minimum wage?
Do you have procedures to ensure that payment to workers and government programs is not delayed or withheld AND
FLBC1.27 proof of payment records are maintained?

Do you have procedures for verifying and continually monitoring the workforce recruiter's or employment
agencies’ compliance to ensure that they are not charging or deducting fees from workers, not holding passports,
FLBC1.28 providing safe housing where applicable, and wages and deductions conform to local and national laws?
Has your facility implemented and does it communicate in the native language(s) of the workers or language(s) which
the workers understand, policies that describe acceptable worker conduct, expectations, and disciplinary measures
FLBC1.29 where those principles are not complied with?

Do you have a policy that prohibits contract substitution or change(s) allowed in the employment agreement upon
FLBC1.29a arrival in the receiving country unless these changes are made to meet local law and provide equal or better terms?
FLBC1.30 Are managers and supervisors trained on the acceptable worker practices and disciplinary measures?
If employees or workers violate company policies, does your facility management have a procedure for issuing
FLBC1.31 warnings to them, taking a progressive approach?
Has your facility implemented procedures for prevention of harassment, coercion, threatening behavior, physical
FLBC1.32 abuse or punishment, sexual abuse, or verbal abuse towards workers?

Does your facility have a process for workers to confidentially report cases of harassment, coercion, threatening
FLBC1.33 behavior, physical punishment or abuse, sexual or verbal abuse and are these recorded and investigated?
FLBC1.35 Are records kept and periodically reviewed to confirm adherence to these guidelines?

FLBC1.36 Do you communicate and conduct training on non-discrimination guidelines to all workers, supervisors, and managers?
Is there a policy permitting employees to perform religious obligations without restriction AND is it practiced /
FLBC1.37 allowed?

Other than through a labor organization, does your facility have an active ongoing process for workers to communicate
FLBC1.38 openly with each other and with management regarding their collective views and interests?
 Is there a policy, that is communicated and trained on, stating that workers at your facility are free to join labor
organizations or trade unions or other collective bargaining organizations of their choice, where country or local laws
FLBC1.39 do not prohibit it?
Is there a policy in place prohibiting the facility from interfering with or attempting to control the labor organization or
FLBC1.40 trade union in any way?
FLBC1.41 Are workers informed if they are automatically enrolled in a labor organization or trade union?
FLBC1.42 Notes and Comments on any question in this section: (answer required, if none enter N/A)
Do you have written policies and guidelines to prevent discrimination in hiring, promotion, equal pay, benefits, and
training based on race, color, age, gender, sexual orientation, gender identity and expression, ethnicity or national
origin, disability, pregnancy, religion, political affiliation, union membership, covered veteran status, protected genetic
FLBC1.43 information or marital status?
FLBC1.20a Is all overtime (outside of the CBA) voluntary?
FLBM - Labor Management Systems
Does your facility utilize a management systems approach (including policies, programs, procedures, and review
FLBM1.1 processes) to assure proper management of LABOR practices?
FLBM1.2 Please name, explain, or describe the type of certificate and certifying body:
FLBM1.3 Expiration Date:
FLBM1.4 On what system or standard is it modeled?
FLBM1.5 To what extent are your LABOR management system(s) documented?
When was the most recent LABOR management systems reviewed for current status and possible improvement
FLBM1.6 opportunities?
FLBM1.7 Does your facility monitor LABOR laws and regulations that apply to your facility?
Does your facility have written performance objectives for LABOR practices, including metrics and targets with
FLBM1.8 implementation plans for achieving those objectives?
FLBM1.9 When did your facility review performance against LABOR objectives and targets?
When did your facility conduct a risk assessment to identify (including root cause determination), prioritize, and
FLBM1.10 mitigate the potential LABOR risks associated with your operations and activities?

When did your facility conduct an audit of LABOR practices in order to assess conformance with regulatory
FLBM1.11 requirements, internal facility requirements, appropriate external codes of conduct and other requirements?
Are LABOR records maintained according to a documented record retention schedule that aligns with applicable
FLBM1.12 regulations and company policy?
When was the last training of ALL employees on acceptable LABOR practices in a language(s) all workers can easily
FLBM1.13 understand?
Has your facility implemented a program to assess risks and manage the identified risks relating to the LABOR practices
FLBM1.14 of your SUPPLIERS (including any contractors or labor agents)?
Is information about the facility LABOR performance practices and expectations communicated to workers, customers,
FLBM1.15 and suppliers?
FLBM1.17 Notes and Comments on any question in this section: (answer required, if none enter N/A)
When was the last time your facility received a LABOR practices audit or assessment by a customer or other external
FLBM1.18 organization at this facility?
Has your company identified a senior executive and company representatives to ensure implementation of your LABOR
FLBM1.19 policy and achievement of LABOR objectives?

Health & Safety

FHSR - Health & Safety Risk Elements

During the past 3 years, has the facility received a notification of, been prosecuted, or cited for any HEALTH and
FHSR1.1 SAFETY violations resulting in penalties or corrective actions mandated by a court or government authority?
FHSR1.2 Describe the nature of the notice, who it is from and the corrective actions taken
FHSR1.3 Are all required permits, licenses and required testing for HEALTH and SAFETY In Place and current?
Does the potential exist that your workers come in contact with flammable or corrosive substances, chemical or
FHSR1.4 biological agents, harmful emissions or lasers?

How many workers have access or are routinely exposed, at any level, to the Toxics per GHS (Acute, Carcinogenicity,
FHSR1.4a Germ Cell Mutagenicity, Reproductive, Target Organ, or Aspiration) for operations or production (e.g. exclude lab use)?
FHSR1.4b List the technical names and CAS Registry Numbers of the Toxics per GHS

FHSR1.6 Does the potential exist for your workers to come in direct contact with unprotected energized electrical circuits?
Do your workers need to work on or around high-pressure vessels, powered industrial vehicles or dangerous
FHSR1.7 machinery?
Does the potential exist for your workers to enter a confined space (an area whose enclosed conditions and limited
FHSR1.8 access would make an emergency exit difficult)?
FHSR1.9 Does the potential exist for workers to be working from heights?
Are all your permits, test reports, certificates and licenses related to Occupational Safety and Machine Safeguarding
FHSR1.10 current and in full compliance?

FHSR1.11 Are the emergency exits clearly and properly marked, maintained, unlocked, and free from blockage at all times?
 Has your facility installed and maintained effective emergency detection and alarm systems to address all building
FHSR1.12 areas?
FHSR1.13 Are all emergency supplies placed in proper locations at the facility for immediate use?
During the last 12 months, were there any fires, explosions, industrial accidents, hazardous releases outside of
secondary containment at your facility that resulted in serious injury, fatality, environmental releases, or property
FHSR1.14 damage?
FHSR1.16 Do you have operations in a multi story building?
FHSR1.17 Is there a warehouse, manufacturing assembly, or storage of any kind above the ground floor?

FHSR1.17a Is there manufacturing assembly, manufacturing machinery or heavy storage of any kind above the ground floor level ?
FHSR1.18 Are any of your workers performing physically demanding work?
Does your facility have a program, providing appropriate tools and equipment, etc., to control worker exposure to
FHSR1.19 physically demanding work to prevent work-related INJURIES?
Does your facility have written guidance that defines and classifies different types of work-related INJURIES or
FHSR1.20 ILLNESSES?
FHSR1.22 In the last 12 months did any work-related INJURIES/ILLNESSES occur at your facility?
FHSR1.23 In the last 12 months did any work-related FATALITIES occur at your facility?

Does your facility provide housing for its workers (dormitory or worker housing, hostels, apartments or any other form
FHSR1.24 of living quarters) directly or through the government, a labor agent, contractor or other 3rd party?
FHSR1.24a How many people live in this house?
FHSR1.24b What type of housing or living quarters are provided?
FHSR1.25 Are your workers required to live in this housing?
FHSR1.26 Does your facility allow workers to freely leave the facility or housing area while off shift?
FHSR1.27 Does your facility impose a curfew on workers living in this housing?
FHSR1.28 What is the average number of persons per 10 square meters in the housing?
FHSR1.29 Are workers provided with extra living space in addition to their beds?
FHSR1.30 Are beds shared between day and night shift workers?
FHSR1.31 Does the housing provide: Safe drinking water?
FHSR1.32 Does the housing provide: Sanitary toilet facilities?
FHSR1.33 Does the housing provide: Fire detection AND alarm systems?
FHSR1.34 Does the housing provide: Adequate ventilation AND heating?
FHSR1.34a Does the housing provide: Adequate lighting?

FHSR1.35 Does the housing provide: Clearly and properly marked exits that are unblocked AND unlocked at all times?
FHSR1.36 Does the housing provide: Secure storage for personal belongings?
FHSR1.37 Does your facility provide or contract for canteen services for workers?
FHSR1.38 Does the canteen provide: Safe drinking water?
FHSR1.39 Does the canteen provide: Clean and sanitary food storage?
FHSR1.40 Does the canteen provide: Clean and sanitary food preparation?

FHSR1.41 Does the canteen provide: Health standards for food handlers including required food handling certification?
FHSR1.42 Does the canteen provide: Health and nutrition standards for food offerings?
FHSR1.43 Notes and Comments on any question in this section: (answer required, if none enter N/A)
FHSR1.44 Does the potential exist for your workers to be exposed to extreme temperatures?
FHSR1.45 Does the potential exist for your workers to be exposed to extreme noise?
FHSC - Health & Safety Control Elements
Is a management representative at this facility assigned responsibility for assuring compliance with current HEALTH
FHSC1.1 and SAFETY laws, regulations and codes?
FHSC1.2 Name of management representative:
FHSC1.3 Position or Title:
FHSC1.4 Email:
Has your facility implemented written HEALTH & SAFETY policies and procedures which is endorsed by senior
management that includes all the EICC Code HEALTH & SAFETY elements: Occupational Safety; Emergency
Preparedness; Occupational Injury and Illness; Industrial Hygiene; Physically Demanding Work; Machine Safeguarding;
FHSC1.5 Sanitation, Food and Housing?
Are your HEALTH and SAFETY policies and procedures posted and communicated clearly to workers in the language(s)
FHSC1.6 understood by the workers?
FHSC1.7 How will you make the HEALTH and SAFETY policies available?
FHSC1.9 Please provide contact name and email address and/or URL:
FHSC1.10 Which of the eight (8) RBA Code HEALTH & SAFETY elements are NOT included?
Has your facility implemented a SUPPLIER code of conduct that covers HEALTH & SAFETY standards including all the
RBA Code HEALTH & SAFETY elements: Occupational Safety; Emergency Preparedness; Occupational Injury and Illness;
Industrial Hygiene; Physically Demanding Work; Machine Safeguarding; Sanitation, Food and Housing, Health and
FHSC1.11 Safety Communication?
Do you have an ongoing process to identify, assess and control potential worker exposure to safety hazards (e.g.
FHSC1.11a chemical, electrical and other energy sources, fire, vehicles, and fall hazards)?
 Does it follow the Hierachy of Controls approach to focus first on proper design, then engineering and finally
administrative controls (including PPE), preventative maintenance and safe work procedures (including lockout/tag
FHSC1.11b out)?
Do you place a contractual requirement on your SUPPLIERS (including any contractors or labor agents) to be in
FHSC1.12 compliance with current HEALTH and SAFETY laws, regulations, or codes of conduct?

You noted that the potential exists for your workers to come in direct contact with unprotected energized electrical
circuits. Are all workers who come into contact with unprotected energized electrical circuits fully certified or qualified
FHSC1.15 to work on electrical issues and employ a lock-out tag-out approach when appropriate?
You noted that your workers need to work on or around high-pressure vessels, powered industrial vehicles, or
dangerous machinery. Do you have documented and implemented procedures in place for safeguarding workers from
FHSC1.16 potential hazards related to ALL of the conditions occurring at your facility?
You noted that the potential exists for your workers to enter a confined space. Are the confined spaces properly
FHSC1.17 marked, have only restricted access and do workers know how and when to enter them safely?
You noted that the potential exists for workers to be working from heights. Is fall protection equipment in all of the
FHSC1.18 appropriate places and safety gear used by workers in all appropriate cases?
Do you provide mandatory occupational and process safety instructions to workers, including operating machines
safely, proper machine maintenance, materials handling, understanding MSDS / SDS (Material Safety Data Sheets) in a
FHSC1.19 language that all workers can easily understand?
Has your facility identified, assessed, and implemented preparedness systems/procedures for potential emergencies
such as process failures, accidents, storms, floods, or other events that could pose a threat to workers, the community,
FHSC1.20 and the environment?
Are all employees instructed in a way they can understand on how to respond in case of fire or other emergencies
FHSC1.21 including an annual drill of all shifts in all buildings?
FHSC1.22 Is your facility equipped with fire and or chemical emergency detection and suppression system?
Are fire and emergency instructions for workers posted in convenient locations at the facility in a language(s) that all
FHSC1.23 workers can easily understand?
FHSC1.24 Does your management encourage workers to report all work-related INJURIES or ILLNESSES?
FHSC1.25 Are there properly trained and equipped medical emergency responders at your facility?
Does your facility have a program to provide regular medical examinations for workers to detect any symptoms of
FHSC1.26 work-related ILLNESSES or INJURIES?
You noted work-related INJURIES/ILLNESSES occurred at your facility in the last 12 months. Was root cause analysis
FHSC1.27 conducted and corrective action taken, including appropriate documentation?
You noted that your facility provides housing for workers. Does your facility have a process to assure that the housing
facilities are in compliance with company standards and local health and safety codes, including maintenance,
FHSC1.28 inspection, and corrective actions if deficiencies are identified?
You noted that your facility provides canteen services for workers. Does your facility have a process to assure that
your canteen facilities are in compliance with company standards and local health and safety codes, including
FHSC1.29 maintenance, inspection, and corrective action if deficiencies are identified?

FHSC1.30 Does your facility utilize or have on site HEALTH and SAFETY technical specialists such as industrial hygienists?
FHSC1.31 Please specify what types of specialists:
FHSC1.32 Notes and Comments on any question in this section: (answer required, if none enter N/A)

You noted that the potential exists for your workers to be exposed to flammable or corrosive substances, biological
agents, lasers or harmful emissions. Does your facility provide adequately maintained engineering controls AND is
FHSC1.33 Personal Protective Equipment (PPE) provided for free to these workers and is it in good working condition?
You noted that the potential exists for your workers to be exposed to extreme temperatures. Is PPE provided for free
FHSC1.34 to these workers and is it in good working condition?
You noted that the potential exists for your workers to be exposed to extreme noises. Is PPE provided for free to these
FHSC1.35 workers and is it in good working condition?
Does your facility have a program to conduct medical examinations of young workers to ensure they are fit for the
FHSC1.260 work?
FHSC1.24a Does your management encourage workers to report all concerns without fear of retaliation?
FHSM - Health & Safety Management Systems
Does your facility utilize a management systems approach (including policies, programs, procedures, and review
FHSM1.1 processes) to assure proper management of HEALTH and SAFETY practices?
FHSM1.2 Please name, explain or describe the type of certificate and certifying body:
FHSM1.3 Expiration Date:
FHSM1.4 On what system or standard is it modeled?
FHSM1.5 To what extent are HEALTH and SAFETY management system(s) documented?
When was the most recent HEALTH and SAFETY management system reviewed for current status and possible
FHSM1.6 improvement opportunities?
FHSM1.7 Does your facility monitor HEALTH and SAFETY laws and regulations that apply to your facility?
Does your facility have written performance objectives for HEALTH and SAFETY practices and results, including metrics
FHSM1.8 and targets with implementation plans for achieving those objectives?
FHSM1.9 When did your facility review HEALTH and SAFETY performance against these objectives and targets?
 When did your facility conduct a risk assessment process to identify, conduct root cause, prioritize, and mitigate the
FHSM1.10 potential HEALTH and SAFETY risks associated with your operations and activities?
When did your facility conduct an audit of HEALTH & SAFETY practices in order to assess conformance with regulatory,
FHSM1.11 internal and other requirements?
Are HEALTH and SAFETY records maintained according to a documented record retention schedule that aligns with
FHSM1.12 applicable regulations and company policy?
When was the last training of ALL employees on acceptable HEALTH and SAFETY practices in a language(s) all workers
FHSM1.13 can easily understand?
When is initial training provided to ALL employees on acceptable HEALTH and SAFETY practices in a language(s) all
FHSM1.13a workers can easily understand?
Has your facility implemented a program to assess risks and manage the identified risks relating to the HEALTH and
FHSM1.14 SAFETY practices of your SUPPLIERS?
Does your facility communicate information about its HEALTH and SAFETY performance practices and expectations to
FHSM1.15 external groups?
FHSM1.17 Notes and Comments on any question in this section: (answer required, if none enter N/A)
When was the last time your facility received a HEALTH and SAFETY practices audit or assessment by a customer or
FHSM1.18 other external organization at this facility?
Has your company identified a senior executive and company representatives to ensure implementation of your
FHSM1.19 HEALTH and SAFETY policy and achievement of HEALTH and SAFETY objectives?

Environmental
FENR - Environmental Risk Elements

During the past 3 years, has the facility received a notification of, been prosecuted, or cited for any ENVIRONMENTAL
FENR1.1 violations resulting in penalties or corrective actions mandated by a court or government authority?
Does your facility perform activities or handle materials that require an environmental permit (i.e., wastewater,
FENR1.2 hazardous waste, air emissions, treatment, storage, disposal, etc.)?

During the last 12 months, was your facility required to self-disclose exceedances or excursions to a government
FENR1.2a agency? (i.e., wastewater, hazardous waste, air emissions, treatment, storage, disposal, etc.)?
During the last 12 months, was your facility cited or warned by a government agency regarding regulatory or
FENR1.3 permit/license non­compliance?
FENR1.4 Please describe the nature of the citation and the resulting actions taken.

FENR1.5 Does your facility store and/or use hazardous materials (flammable, corrosive, toxic, reactive, etc.) for any reason?
Does your facility store and/or use Toxics per GHS (Acute, Carcinogenicity, Germ Cell Mutagenicity, Reproductive,
FENR1.5a Target Organ, or Aspiration) for operations or production (e.g. exclude lab use)?

Does your facility ship, by transportation, any dangerous goods that are listed or regulated as a hazardous material by
FENR1.5b the International Civil Aviation Organization (ICAO) or International Maritime Dangerous Goods (IMDG) Code?
FENR1.6 Does your facility use any hazardous materials in volumes that require storage or use permits?
Does your facility use any hazardous materials with a high hazard (e.g. Hazard Severity of 4 or 3) in volumes that
FENR1.6a require storage or use permits?
List the technical names and CAS Registry Numbers of high hazard materials (e.g. Hazard Severity of 4 or 3) in volumes
FENR1.6b that require storage or use permits:

FENR1.7 In the past 3 years, have you received a notice of violation or penalty for non-compliance of these permits?
FENR1.8 Do you have chemicals at your facility that are stored outside or in uncovered areas?
FENR1.9 Do the chemical storage areas at your facility have secondary containment for all chemicals?

FENR1.10 Does your facility store any of the following in underground tanks: hazardous, flammable or corrosive chemicals?
FENR1.11 Does your facility generate hazardous wastes in volumes that require storage or use permits?

FENR1.12 Are the following methods of hazardous waste management used by your facility: Onsite waste treatment?
FENR1.13 Onsite long-term (longer than one year) storage?
FENR1.14 Discharge to ground or water (e.g. pond)?
FENR1.15 Collection and transfer to a licensed hazardous waste management facility?
FENR1.16 What type of wastewater is generated at your facility?
FENR1.17 Does your facility treat wastewater onsite in any way?
In the last 2 years, did you receive any notice of violation from authorities regarding waste water treatment, discharge
FENR1.18 or release?
FENR1.18a For Yes or Partial, please provide Notes/ Comments
FENR1.19 Does your facility dispose of non-hazardous waste at your facility?
FENR1.20 Does your facility dispose of non-hazardous waste at a public non-hazardous waste facility?
Does your facility dispose of non-hazardous waste using properly licensed third party waste management / disposal
FENR1.21 firms, approved by local authorities?
FENR1.22 How does your facility handle excess or obsolete non-hazardous materials and/or parts?
FENR1.23 Does your facility generate air emissions?
FENR1.23a Does your facility use/track/label Ozone Depleting Substances?
FENR1.23b Does your facility manage Ozone Depleting Substances in accordance with the Montreal Protocol?
FENR1.24 Are all air emissions currently within the regulated discharge limits?
FENR1.25 Are all noise levels at the facility currently within regulatory limits?

Has your facility implemented programs and/or procedures to phase out controlled materials from its product within a
FENR1.26 specified time period, consistent with international legislation on restriction of hazardous substances?
During the last 12 months, have any of your facility’s products been rejected by the buyer or banned from any market
FENR1.27 as a result of the use of controlled materials?
FENR1.28 Please describe these incidents and Corrective Actions taken:
Has your facility implemented programs and/or procedures to assure proper information disclosure for your products,
FENR1.29 including material composition and product safety information?
Does your facility have a program to facilitate recovery of discarded products, components, or materials at the end of
FENR1.30 their useful life (product take-back)?
FENR1.31 Notes and Comments on any question in this section: (answer required, if none enter N/A)
Does your facility release any Chlorofluorocarbons (CFCs), Sulfur Hexafluoride (SF6) or other significant non-
FENR1.32 hydrocarbon greenhouse gas emissions from your facility?
Does your facility store and/or use any substances listed in the Annexes of the Montreal Protocol or GHS Category 1
FENR1.33 Hazardous to the Ozone Layer?
FENC - Environmental Control Elements
Is a management representative at this facility assigned responsibility for assuring and facilitating compliance with
FENC1.1 current ENVIRONMENTAL laws, regulations and codes?
FENC1.2 Name of management representative:
FENC1.3 Position or Title:
FENC1.4 Email:

Does your facility adhere to a written ENVIRONMENTAL policy (or statement of commitment) endorsed by senior
management that includes all the RBA Code ENVIRONMENTAL elements: Environmental Permits & Reporting;
Pollution Prevention and Resource Reduction; Hazardous Substances; Solid Waste; Air Emissions; Materials
FENC1.5 Restrictions, Water Management, and Energy Consumption and Greenhouse Gas Emissions?
Are your ENVIRONMENTAL policies and procedures communicated clearly to workers in a language(s) that all workers
FENC1.6 can easily understand?
FENC1.7 How will you make the ENVIRONMENTAL policy available?
FENC1.9 Please provide contact name and email, and/or URL.
FENC1.10 Which of the six (6) EICC Code ENVIRONMENTAL elements are NOT included?
Has your facility implemented a SUPPLIER code of conduct that covers ENVIRONMENTAL standards including all the
RBA Code ENVIRONMENTAL elements: Environmental Permits & Reporting; Pollution Prevention and Resource
Reduction; Hazardous Substances; Solid Waste; Air Emissions; Materials Restrictions, Water Management, and Energy
FENC1.11 Consumption and Greenhouse Gas Emissions?
Do you place a contractual requirement on your SUPPLIERS (including contractors) to be in compliance with current
FENC1.12 ENVIRONMENTAL laws, regulations, or codes of conduct?
Does your facility have a program and/or procedures for obtaining environmental permits/approvals and managing
FENC1.13 compliance with the permit requirements?
Are your facility operations currently in compliance with all local and national monitoring, reporting, and
FENC1.14 permit/approval requirements?
Does your facility have a program and/or procedures including record keeping and metrics to systematically reduce or
FENC1.15 eliminate pollution and waste in your operations?
Does your facility have a program and/or procedures including record keeping and metrics to systematically track and
FENC1.16 reduce the use of energy, water, and other resources in your operations?
Do you have a program to track and reduce or eliminate the use of natural resources, including water fossil fuels,
FENC1.16a minerals and virgin forest products?
You noted that your facility stores and/or uses hazardous materials. When did the workers who handle hazardous
FENC1.17 materials last receive the appropriate training?
You noted that your facility generate hazardous wastes in volumes that require storage or use permits. Does your
facility have a program and/or procedures for management of hazardous wastes, including monitoring,
FENC1.18 characterization, treatment or conversion, and disposal?

You noted that there is collection and transfer of hazardous waste to a licensed management facility. When did you
FENC1.19 last audit the hazardous waste management facility that collects and transfers your hazardous waste?

You noted that waste water is generated at your facility. Does your facility have a program and/or procedures for
FENC1.20 management of wastewater, including monitoring, characterization, treatment, discharge, and/or recycling?
Does your facility have a program and/or procedures for management of non-hazardous waste (e.g. office waste,
FENC1.21 trash), including collection, separation, disposal, and/or recycling?

You noted that your facility generates air emissions. Does your facility have a process to identify, characterize, monitor
FENC1.22 and control all air emissions from your facility in accordance with country/local regulations?
 You noted that your facility generates air emissions. Are engineering controls (oxidizer, scrubber, precipitator, etc.)
FENC1.23 required for any reason to safely manage air emissions from your facility?
FENC1.24 Please specify the controls you use:
FENC1.25 Do you have a preventive maintenance schedule to ensure proper operation of air emission controls?
Has your facility implemented programs and/or procedures to determine the quantities of controlled materials (e.g.
lead, mercury, cadmium, CFCs, flame retardants) in your products and any material you purchase (to be compliant
FENC1.27 with regulatory and customer requirements)?
FENC1.27a Do you have a program to track and document all relevant Scope 1 and Scope 2 emissions?

FENC1.27b Do you have a program to reduce or eliminate emissions and discharges of pollutants and generation of waste?
Does your facility utilize or have on site ENVIRONMENTAL technical specialists such as pollution control or waste
FENC1.28 management engineers?
FENC1.29 Please specify what types of specialists:
Has your facility implemented programs and/or procedures to ensure that your SUPPLIERS are in compliance with
FENC1.30 product content restrictions?
FENC1.31 Notes and Comments on any question in this section: (answer required, if none enter N/A)
Does your facility have a stormwater management plan in place to prevent stormwater contamination from chemicals
FENC1.32 and other materials used at your facility?
Does your facility have a program to inventory, reduce, and report the emissions of Scopes 1 and 2 greenhouse gasses
FENC1.33 (GHGs) from your operations?
Does your facility have access to a corporate wide GHG reduction goal which included a program to inventory, reduce,
FENC1.33a and report the emissions publicly?
FENC1.34 Does your facility translate energy use into greenhouse gas emissions at the facility level?
FENM - Environmental Management Systems
Does your facility utilize a management systems approach (including policies, programs, procedures, and review
FENM1.1 processes) to assure proper management of ENVIRONMENTAL practices?
FENM1.2 Please name, explain or describe the type of certificate and certifying body:
FENM1.3 Expiration date:
FENM1.4 On what system or standard is it modeled?
FENM1.5 To what extent is the above ENVIRONMENTAL management system(s) documented?
FENM1.6 When was the most recent ENVIRONMENTAL management systems review?
FENM1.7 Does your facility monitor ENVIRONMENTAL laws and regulations that apply to your facility?
Does your facility have written performance objectives for ENVIRONMENTAL practices and results, including metrics
FENM1.8 and targets with implementation plans for achieving them?
FENM1.9 When did your facility review ENVIRONMENTAL performance against these objectives and targets?
When did your facility implement a risk assessment process to identify, conduct root cause, prioritize, and mitigate the
FENM1.10 potential ENVIRONMENTAL risks associated with your operations and activities?
When did your facility last conduct an audit of ENVIRONMENTAL practices in order to assess conformance with
FENM1.11 regulatory and other requirements?
Are Environmental records maintained according to a documented record retention schedule that aligns with
FENM1.12 applicable regulations and company policy?
When was the last training for ALL employees on acceptable ENVIRONMENTAL practices in a language(s) all workers
FENM1.13 can easily understand ?
Has your facility implemented a program to assess risks and manage the identified risks relating to the
FENM1.14 ENVIRONMENTAL practices of your SUPPLIERS (including any contractors)?
Does your facility communicate information about its ENVIRONMENTAL performance practices and expectations to
FENM1.15 external groups?
FENM1.17 Notes and Comments on any question in this section: (answer required, if none enter N/A)
When was the last time your facility received an ENVIRONMENTAL practices audit or assessment by a customer or
FENM1.18 other external organization at this facility?
Has your company identified a senior executive and company representatives to ensure implementation of your
FENM1.19 ENVIRONMENTAL policy and achievement of ENVIRONMENTAL objectives?

Ethics
FETR - Ethics Risk Elements
During the past 3 years, has the facility been prosecuted or cited for labor or ETHICS violations resulting in penalties or
FETR1.1 corrective actions mandated by a court or government authority?
During the last 12 months, how many confidential notifications regarding ethical or legal violations were investigated
FETR1.2 at your facility?
Does your company agree to not pay or give anything of value to any government official or 3rd party for the purpose
FETR1.3 of improperly influencing any official decision or process?

FETR1.4 Do you have a system in place to allow anonymous reporting of Ethical concerns or Ethics Violations concerns?
Has your facility implemented a process for independently investigating reports of ethical or legal misconduct and for
FETR1.5 taking disciplinary actions?
FETR1.6 Is management held accountable for labor, ethics, environmental, and health & safety in the facility?
FETR1.7 Notes and Comments on any question in this section: (answer required, if none enter N/A)
 Does your company agree to not offer, give, or accept anything of value to obtain or retain business or influence a
FETR1.8 decision?
FETC - Ethics Control Elements

Is a management representative or an ethics and compliance officer assigned responsibility for assuring and facilitating
FETC1.1 compliance with current business ETHICS laws, regulations and codes (e.g. bribery, corruption, etc.) for this facility?
FETC1.2 Name of management representative:
FETC1.3 Position or Title:
FETC1.4 Email:

Has your facility implemented a written ETHICS code of conduct or business integrity policy which is endorsed by
senior management that includes all the RBA Code of Conduct ETHICS elements: Business Integrity, Prohibition of
payment of Bribes, Extortion and Embezzlement; Disclosure of Information; Intellectual Property; Fair Business,
FETC1.5 Advertising and Competition; Protection of Identity and Non-Retaliation; Responsible Sourcing of Minerals; Privacy ?
Are your ETHICS policies and procedures communicated clearly to workers in a language(s) that all workers can easily
FETC1.6 understand?
FETC1.7 How will you make the ETHICS policy available?
FETC1.9 Please provide contact name and email address and/or URL:
FETC1.10 Which of the eight (8) RBA Code of Conduct ETHICS elements are NOT included?

Has your facility implemented a SUPPLIER code of conduct that covers ETHICS standards including all the RBA Code of
Conduct ETHICS elements: Prohibition of payment of Bribes, Extortion and Embezzlement; Disclosure of Information;
Intellectual Property (including using software license compliance); Fair Business, Advertising and Competition;
FETC1.11 Protection of Identity and Non-Retaliation; Responsible Sourcing of Minerals; Privacy?
Do you place contractual requirements on your SUPPLIERS (including any contractors or labor agencies) to be in
FETC1.12 compliance with current ETHICS laws, regulations, or codes of conduct?
Has your facility implemented a program and/or procedures to uphold all of the RBA Code of Conduct ETHICS
elements: Business Integrity (corruption, extortion, embezzlement, conflict of interest); No Improper Advantage
(bribery, excessive gift-giving); Disclosure of Information; Intellectual Property (including software compliance license
compliance), Fair Business, Advertising and Competition;Protection of Identity and Non-Retaliation, Responsible
FETC1.13 Sourcing of Minerals; Privacy?
FETC1.14 Which of the eight (8) ETHICS elements are NOT included?
Does your facility have a program and/or procedures to detect, eliminate, and prohibit situations in which managers or
FETC1.15 workers have a potential conflict between the company’s interests and their own?

Has your facility implemented a program and/or procedures to ensure accurate disclosure of information regarding
FETC1.16 business activities, structure, financial situation, and performance in accordance with applicable regulations?
Does a program and/or procedures exist to assure non-disclosure of sensitive or confidential information about
customers, channel partners, suppliers, workers, and other business partners as required by law or your contracts with
FETC1.17 the listed parties?
Has your facility implemented a program and/or procedures to ensure that required standards of fair business,
FETC1.18 including advertising and competitive marketing, are upheld?
Has your facility implemented a written procedure for workers to report about discrimination, ethical violations, harsh
FETC1.19 treatment, or other issues without threat of reprisals?

Has your facility implemented a program and/or procedures to allow workers to submit grievances anonymously if
FETC1.20 they so choose and protect the identity of workers that report suspected cases of ethical or legal misconduct?
Has your facility implemented programs/procedures to uphold RBA Code of Conduct ETHICS elements on suppliers,
contractors, or agents representing the facility: Business Integrity; No Improper Advantage; Disclosure of Information;
Intellectual Property, Fair Business, Advertising, and Competition;Protection of Identity and Non-Retaliation;
FETC1.21 Responsible Sourcing of Minerals; Privacy ?
Are the cases tracked and then results shared with workers at a summary level (without disclosing individuals
FETC1.22 involved)?
Is there active ongoing communications to employees on key ETHICS topics and the code of conduct or business
FETC1.23 integrity policy to all employees in a language(s) all workers can easily understand?
How often does your facility provide formal training to employees on business ETHICS which includes training on all
items in the code of conduct or business integrity policy and how to prevent and detect corruption in a language(s) all
FETC1.24 workers can easily understand?
FETC1.25 Who attends the training?
FETC1.26 Is there targeted ETHICS training for new hires within the first 90 days?
FETC1.27 Do your employees verify compliance to the Code or ETHICS policy?
Is there a survey/process for understanding whether employees feel safe in raising labor, ethics, environmental, health
FETC1.28 & safety concerns in the facility?
Is there an ongoing processes, including grievance mechanism, to assess employees’ understanding of and obtain
feedback on or violations against practices and conditions covered by the facility Code of Conduct and/or policies and
FETC1.28a agreements?
FETC1.29 Notes and Comments on any question in this section: (answer required, if none enter N/A)
Has your facility adopted a policy to exercise due diligence on the source and chain of custody of the tantalum, tin,
FETC1.21a tungsten, and gold (3TG) in the products you manufacture?
FETM - Ethics Management Systems
Does your facility utilize a management systems approach (including policies, programs, procedures, and review
FETM1.1 processes) to assure proper management of ETHICS practices?
FETM1.2 Please name, explain or describe the type of certificate and certifying body:
FETM1.3 Expiration Date:
FETM1.4 On what system or standard is it modeled?
FETM1.5 To what extent are your ETHICS management system(s) documented?
When was the most recent ETHICS management systems reviewed for current status and possible improvement
FETM1.6 opportunities?
FETM1.7 Does your facility monitor ETHICS laws and regulations that apply to your facility?
Does your facility have written performance objectives for ETHICS practices, including metrics and targets with
FETM1.8 implementation plans for achieving those objectives?
FETM1.9 When did your facility review performance against ETHICS objectives and targets?
When did your facility conduct a risk assessment process to identify (including root cause determination), prioritize,
and mitigate the potential Business ETHICS risks associated with your operations and activities including conformance
FETM1.10 with regulatory and legal requirements?
When did your facility conduct an audit of ETHICS practices in order to assess conformance with regulatory, internal
FETM1.11 requirements, appropriate external codes of conduct and other requirements?
Are ETHICS records maintained according to a documented record retention schedule that aligns with applicable
FETM1.12 regulations and company policy?
When was the last training of ALL employees on acceptable ETHICS practices in a language(s) all workers can easily
FETM1.13 understand?
Has your facility implemented a program to assess risks and manage the identified risks relating to the ETHICS
FETM1.14 practices of your SUPPLIERS (including any contractors or labor agencies)?
Is information about the facility ETHICS performance, practices and expectations communicated to workers, customers
FETM1.15 and suppliers?
FETM1.17 Notes and Comments on any question in this section: (answer required, if none enter N/A)
When was the last time your facility received an ETHICS practices audit or assessment by a customer or other external
FETM1.18 organization at this facility?
Has your company identified a senior executive and company representatives to ensure implementation of your
FETM1.19 ETHICS policy and achievement of ETHICS objectives?