RBA Validated Audit Program (VAP)

Operations Manual
Revision 6.0.0– January 2018
Organizations working with and in the Responsible Business Alliance (RBA)
www.responsiblebusiness.org are working to improve sustainability and social responsibility
within the global supply chain.

These companies recognize a mutual responsibility to ensure working conditions are safe,
workers are treated with respect and dignity, and that manufacturing practices are
environmentally responsible. The Validated Audit Program (VAP) is a collaborative approach to
auditing to reduce the burden on supply chain companies from multiple requests for social
audits. The VAP meets the need for a high quality, consistent and cost-effective standard
industry assessment for labor, ethics, health, safety and environmental practices based on the
RBA code of conduct, laws, and regulations.

For more information about the Validated Audit Program (VAP), please contact:
• RBA Email: [email protected]
• RBA Address: Suite 330, 1737 King Street, Alexandria VA 22314, USA
• RBA Website: www.responsiblebusiness.org

© 2017 Responsible Business Alliance. All Rights Reserved. No part of these materials may be reproduced or transmitted in any
form or by any means, electronic or mechanical, including but not limited to photocopy, recording or any other information
storage or retrieval system known now or in the future, without the express written permission of the Responsible Business
Alliance, Incorporated. The unauthorized reproduction or distribution of this copyrighted work is illegal and may result in civil
or criminal penalties under the U.S. Copyright Act and applicable copyright laws.
APPENDIX 11 CODE INTERPRETATION GUIDANCE

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1. GENERAL NOTES
This Appendix outlines requirements or AC for site observation, document review, management knowledge and understanding and worker awareness and
understanding for each of the RBA Code provisions as described in the most current VAP OM. These are termed Conformance Requirements in this Appendix.
All of the Conformance Requirements must be met for the Auditors to conclude Conformance for that AC.
The appendix provides also additional clarification, definitions, details and examples. These are termed Additional Assistance. Additional assistance is guidance
and assistance to the Conformance Requirements but do not form in themselves a requirement of conformance.
Additionally, this Appendix provides guidance for rating non-conformance for each of the AC.

The following notes apply for all provisions herein:

• When there is a discrepancy between the RBA code, local law, a participant’s policies or a Collective Bargaining Agreement, the RBA defines conformance
to the RBA code as meeting the strictest requirements (even if it meets RBA code provisions and legal requirements).
• A legal non-conformance is a Major non-conformance unless otherwise stated in a specific provision (e.g. A3.1 if situation of Auditee is below 60h/w but
above local law for ≤40% of the workers) or there is another finding which has a higher non-conformance rating for that provision
• For the purpose of rating, an element is defined as any listed Conformance Requirement.
• All communications from Auditee to workers must be done in a language the worker can understand unless otherwise stated in the provisions. If this is not
the case, then the relevant aspect is at minimum a ‘Major’ non-conformance.
• All AC apply to all workers, including temporary, migrant, student and contract, directly and indirectly employed workers that work in the factory/on
production/in warehouse and any other type of worker/employee unless the AC specifically states a narrower focus group.
• Unless otherwise noted, references to percentage of workers in conformance or non-conformance are based upon the defined sample.
• A process is not required to be in writing as per ISO (unless the AC states specifically it must be documented), however all processes must be verifiably
implemented in a consistent way
• “Supplier” in this section shall mean “Next Tier Major Supplier”. This is different to ‘supplier” which can be any supplier to the facility.

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2. A. LABOR
A1) Freely Chosen Employment

Forced, bonded (including debt bondage) or indentured labor; involuntary or exploitative prison labor; slavery or trafficking of persons shall not to
be used. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud
for labor or services. There shall be no unreasonable restrictions on workers’ freedom of movement in the facility in addition to unreasonable
restrictions on entering or exiting company-provided facilities. As part of the hiring process, workers must be provided with a written employment
agreement in their native language that contains a description of terms and conditions of employment prior to the worker departing from his or her
country of origin and there shall be no substitution or change(s) allowed in the employment agreement upon arrival in the receiving country unless
these changes are made to meet local law and provide equal or better terms. All work must be voluntary and workers shall be free to leave work at
any time or terminate their employment. Employers and agents may not hold or otherwise destroy, conceal, confiscate or deny access by employees
to employees’ identity or immigration documents, such as government-issued identification, passports or work permits, unless such holdings are
required by law. Workers shall not be required to pay employers’ or agents’ recruitment fees or other related fees for their employment. If any such
fees are found to have been paid by workers, such fees shall be repaid to the worker.

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A1.1 Any type of forced, involuntary or exploitative prison, indentured, bonded (including debt bondage), trafficked or slave labor is not used
Conformance Requirements:
Site Observations Record Review
Not applicable 1) Voluntary work
a) Personnel files and working hour record/wages do not show any
form of non-voluntary labor
2) Fees
a) All Fees and penalties are disclosed to the workers.
b) Records on Fees are maintained and disclosed to the worker
c) Fees are not permitted under any circumstances.
d) Any Fees are required to be returned to the worker within 90 days
of discovery.
3) Loans
a) Personal loans have a repayment maximum of 10 percent of the
worker’s monthly gross base wage, including interest, for no more
than 6 monthly installments.
b) Education loan repayments do not exceed 10% of one year of
gross base wages. Any education loan cannot be longer than 1
year per loan.
Additional assistance:
Site Observations Record Review
Not applicable 1) Voluntary work
a) examples of non-voluntary work: Lack of workers’ consent to
work, unlawful retention of wages or benefits, work through any
form of servitude (e.g. negotiation of visa, housing, work in
exchange for training), security guards (armed or unarmed) keep
workforce under retention
2) Fees
a) Payroll, wage and other records reviewed show no prohibited
fees, excessive fees, significant debt, and/or significant loans
except those acceptable fees listed in Appendix 13
3) Fees are defined in Appendix 13. If a fee is not specifically listed in
Appendix 13 or does not fit any of the example categories, foreign
migrant workers shall not be required to pay anything that a ‘Local
worker would not be required to pay.

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Rating:

Scenario 1 - Prohibited recruitment and hiring fees that were paid and not reimbursed within 90 days, or as soon as practicable upon discovery.
<100% >100%-150% >150%
Frequency \ Severity in monthly gross base wages (<1 month gross base salary) (> 1 month – 1.5 month gross base salary) (> 1.5 month gross base salary)
<1% or 3 workers or fewer (whichever is greater) Minor Major Priority
>1%-5% or more than 3 workers but less than 7 workers Major Major Priority
>5%-40% or more than 7 workers Major Priority Priority
>40% Priority Priority Priority

Scenario 2 - For findings other than prohibited recruitment and hiring fees paid were not reimbursed within 90 days, or as soon as practicable upon discovery:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: Not Applicable Not Applicable
1. Penalty to leave without reasonable notice is >3 1. Termination notice period more than the stricter of 1
months of gross base wages month or law
2. Workers restricted from voluntary employment 2. Penalty to leave without reasonable notice is >60%
termination or penalized in other ways when giving of 1 month of gross base wages (about 2-3 weeks)
reasonable notice. 3. Historic non-voluntary labor was present in last 12
3. A Priority item in A1.3, A1.4 or A1.5 months (situation was removed AND system was not
4. Non-voluntary labor is present (other than scenarios updated)
above or Major nonconformance)
Remote Verification Acceptable: NO

NOTE: A1 provisions are linked as per the below diagram.

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A1.2 Adequate and effective policy and procedures are established ensuring that any form of forced, bonded, involuntary or exploitative prison,
trafficked or slave labor is not used.
Conformance Requirements
Site Observations Record Review
Not applicable 1) Policies
a) Adequate and effective policies and procedures are in place
i) To ensure that no forced, bonded, involuntary or
exploitative prison, trafficked or slave labor is used
ii) Stating that workers are not required to pay fees, Excessive
Fees, deposits or incur debt as part of the employment
iii) Stating that when employment has been terminated
voluntarily or involuntarily, worker will be paid appropriate
amounts for all hours worked.
b) An implemented procedure to determine the specific amount of
any fees and expenses paid by each individual foreign worker
prior to commencement of work.
2) Monitoring
a) Method of monitoring of conformance with policy, monitoring
reports and corrective actions are available for review
Additional assistance:
Site Observations Record Review
Not applicable 1) Policies
a) This is applicable for direct and indirect employment workers.
b) Scope of policies and procedures is during recruiting, hiring and
employment.
c) Stating that workers are not required to pay either as one-time or
installment payments, collected directly or through wage
deductions.
2) Any non-conformance that is related to worker employment
conditions should still be reported within their appropriate
subsection elsewhere (e.g. if wages are delayed, benefits not paid,
then report in A4).

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Rating:
Priority Major Minor Not Applicable
Not applicable One or more of the following is true: One or more of the following is true: Not applicable
1. No policy or procedure (must include recruitment 1. Policy and procedures are in place for recruitment
and hiring practices, termination and other but one of the implementation components is
fees/deposits/debt) missing (e.g., monitoring, correction) in either direct
2. No monitoring of program effectiveness workers or those employed by Labor Agents and
3. Trafficked or slave labor prohibition requirements Contractors
are not in contracts with Labor Agents and 2. Monitoring of program effectiveness is in place but
Contractors corrective actions on findings are open/not in place
4. No contracts are in place between the Auditee and
Labor Agents and Contractors
5. Any priority in A1.1

Remote Verification Acceptable: NO

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A1.3 Terms of contract are provided in writing and in their native language prior to employment (in case of migrant workers, before they leave their
home country/region and no substitution or change(s) was made in the employment agreement upon arrival in the receiving country unless these
changes are made to meet local law and provide equal or better terms) of the key employment terms and conditions via employment
letter/agreement/contract and explained verbally in their native language so workers understand what the contract states.
Conformance Requirements:
Site Observations Record Review
Not applicable 1) Local workers
a) Workers are informed prior to employment of the key
employment terms and conditions either verbally or in writing via
contract in their native language.
b) Contracts state that workers can resign without penalty
2) Migrant workers:
a) Workers are informed prior to employment and leaving their
home country of the key employment terms and conditions either
verbally or in writing via contract in their native language.
b) Contracts state that workers can resign without penalty
c) No substitution or change(s) allowed in the employment
agreement upon arrival in the receiving country unless these
changes are made to meet local law and provide equal or better
terms
d) Contracts comply with ILO conventions on Migrant Workers
3) Verbal explanation to workers of the key components of the
employment conditions in a language they can understand:
a) Nature of work
b) Working hours, Days off and holidays
c) Leave entitlements
d) Benefits (housing, transportation, uniforms, ...)
e) What fees the worker will be charged and the amount(s)
f) Wages and wage deductions (including all components of social
insurance) and how these are calculated.
g) Other non-legally required benefits provided (pension,
insurances, ...)

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Additional assistance:
Site Observations Record Review
Not applicable 1) Local workers
a) Contract = employment letter/agreement /contract
b) Penalty = no threat of punishment, fines, violence, or withholding
wages)
c) Any contract changes are declared and follow good practice
communication/negotiation with worker
d) Defined worker groups (e.g. student, intern, dispatch, etc.) in
compliance with legal and/or customer requirements
2) Migrant workers:
a) Contract = employment letter/agreement /contract
b) Penalty = threat of repatriation, threat of punishment, fines,
violence, or withholding wages).
c) Any contract changes are declared and follow good practice
communication/negotiation with worker
3) A priority rating on this finding also requires a priority rating for
A1.1

Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Contracts are not legally required.
1. Contract substitution for materially worse conditions 1. No contract or contract not in native language or 1. Contracts are provided but are incomplete (e.g.
(e.g. lower wages, different production facility, contract not delivered prior to departure (in case of missing terms or conditions)
undisclosed fees for housing, food, etc.) migrant workers) BUT conditions were 2. Defined worker group mix (e.g. student, intern,
2. No contract or conditions communicated prior to communicated before work began (before leaving dispatch, etc.) exceeds legal limits by >1% but
employment (before leaving home in case of migrant home in case of migrant worker) ≤5%.
worker) 2. Contract or conditions communicated were
3. Contracts contain language to limit the workers’ incomplete (missing one or more elements)
ability to voluntarily terminate their employment 3. Defined worker group mix (e.g. student, intern,
dispatch, etc.) exceeds legal limits by >5%
Remote Verification Acceptable: NO

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A1.4 Upon hiring, the worker’s government issued identification and personal documentation originals are not held by employer/Labor Agent or
Contractor (if applicable)
Conformance Requirements:
Site Observations Record Review
1) Workers can demonstrate where personal 1) Policy
documents are kept. a) Adequate and effective policies and procedures is in place stating
2) Workers maintain possession or control over no government issued identification or personal documents
their identity documents originals are held or stored.
2) Worker possession
a) Worker files contain no workers' personal documentation
originals

Additional assistance:
Site Observations Record Review
1) Policy/Procedures
a) Auditee may request, where permitted, copies of the original
documents).
2) Worker possession
a) Workers' personal documentation originals: e.g. passport; work
visa/permit; citizenship, residence, identification, social
insurance cards/documents; birth certificate; bank documents; ...).
b) In some countries, the local law requires employers to hold
foreign workers’ personal documents. In those cases:
i) Procedures are in place for safe keeping of only those
personal documents required by law.
ii) Personal documents must not be tampered with or damaged
in any way.
iii) Worker must have access to those documents within 12
hours of requesting them.
iv) In no case shall there be a fee for the safe keeping of
government-issued identification, passports or work
permits.
3) A priority rating on this finding also requires a priority rating for
A1.1

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Rating:
Priority Major Minor Not Applicable
1. Any original personal documents are destroyed, One or more of the following is true: One or more of the following is true: Not Applicable
concealed, confiscated, involuntarily held or access 1. Original personal documents are kept 1. When the law requires holding original-documents,
is denied when requested. 2. There is no policy for document safekeeping and/or a safe keeping policy and procedures are in place but
worker access to their documents when the law workers cannot access their documents within 12
requires holding original documents hours.
3. For workers in any form of 2. For workers in any form of
company/agent/contractor provided living company/agent/contractor provided living
accommodations, access to personal secure storage accommodations, access to personal secure storage
is inhibited in >5% of cases. is inhibited in ≤5% of cases.

Remote Verification Acceptable: NO

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A1.5 There are no unreasonable restrictions on the movement of workers and their access to basic liberties
Conformance Requirements:
Site Observations Record Review
1) If workers reside on site (dormitory), access 1) Policy
to the dormitory is open or there are no a) Adequate and effective policies and procedures on freedom of
unreasonable restrictions through procedure movement are in place.
or undue security guard restrictions, on 2) Records
worker’s ability to leave the facility a) Entry and leave records (if applicable) show no restriction in
including during workers' rest time. movement
2) Workers move freely when needed to access
basic liberties.
3) Workers are free to leave the Auditee
location or dormitory when not engaged in
work.
4) There are no systems for restriction in place
such as toilet passes.

Additional assistance:
Site Observations Record Review
1) Freedom to enter and leave site does not 1) Records
apply to prison labor a) Entry and leave records e.g. toilets, drinking water, external
medical facilities, factory/dormitory exit and entry.
2) A priority rating on this finding also requires a priority rating for
A1.1
Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Not Applicable
1. Any situation that is putting workers at a health or 1. Workers are restricted from movement through 1. No policy or procedures are in place on freedom of
safety risk (e.g. locking in factory or dorm). threat or penalty (but not a threat of firing, reporting movement but there are no restrictions on freedom
2. Workers are restricted from movement through to authorities or similarly severe threat), even if a of movement.
threat of firing, reporting to authorities or similarly policy is in place. 2. Non-coercive restrictions systems/procedures are
severe threat. used (e.g. toilet passes)

Remote Verification Acceptable: NO

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 A2) Young Workers

Child labor is not to be used in any stage of manufacturing. The term “child” refers to any person under the age of 15, or under the age for completing
compulsory education, or under the minimum age for employment in the country, whichever is greatest. The use of legitimate workplace learning
programs, which comply with all laws and regulations, is supported. Workers under the age of 18 (Young Workers) shall not perform work that is
likely to jeopardize their health or safety of young workers, including night shifts and overtime. Participant shall ensure proper management of
student workers through proper maintenance of student records, rigorous due diligence of educational partners, and protection of students’ rights
in accordance with applicable law and regulations. Participant shall provide appropriate support and training to all student workers. In the absence
of local law, the wage rate for student workers, interns and apprentices shall be at least the same wage rate as other entry-level workers performing
equal or similar tasks.

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A2.1 Workers are not below the minimum age
Conformance Requirements:
Site Observations Record Review
1) No workers on site appear to be under the 1) Records
minimum age. a) Personnel file sample shows all workers are above minimum age
or above company policy minimum age (whichever is greater)

Additional assistance:
Site Observations Record Review
1) Records
a) The worker roster shows all workers are above minimum age or
above company policy minimum age (whichever is greater)
2) Auditors need to ensure that sample covers all types of
workers/employees.

Rating:
Priority Major Minor Not Applicable
1. Confirmed underage workers are present at the One or more of the following is true: 1. One of the minimum requirement elements is Not Applicable
facility or were present at the facility in the last six 1. No policy or training on policy in place but no missing or ineffective, or a system element is not
months underage workers present adequately documented or is prohibited
2. Two or more of the minimum requirement
elements is missing or ineffective
Remote Verification Acceptable: NO

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A2.2 An adequate and effective policy and process is established to ensure that workers below the legal minimum working age are not hired either
directly or indirectly via labor agencies/contractors.
Conformance Requirements:
Site Observations Record Review
Not applicable 1) Policy
a) Adequate and effective child labor prohibition policies and
procedures are in place
b) There is an adequate process in place to verify the reliability of
age documents. Age verification must include visual verification
of a government recognized photographic identification
document.
c) There is a reliable ID verification system to control the workers'
access into the facility
d) Auditee does not refuse the worker's job application after the
“child” worker's age meets legal requirements.
2) Underage assistance
a) There is a procedure to assist underage children found working
for the Auditee that is designed to provide for the welfare of the
child

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Additional assistance:
Site Observations Record Review
1) Policy
a) Inspect and cross-reference to verify the validity at least two types
of official ID*
b) Reliable ID verification system to control the workers' access into
the facility e.g. finger printing or ID card with owner's
photograph to prevent under-age workers entering the facility by
using another person's ID
c) ID types for verification and cross-reference
i) Matching photographic ID to worker’s face
ii) Verification through third-party resources where available,
such as Internet resources or local government offices
iii) Birth certificate
iv) Government-issued personal identification card
v) Driver’s license
vi) Voting registration card
vii) “Official stamped” copy of a school certificate
viii) Affidavit from local government representative
ix) Foreign national work permit or other government
recognized document.
2) Underage assistance includes
a) Health exam and appropriate action if necessary
b) Completion of compulsory schooling
c) Maintaining the child's income until legally eligible to work
d) When they exist, and are acceptable by law, to move underage
workers into proper apprenticeship positions, restricting their
hours and type of work to accommodate educational needs, as
required, rather than discharging or fining of these workers.
Rating:
Priority Major Minor Not Applicable
1. Child or underage workers are hired directly or One or more of the following is true: 1. Formal policy in place, however, the process is Not Applicable
indirectly through a labor agent/contractor 1. No formal policy and process in place AND no incomplete or proof-of-age documentation is
proof-of-age documentation missing
2. If A2.1 Priority then default Major Non-
conformance for inadequate process
Remote Verification Acceptable: NO

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A2.3 Workers under the age of 18 are not allowed to perform work that is likely to jeopardize the health or safety of these young workers, including
night work or overtime.
Conformance Requirements:
Site Observations Record Review
1. No workers under 18 are performing jobs that 1) Policy
are hazardous a) Adequate and effective young worker policies and procedures are
in place
b) Implementation mechanisms are clearly defined and implemented
including:
i) Health checks if required by law
ii) Clear risk evaluation
iii) Restriction on hours worked and time of day worked
iv) Identification and assignment of young workers to non-
hazardous positions
v) Young workers are not allowed night work or overtime
2) Records
a) The implementation mechanisms are reflected in personnel files,
medical files and work time records.

Additional assistance:
Site Observations Record Review
1) Policy
a) Night work: Night work for young workers may be defined
specifically by local law though generally means any consecutive
period of at least 7 hours between 10 PM and 7 AM
b) Immediate containment, (i.e. re-assignment, putting on to day
shift only …not termination) is required in Priority and Major
findings regarding young workers
2) Records
a) The analysis 100% of Young Worker working hours, overtime,
days of rest are to be noted here in A2.
Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: 1. One of the minimum requirement elements is 1. Policy and implementation mechanisms are in
1. Young workers are doing hazardous work 1. No policy missing or ineffective, or a system element is not place AND No workers under age 18 on site.
2. Young workers are working overtime 2. Two or more of the minimum requirement adequately documented or is prohibited
3. Young workers are doing night work elements is missing or ineffective

Remote Verification Acceptable: NO

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A2.4 Adequate and effective Apprentice/Intern/Student Worker employment policies and procedures are in place.
Conformance Requirements:
Site Observations Record Review
1) Student workers/interns/apprentices only 1) Policy
perform tasks related to their field of study a) Adequate and effective policies and procedures on
or learning of a new vocation and shall not Apprentice/Intern/Student Worker’s assignments:
perform the tasks prohibited by applicable i) If applicable, a written policy stating that the Auditee does
laws. not hire apprentices/interns/student workers.
ii) A commitment to only providing internships/student
workers assignments and apprenticeships that complement
their course of study field or learning of a new vocation;
iii) Maximum duration of apprenticeship (not more than 6
months if worker is paid below minimum wage);
iv) No agency or intermediary may be used in connection with
the recruitment, hiring, arrangement, and management of
student workers, interns or apprentices;
v) All work is voluntary (including choice of learning
placement assignment);
vi) Prohibition of use of student workers, interns or apprentices
to simply fill a labor shortage;
2) Records
a) Tri-partite agreement: If applicable, documented specific
requirements on tri-party agreement (student workers (and/or
legal guardian), school and Auditee)
b) Personnel records:
c) Maintenance of student worker/intern or apprentices' records in
personnel files (includes agreement if applicable, learning
objectives, evaluations, reference to training material,
assignment, …);
d) Details on promotion/hiring opportunities after successful
apprenticeship, eligibility, recruitment, employment agreement,
nature of work, working hours, wages and benefits
i) Training material: An outline of training program and
copies of the training material are available at all times

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Additional assistance:
Site Observations Record Review
1) Policy
a) If the student worker/intern or apprentice is a young worker then
all young worker requirements in A2.3 apply (report in A2.3)
b) An apprenticeship is different from worker probation period.
Apprentice/ intern/student worker programs are regulated by law
in most countries, with specific limits on:
i) Working hours shall also not conflict with the student
worker’s school attendance, duration of training period, and
number of times the same worker can be classified as a
trainee;
ii) Auditee shall not deduct educational fees from the student
worker’s wages nor shall they deduct placement fees from
the student worker’s wages;
iii) Auditee shall ensure that the student worker is insured
against accident or liability and that the student worker is
fully covered for any other forms of insurance required by
law or regulation;
iv) The period where wages can be below minimum wage as
per law should be limited and reasonable in duration or not
longer than 6 months, whichever is stricter; and
v) Student workers/interns/apprentices should only be
assigned to work activities that complement the academic
degree/certificate or skill enhancement learning goals.
2) Records
a) Tri-partite agreement:
i) Student worker’s full name
ii) Student worker’s emergency contact information
iii) The name and address of the student worker’s school
iv) The name and address of the Auditee, etc.
v) Living conditions (if applicable)
vi) Wages and benefits
vii) Costs (if any) for meals and accommodation (must be no
higher than a fair market rate)
viii) Working hours
ix) Nature of work and place where it will be performed
x) Signed in three copies

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Rating:
Priority Major Minor Not Applicable
1. Two or more of the minimum requirement One or more of the following is true: One or more of the following is true: 1. A policy on learning programs is in place AND no
elements is missing or ineffective 1. Work performed by apprentices is not related to a 1. No policy on learning programs in place student workers, interns or apprentices on site
field of study or learning of a new vocation. 2. No school due diligence performed
2. Apprenticeship where worker is paid below 3. One of the minimum requirement elements is
minimum wage is longer than 6 months (longer than missing or ineffective, or a system element is not
6 months is only permitted if legal requirement) adequately documented or is prohibited
3. No tri-party agreement among the school, factory
and student/parent
4. Intern, student worker or apprentice is hired through
a labor agent/contractor
5.
Remote Verification Acceptable: NO

REFERENCE: The table below summarizes specific requirements for student workers, interns, and apprentices:
Requirement Student worker Intern Apprentice
Tri-party agreement (student, school, and company/Auditee) Yes N/A N/A

No financial/scholastic penalty (note scholastic penalty is allowed only if directly related to underperformance on
Yes Yes N/A
educational component of program)

Due Diligence: verify that worker is actively enrolled in a valid program of study at an educational institution. Take
corrective actions to address any non-conformance by an educational institution and establish sanctions as Yes No N/A
appropriate, including termination of the relationship
No (at least minimum wage during
Wage rate the same as other workers performing equal or similar tasks intern period) unless their
Yes N/Aa
performance is significant below
expectation for that wage cycle
a
Agreed apprentice wage increase when meeting new skills requirements. Workers after a successful apprenticeship have clearly documented promotion and wage adjustment

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 A3) Working Hours

Studies of business practices clearly link worker strain to reduced productivity, increased turnover and increased injury and illness. Working hours
are not to exceed the maximum set by local law. Further, a workweek should not be more than 60 hours per week, including overtime, except in
emergency or unusual situations. Workers shall be allowed at least one day off every seven days.

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A3.1 Hours worked in a workweek over the last 12 months does not exceed 60 hours.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records:
a) Mandatory sample size of individual time records as well as
summary reports, show the number of hours worked - including
overtime - per worker per week should not exceed 60 hours
2) Waivers:
a) If a government waiver/permit or alternative working hour system
is in place then it needs to comply with the RBA Waiver Policy
(see section B.9 of the VAP OM).
b) RBA Code requires that companies comply with local law or
Code whichever is more stringent. If you have a valid and current
government waiver (e.g. Comprehensive Work Hour System in
China which allows shifting of overtime limits) this waiver is
considered “local law.” Regardless of the waiver, the 60
hours/week limit is in place.
Additional assistance:
Site Observations Record Review
Not Applicable 1) Records:
a) Three (3) months will be evaluated from the last 12 months; these
months should typically be a peak, a low, and an average month.
For each month, the following is reported:
i) Three (3) month sample
ii) Within sample, by work area
iii) Within sample, by job code
iv) Within sample, by nationality (if foreign migrant workers
present)
b) Any workers under the age of 18 must be studied separately.
c) Working hours evaluation sample should be reflect the
demographics of location, and not focused on highest hours only
d) Use the official working hour evaluation template
e) If there were multiple work hour recording systems in place
during the previous 12 months, the most recent system is to be
evaluated. A minimum of 3 months must be in place and sampled
and the sample size should be 3 times the normal sample size.
f) Unless specified otherwise by local legal requirements, this
provision does not apply to exempt workers, including those in
executive, managerial, or professional positions.
g) If 60 hours limit are exceeded, ensure this was not because of an
emergency or unusual situations. Exceptional circumstances must
be documented at the time of the emergency or unusual situation.
h) Priority audit:
i) For a 90-day Priority audit the trend since last audit must be
reviewed. For rating the month immediately preceding the
priority audit is used at 3 times normal sample rate.
ii) For a 180-day Priority audit the trend since last audit must
be reviewed. For rating the 3 months immediately preceding
the priority audit is used at normal sample rate.

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Rating: If workers under the age of 18 are found to be working in excess of the stricter of law or 60 hours per week is a Priority Non-Conformance.

% of Sample Work Weeks (Total or Specific Area or Function or Nationality)

Work Hours/Week
≤1%** >1% to ≤5% >5% to ≤15% >15% to ≤40% >40%
>84 hours/week Priority
>72 hours/week to ≤84 hours/week Conformance Minor Major Priority Priority
>60 hours/week to ≤72 hours/week Conformance Opportunity for Improvement Minor Major Priority
>Local law* to ≤60 hours/week Conformance Opportunity for Improvement Minor*** Minor*** Major
<Local law* AND ≤60 hours/week Conformance
* Local law is stricter than 60 hours/week
** No tolerance allowed if working hours are >84hours/week
*** Legal non-conformance is rated a major non-conformance except if working hours if below 60h/week but above local law for ≤40%

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A3.2 Workers receive at least one (1) day off every seven (7) days
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records:
a) Mandatory sample size of individual work records as well as
summary reports (if available) show that the maximum
consecutive days worked is equal to or less than 6 days.

Additional assistance:
Site Observations Record Review
Not Applicable 1) Records:
a) Three (3) months will be evaluated from the last 12 months; these
months should typically be a peak, a low, and an average month.
For each month, the following is reported:
i) Three (3) month sample
ii) Within sample, by work area
iii) Within sample, by job code
iv) Within sample, by nationality (if foreign migrant workers
present)
b) Any workers under the age of 18 must be studied separately.
c) Working hours evaluation sample should be reflect the
demographics of location, and not focused on highest hours only
d) Use the official working hour evaluation template
e) If there were multiple days off recording systems in place during
the previous 12 months, the most recent system is to be evaluated.
A minimum of 3 months must be in place and sampled and the
sample size should be 3 times the normal sample size.
f) Unless specified otherwise by local legal requirements, this
provision does not apply to exempt workers, including those in
executive, managerial, or professional positions.
g) If 6 consecutive days are exceeded, ensure this was not because
of an emergency or unusual situations. Exceptional circumstances
must be documented at the time of the emergency or unusual
situation.
h) Priority audit:
i) For a 90-day Priority audit the trend since last audit must be
reviewed. For rating the month immediately preceding the
priority audit is used at 3 times normal sample rate.
ii) For a 180-day Priority audit the trend since last audit must
be reviewed. For rating the 3 months immediately preceding
the priority audit is used at normal sample rate.

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Rating:

If workers under the age of 18 are found to be working consecutive days in excess of the stricter of law or 6 consecutive days is a Priority Non-Conformance unless required
for their qualification/certification under A2.4.

% of Sampled Workers (Total or Specific Area, Function or Nationality)

Consecutive Days
≤1%** >1% to ≤5% of sampled workers >5% to ≤40% >40%
≥24 Consecutive Days Priority
>12 to <24 Consecutive Days Minor Minor Major Priority
>6* to ≤12 Consecutive Days Conformance Minor Minor Major
≤6* Consecutive Days Conformance
*Or legal requirements if stricter than 6 consecutive days
** A tolerance of 1 percent of population is allowed, i.e. if no more than 1 percent of workers is detected to work more than the legal limit then this is conformance, except if the days off
are more than 12 or more days, in which case the 1 percent tolerance does not apply.

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A3.3 Adequate and effective policy and system/procedures are established to determine, communicate, record, manage and control working hours
including overtime, including reliable and detailed records of workers’ regular and overtime working hours
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy:
a) Adequate and effective working hours/days off policies and
procedures are in place to
i) Accurately determine
ii) Record
iii) Manage
iv) Control working hours including overtime and days off.
b) If non-conformance is detected, documented corrective action
should be implemented and progress against the corrective action
documented.
2) Records:
a) Review the company's time records and system for recording time
worked to determine that time is recorded accurately and
completely.
3) Recording devices:
a) Time Recording Devices are present and all are in working order.
Additional assistance:
Site Observations Record Review
1) Policy:
a) The policy and implemented process should at a minimum:
b) Ensure awareness of requirements of compliance with local and
national laws and regulations regarding working hours and days
off and RBA requirements
c) Integrate legal and RBA requirements
d) Monitor actual performance
e) Use a strategy to ensure conformance with all requirements.
2) Records:
a) Review the company's time records and system includes:
b) All workers have a time record.
c) Each time record is accurate and can be cross-referenced with
leave records, production records, maintenance, procurement or
other relevant records.
d) Regular working time and overtime recording
e) Adequate detail to allow for daily, weekly and monthly working
time and overtime analysis.
3) Unintentional errors found in records are covered here. If
intentional errors are found, then this is covered in section D3.1

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Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. No time recording devices present or time recording 1. Time records not matching other relevant Auditee
devices not accurate or not in good working order records for >1% to ≤5% of population
2. Time records do not match other relevant Auditee 2. One of the minimum requirement elements is
records (for greater than 5 percent of population) missing or ineffective, or a system element is not
3. Time records are not accurately adjusted after worker adequately documented or is prohibited
complaint
4. Two or more of the minimum requirement elements
is missing or ineffective
5. If A3.1 or A3.2 is a Priority Non-conformance then
A3.3 is a Major Non-conformance

Remote Verification Acceptable: NO

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A3.4 Workers are allowed mandated breaks, holidays and vacation days, including time off when ill or for maternity leave.
Conformance Requirements:
Site Observations Record Review
1) Workers take mandatory breaks which 1) Policy
includes at least one meal break per shift a) Adequate and effective policies and procedures for sick leave,
holidays, vacation and paternity/maternity leave are in place.
b) Workers are provided with mandated meal and rest breaks, leave
periods, holidays, and vacation days
2) Records
a) The actual leaves and holidays are recorded in leave records,
securely kept and are accurate.
b) Leave records for 12 months are consistent with those medical
certificates.
c) Payroll records for these absences show that there was no
financial penalty for maternity or sick leave.

Additional assistance:
Site Observations Record Review
1) Policy
a) Workers receive a reasonable amount of time off for sickness or
maternity without job loss or financial penalty when supported
with a medical certificate.
b) Most countries require workers to be given a 20 or 30-minute
break every two or four hours, as well as a defined meal break.
Compare the company's practices to local legal requirements.

Rating:
Priority Major Minor Not Applicable
1. Workers are not allowed time off for illness or One or more of the following is true: Holidays and mandatory breaks are provided but: Not Applicable
maternity with valid medical certificate 1. No policy in place and mandatory breaks/holidays 1. No policy is in place
are not provided or guaranteed. 2. Policy is not communicated to workers
2. Leave records are not kept or accurate.

Remote Verification Acceptable: NO

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 A4) Wages and Benefits

Compensation paid to workers shall comply with all applicable wage laws, including those relating to minimum wages, overtime hours and legally
mandated benefits. In compliance with local laws, workers shall be compensated for overtime at pay rates greater than regular hourly rates.
Deductions from wages as a disciplinary measure shall not be permitted. The basis on which workers are being paid is to be provided in a timely
manner via pay stub or similar documentation. For each pay period, workers shall be provided with a timely and understandable wage statement
that includes sufficient information to verify accurate compensation for work performed. All use of temporary, dispatch and outsourced labor will
be within the limits of the local law.

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A4.1 Wages for regular and overtime hours are correctly calculated and timely paid to all workers
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective wages and compensation policies and
procedures are in place:
b) “Pay equals time worked” applies; this means any company-
required activity
c) All workers shall be paid no less than the agreed* wage for all
regular hours.
d) overtime and other compensation and benefits are paid and are on
top of agreed* wage for regular hours
e) Payment made to leavers (resigned workers).
2) Records
a) Wages benefits, and overtime are correctly calculated and
accurate pay records are maintained for 12 months.
b) Wages are paid directly to workers (or a legally designated third
party) with no unauthorized deductions (including for disciplinary
measures) in a timely manner.
c) For recurring pay (including overtime, other) should not be
delayed more than two days after the agreed timing for payment
d) For severance pay, payment (including resigned workers) must be
made in compliance not later than one month after final day on
the job

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Additional assistance:
Site Observations Record Review
Not Applicable 1) Policy
a) Company-required activity e.g. briefings, trainings, daily
overview meetings, shall be paid equal to the time of this
mandatory attended activity.
b) A worker’s base wage shall always be set at or above minimum
wage for the classification of worker.
c) This applies to both direct and indirect workers.
d) * Agreed = the stricter of legal minimum wage, wage stipulated
in employment contract or wage set in Collective Bargaining
Agreement
e) NOTE: In case the country does not have a legal set minimum
wage, then the industry prevailing wage will apply as a standard.
The industry benchmark and reference needs to be specified under
legal references in this case.
2) Records
a) Evaluate the company's pay system and records to determine if
workers are paid at least the legal minimum wage applicable in
the country of operation or the amount specified in worker
contract.
b) Document review needs to be for at least three months (Average,
peak and low activity months) and for all workers in the statistical
sample.
c) For each of the months specify in report the minimum wage, and
the average wage for obvious worker categories.
d) Look for deductions from workers' pay that can reduce
compensation to below minimum wage.
e) Assess the impact of the production system on pay – verify that
production targets do not drag workers below the legal minimum
wage.
f) Review payroll records and look for the lowest compensation
totals to determine all mandated pay and benefits are provided.
g) Bank transfer records, or other equivalent proof of payment,
which includes date and amount due for each worker
3) Student workers/interns/apprentices must be reviewed as a separate
category
Rating:
Priority Major Minor Not Applicable
1. ≥20% of sample is paid less than agreed* wage No policy is in place AND one or more of the following 1. No policy is in place but calculations and payment Not Applicable
is true: conform to legal requirements, contract or RBA
1. Wage calculations have structural calculation error requirements
2. Percentage of sample or population paid below
agreed* wage is ≥5% and ≤20%
3. Percentage of sample or population not paid benefits
or correct overtime compensation is ≥5%

Remote Verification Acceptable: NO

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A4.2 For each pay period, workers are provided with understandable wage statements that includes sufficient information to verify accurate
compensation for work performed.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records
a) Workers are provided with payroll receipts that clearly indicate
compensation, including overtime hours and overtime
compensation levels and detail of deductions (e.g. insurance
contributions, …).

Additional assistance:
Site Observations Record Review
Not Applicable 1) Records
a) Review evidence that workers are given information relating to
wages in an understandable form.
b) Verify for statistical sample and for a minimum of three months:
i) worker signatures on pay registers
c) In most countries, the law states the requirement of the employer
to contribute a portion of worker's wages to national or private
insurance schemes. These generally consist of retirement,
unemployment, accident, medical and possibly others. These
needs to be communicated to workers and reflected on worker
wage receipts.

Rating:
Priority Major Minor Not Applicable
1. Payments have been delayed for more than 1 month One or more of the following is true: One or more of the following is true: Not Applicable
beyond regular payment cycle 1. Wages and compensation are not communicated to 1. Communication and training is provided but >5
workers in the form of pay slips, pay roll receipt or percent of the worker sample or population do not
equivalent understand how wages are calculated
2. No training or explanation of wages are provided to 2. Payments have been delayed less than one month
workers beyond normal payment cycle and for ≤5 percent of
3. Payments are delayed less than one month beyond worker sample or population
normal payment cycle and for >5 percent of worker
sample or population

Remote Verification Acceptable: YES

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A4.3 Wages are not deducted or reduced for disciplinary reasons
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policies and procedures prohibiting
disciplinary wage deductions are in place including “Pay equals
time worked”
2) Records
a) Disciplinary records, pay slips and payment records of wages or
equivalent not show any form of disciplinary wage deduction

Additional assistance:
Site Observations Record Review
1) Policy
a) “Pay equals time worked” applies, this means that if a worker is
late the impact on its wages can be no more than the time the
worker was late
2) Records
a) Evaluate for 3 months the statistical sample on Disciplinary
records, pay slips and payment records of wages or equivalent

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. Wage deductions are employed by the Auditee as a 1. Wage deductions are not employed by the Auditee Not Applicable
standard disciplinary measure however no clear policy statement on this is in
place

Remote Verification Acceptable: NO

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A4.4 Deductions or withholdings are calculated correctly and submitted to the appropriate government agency within the local law time frame
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records
a) Calculations: Records of employer contributions to worker
insurance schemes, e.g. unemployment, retirement/pension,
health/medical, life, accident, disability, ... are available on a
monthly basis that:
i) Allows for analysis by individual worker
ii) Total per contribution type.
b) Payment: Payment records for these contributions are available
for at least 12 months and payments are made timely.
c) Communication to worker: Pay slip or equivalent shows
employer and worker contributions
Additional assistance:
Site Observations Record Review
1) Records
a) Verify for at least 3 months statistical sample documents to
demonstrate regulatory deduction, payment and communication
to worker.
b) Withholdings for taxes and other government programs should be
made promptly to the applicable agency. In most countries, the
law states the requirement of the employer to contribute to
national or private insurance schemes. These generally consist of
retirement, unemployment, accident, medical and possibly others.
c) RBA DOES NOT accept a signed agreement with a worker
that allows to deduct the social insurance as conformance
option to legal social insurance compliance.
Rating:
Priority Major Minor Not Applicable
1. Payment of government or regulatory deductions One or more of the following is true: One or more of the following is true: 1. No withholdings or required contributions
have not been made or paid on time for at least 3 1. Percentage of sample or population that do not have 1. Percentage of sample or population that do not
months correct required employer and employee have correct required employer and employee
contributions paid is ≥20% (excluding new workers contributions paid is <20% (excluding new
less than 2 pay cycles with the employer). workers less than 2 pay cycles with the employer).
2. Required employer and employee contributions are 2. Required employer and employee contributions are
not paid regularly or timely paid timely but not communicated to workers.
Remote Verification Acceptable: YES

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 A5) Humane Treatment

There is to be no harsh and inhumane treatment, including any sexual harassment, sexual abuse, corporal punishment, mental or physical coercion
or verbal abuse of workers; nor is there to be the threat of any such treatment. Disciplinary policies and procedures in support of these requirements
shall be clearly defined and communicated to workers.

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A5.1 No evidence of sexual harassment or abuse, corporal punishment, mental or physical coercion, verbal abuse or intimidation exists
Conformance Requirements:
Site Observations Record Review
1) No identification of possible instances of 2) Records
inhumane treatment a) Grievance records do not show instances of inhumane treatment
b) If instances are found appropriate corrective actions are taken
immediately and documented
c) Disciplinary records do not show inhumane disciplinary measures

Additional assistance:
Site Observations Record Review
1) Inhumane treatment includes sexual harassment, sexual abuse, corporal
punishment, mental or physical coercion or verbal abuse, as well as
withdrawal of basic physical comforts provided other workers.
Rating:
Priority Major Minor Not Applicable
1. One or more case of inhumane treatment is 1. Less than two (2) inhumane treatment cases are 1. Less than two (2) inhumane treatment cases were Not Applicable
reported without action taken by Auditee reported with actions still in progress reported with actions completed but no measures
management on an ongoing basis.

Remote Verification Acceptable: NO

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A5.2 Adequate and effective policies and procedures on decent/humane working conditions and fair treatment of workers are established
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policies and procedures on human
treatment are in place
Additional assistance:
Site Observations Record Review
Not Applicable 1) Policy
a) Inhumane treatment includes sexual harassment, sexual abuse,
corporal punishment, mental or physical coercion or verbal abuse,
as well as withdrawal of basic physical comforts provided other
workers.

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No disciplinary policy/procedures 1. Disciplinary policy and disciplinary action records Not Applicable
are but incomplete

Remote Verification Acceptable: NO

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A5.3 Disciplinary actions are recorded, consistent with the procedures and reviewed by management
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Records
a) Records of all cases of disciplinary action are available for last 12
months
b) All records of disciplinary action against workers must be
verifiably communicated to them
c) Disciplinary records show disciplinary actions with signature or
confirmation of worker
Additional assistance:
Site Observations Record Review
1) Policy
a) Inhumane treatment includes sexual harassment, sexual abuse,
corporal punishment, mental or physical coercion or verbal abuse,
as well as withdrawal of basic physical comforts provided other
workers

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. Disciplinary action records are available but Not Applicable
1. Disciplinary action records are not available workers do not confirm or sign the records/actions
2. Disciplinary action records are not consistent with
company procedures

Remote Verification Acceptable: YES

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 A6) Non-Discrimination

Participants should be committed to a workforce free of harassment and unlawful discrimination. Companies shall not engage in discrimination
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 information or marital status in hiring and employment practices
such as wages, promotions, rewards, and access to training. Workers shall be provided with reasonable accommodation for religious practices. In
addition, workers or potential workers should not be subjected to medical tests or physical exams that could be used in a discriminatory way.

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A6.1 No evidence of discrimination
Conformance Requirements:
Site Observations Record Review
1) No visible instances of discrimination 1) Human resources process:
a) Application questions and testing should not exist/occur which
are not required OR are necessary to evaluate the candidate’s
fitness for the job
b) Hiring and termination records confirm the candidate's ability to
perform the job's requirements.
c) Job postings and advertisements do not discriminate.
a) Job descriptions: Written job descriptions that focus solely on
occupational qualifications, not personal characteristics are in
place.
2) Medical tests:
a) Workers or potential workers are not subjected to medical tests
that could be used in a discriminatory way.
b) Health tests, pregnancy testing, or contraception are not used as a
condition of employment.
3) Pregnancy/Maternity/Paternity:
a) All conditions regarding pregnancy and postnatal employment
protections, benefits, and pay are met
4) Personnel records:
a) Hiring records, promotion records, pay roll, general training and
disciplinary records for statistical sample are reviewed for
consistency of policy and to look for evidence of discrimination
including hiring, wages, promotions, rewards, and access to
training.

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Additional assistance:
Site Observations Record Review
1) Medical tests:
a) In some cases, local governments require health tests for foreign
workers prior to issuance of work visas.
b) No discrimination on the basis of a person’s medical status, make
any employment decisions that negatively affect the person’s
employment status unless such decision is dictated by the inherent
requirements of the job or is prudent for workplace safety.
c) No discrimination against a worker in eligibility for another
position based on the worker’s refusal to take a medical test where
there is no required medical test for such position.
2) Pregnancy/Maternity/Paternity:
a) Review for discrimination based on pregnancy tests, maternity
and paternity leaves:
i) Refuse to hire an applicant for a non-hazardous position; or
ii) Terminate a worker’s employment solely based on the
worker’s pregnancy, virginity or parental status.
3) Discrimination cases are applicable if these cases have a
documented basis, allegations are not considered as a
discrimination case.
4) Trade union member discrimination based on their trade union
status is listed in A7.4

Rating:
Priority Major Minor Risk of Non-Conformance Not Applicable
1. Management discriminates in a 1. Two or more discrimination cases are 1. One discrimination case was reported 1. Discrimination case allegations exist Not Applicable
structural way that causes significant reported with actions not taken. with actions completed but no which are open (not investigated/
harm to a protected class. preventative measures on an ongoing closed). Discrimination exists because
basis of current legal provisions in the
country of operation.

Remote Verification Acceptable: NO

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A6.2 Adequate and effective policies and procedures that ban discrimination and harassment are in place.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
b) Adequate and effective policies and procedures that ban
discrimination are established.
i) Decisions in hiring, employing (such as compensation,
promotion, access to training, …), or terminating workers
are based solely on the candidate's ability to perform the
job's requirements.
ii) Auditee periodically reviews hiring practices, compensation
records, employee evaluation and promotion documents,
training records, employee benefits policies and procedures,
and termination/disciplinary records to determine that there
is no prohibited discrimination.
Additional assistance:
Site Observations Record Review

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No non-discrimination policy 1. Non-discrimination policy in place, but does not Not Applicable
protect all RBA-protected classes
Remote Verification Acceptable: YES

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A6.3 Reasonable accommodation for religious practices is provided.
Conformance Requirements:
Site Observations Record Review
1) In countries and/or work places where a 1) Policy
significant percentage of the workers require a) Adequate and effective policies and procedures are in place to
prayer spaces to perform religious reasonably accommodate for religious practices and adjustments
observances; clean and safe prayer /religious to the work environment to allow a worker to comply with their
areas are provided. religious beliefs while at work or in the job application process.
b) A mechanism for receiving religious accommodation requests is
in place
2) Records
a) Requests are kept, reviewed and decision and reason of decision
of accommodation (or no accommodation) is provided to the
requestor in a timely manner.
3) CBA
a) Granting a religious accommodation should be evaluated against
the Collective Bargaining Agreement (CBA - if in place) and may
vary from the CBA.

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Additional assistance:
Site Observations Record Review
1) Policy
a) The procedures must reasonably accommodate group or
individual religious practice requests made to management and
may include:
i) Scheduling Changes
ii) Voluntary Substitutes and Shift Swaps
iii) Change of Job Tasks and Lateral Transfer
iv) Dress and Grooming Standards
v) Use of Employer Facilities
vi) Tests and Selection Procedures
b) Reasonable Religious Accommodation may be refused for safety
and security concerns, after seeking alternatives (including off-
site options) and/or significant impact on business operations,
operating costs or other workers.
2) CBA
a) Dialogue with worker representatives is held if there is a
difference between the religious accommodation and the CBA, if
this does not violate the privacy of the Reasonable Religious
Accommodation requestor.
3) To provide reasonable accommodation for religious practices, a
facility is expected to take reasonable measures to ensure that every
worker is not discriminated against based on established religion.
Where significant numbers of followers of a religion require special
accommodation to perform their religious obligations, the facility
should work to take extra steps to provide space, time, and
flexibility to allow these individuals to meet their religious
obligations (e.g. absent from work by taking annual paid or unpaid
leave to perform religious obligations or adjustment of work hours)

Rating:
Priority Major Minor Not Applicable
1. Reasonable Religious Accommodation requests One or more of the following is true: 1. Reasonable Religious Accommodation records Not Applicable
are refused by management without justification 1. No policy or adequate Reasonable Religious (application and responses) are not kept
Accommodation in place
2. Prayer /religious areas are provided but not safe,
clean or adequate
3. Reasonable Religious Accommodation requests are
made but not evaluated or decisions are not
communicated to requestor/workers

Remote Verification Acceptable: NO

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 A7) Freedom of Association

In conformance with local law, participants shall respect the right of all workers to form and join trade unions of their own choosing, to bargain
collectively and to engage in peaceful assembly as well as respect the right of workers to refrain from such activities. Workers and/or their
representatives shall be able to openly communicate and share ideas and concerns with management regarding working conditions and management
practices without fear of discrimination, reprisal, intimidation or harassment

GENERAL NOTES
• The reference to “trade union” throughout this guidance refers to trade unions, union, and other worker representational bodies.
• For sake of brevity, the audit guidance focuses on the right of workers to form and join trade unions of their own choosing, to bargain
collectively, and to engage in peaceful assembly. The audit guidance should also be read to encompass the rights of workers to
refrain from forming and joining trade unions, collective bargaining, and peaceful assembly.
• Neutrality statement: The auditee company is responsible for ensuring their workers can exercise their rights to organize in a climate
free of violence, pressure, fear, and threats. Auditee Company is not required to take an active role in supporting workers’ efforts to
associate or organize.

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A7.1 Workers can form or enroll in a trade union of their own free will
Conformance Requirements:
Site Observations Record Review
1) No evident presence of violence and explicit 3) Policy
threats of any kind a) Adequate and effective policies and procedures that respect that
2) No evidence present of management’s the right of workers to form or enroll in a trade union, or to refrain
control of a trade union exists from doing so, are in place
b) No interference: Policy must include that the Auditee will not
interfere with and will not finance a trade union
4) Records/minutes
a) There are no documented episodes of violence, explicit threats of
any kind or any other violations of the right to freedom of
association.
b) Trade union meeting minutes and financial records for 12 months,
if available, to determine source of funding and materials;
c) Management contributions are limited to providing meeting space
and/or meeting materials (such as note taking material);
d) Payroll records confirm that trade union employees are paid the
same as other workers in similar job functions
Additional assistance:
Site Observations Record Review
1) Policy
a) Workers can form or join a trade union (or refrain from
doing so) and are allowed to organize independently of
management. Management must not interfere in the process
by directly or indirectly conducting elections related to the
formation, recognition or governance of a trade union. The
absence of trade union does not automatically mean a non-
conformance, refer to the rating for guidance.
b) Management should not dominate or interfere with the formation
or administration of any trade union or contribute support, either
financial or human resources. Where legally required,
management will permit the democratic election of worker
representatives.

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Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. Policy/Communication on Freedom of Association Not Applicable
1. Freedom of Association is prohibited in Auditee not communicated to or not in a language
communication understood by the worker
2. No specific policy or language in general policies
that respects the right of the workers to form or
enroll in a trade union
3. Any grievance or legal finding that the Auditee
interfered with workers Freedom of Association is
not acted upon
4. Auditee controls or attempts to control a trade
union at the Auditee’s facility.
5. Evidence that Auditee provides payments or other
items of value to a trade union or the trade union’s
leadership or members.
Remote Verification Acceptable: NO

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A7.2 Legal rights of all workers to bargain collectively, or refrain from doing so, are respected
Conformance Requirements:
Site Observations Record Review
1) No evidence of refusal by management to 2) Policy
enter into negotiations upon request by the a) Adequate and effective policies and procedures on collective
trade union certified to represent workers bargaining including the recognition of the right of workers to
bargain collectively, or refrain from doing so
3) Records/meeting minutes
a) No evidence of refusal by management to enter into negotiations
upon request by the trade union
b) Auditee participates in good faith in the collective bargaining
process with the trade union certified to bargain on behalf of the
workers;
4) CBA
a) The Collective Bargaining Agreement terms and conditions are
implemented

Additional assistance:
Site Observations Record Review
1) CBA
a) If the Collective Bargaining Agreement terms and conditions
are not implemented or met please list the finding in the
appropriate provision

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: Not Applicable No CBA in place.
1. Material elements of the CBA are not upheld and
there is no evidence that management is taking action
to remediate;
2. Evidence that the CBA process is prohibited

Remote Verification Acceptable: NO

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A7.3 Participants respect the legal right of all workers to peacefully assemble as well as respect the right of workers to refrain from doing so.
Conformance Requirements:
Site Observations Record Review
1) No signs of explicit prohibition of the right 1) Policy
of peaceful assembly. a) Adequate and effective policies and procedures on peaceful
assembly are in place noting the right of workers; individually or
collectively; to express, promote, pursue, and defend their
concerns or ideas; or to refrain from doing so
2) Records/meeting minutes
a) Respects the right of workers to individually or collectively; to
express, promote, pursue, and defend their concerns or ideas as
well as respect the right of workers to refrain from doing so
b) Does not interfere with, restrain, or coerce workers in the exercise
of their right to individually or collectively; to express, promote,
pursue, and defend their concerns or ideas or to refrain from doing
so
Additional assistance:
Site Observations Record Review
1) Policy
a) May place reasonable time, place, and manner controls regarding
assembly for purposes of maintaining a healthy, safe, and
productive work environment

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. Communication about the right of workers to Not Applicable
1. Right of workers to individual or collectively raise individual or collectively raise concerns or ideas is
concerns or ideas is not recognized in policy and/or made, but not in a language understood by the
has not been upheld in practice worker
2. Right of workers to individual or collectively raise
concerns or ideas process is prohibited in Auditee
communication

Remote Verification Acceptable: NO

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A7.4 No evidence of unequal treatment between unionized or worker representatives and other workers exists
Conformance Requirements:
Site Observations Record Review
1) No evident presence of a prohibition of 1) No evidence that Auditee dismisses, disciplines, or explicitly threatens
association with a trade union workers in order to encourage or discourage workers from forming or
joining a trade union, or refraining from doing so

Additional assistance:
Site Observations Record Review
1) Payroll; promotion; training; disciplinary; hiring and termination
records do not indicate any form of discrimination between workers;
2) Management should not discriminate against workers with respect
to hiring, termination, or any other term or condition of
employment in order to encourage or discourage workers from
forming or joining a trade union, or refraining from doing so.
Differences in terms and conditions of employment between
unionized and non-union workers due to a collective bargaining
agreement negotiated between management and a duly recognized
trade union on behalf of certain workers does not constitute
discrimination.
3) Any other form of discrimination must be listed in A6.1

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One case exists where the mechanism to report and 1. No union (not unionized) or worker representative
1. Mechanism to report and resolve discrimination is resolve discrimination is ineffective
ineffective (two or more cases)
2. Differences in pay; promotion; training; discipline;
hiring and termination records encourage or
discourage workers from forming or joining a trade
union, or encourage or discourage workers to refrain
from doing so

Remote Verification Acceptable: NO

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3. B. HEALTH & SAFETY

GENERAL NOTES

• For facilities with significant EHS risks an EHS expert Auditor will be added to the audit team for an expert review of these policies, programs, and performance.
• Where monitoring, testing, audits or other assessments are required and the law, licenses or permits are silent on the frequency must not exceed three years unless
there are significant changes to the process, facility or product use
• A risk assessment must be updated if there is a Significant Change.

B1) Occupational Safety

Worker potential for exposure to safety hazards (e.g. chemical, electrical and other energy sources, fire, vehicles, and fall hazards) are to be
identified and assessed and controlled through proper design, engineering and administrative controls, preventative maintenance and safe work
procedures (including lockout/tag out), and ongoing safety training. Where hazards cannot be adequately controlled by these means, workers are
to be provided with appropriate, well-maintained, personal protective equipment and educational materials about the risks to them associated with
these hazards. Reasonable steps must also be taken to remove pregnant women/nursing mothers from working condition with high hazards, remove
or reduce any workplace health and safety risks to pregnant women and nursing mothers including those associated with their work assignments,
as well as include reasonable accommodations for nursing mothers.

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B1.1 All required permits, licenses and test reports for occupational safety is in place and a process is implemented to ensure permits and licenses
are up to date at all times
Conformance Requirements:
Site Observations Record Review
1) License related to special equipment, such as 1) Process
crane, boiler, forklift, are placed at the a) A documented process is in place to ensure permits are renewed
working area before current permits expire
2) Records
a) All required occupational safety permits and licenses are in place,
available for review and valid.
b) Occupational safety testing reports are in place, available for
review.
3) Drinking water
a) Drinking water testing reports are available for review. Water
must be tested for those contaminants assessed to be at risk for the
local region and operations.

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or
reminders/tasks/calendar appointments via an e-mail system.
2) Records
a) All occupational safety permits and licenses e.g.
i) Building occupancy permits
ii) Pressure vessel (e.g. boiler) permits
iii) Hoist permit
iv) Lift permit
b) Occupational safety testing reports e.g.
i) Industrial hygiene sampling data
ii) Drinking water sampling data
iii) Ventilation flow tests
3) Drinking water
a) Drinking water testing is not required if local water utility
company can attest water meets World Health Organization
(WHO) Guidelines for Drinking-water Quality or equivalent
standard
b) Permits and testing (e.g. drinking water testing) related to
sanitation, food and drinking water are covered under B7.1.

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Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: 1. No permits or license required. No testing reports
1. Required permits, licenses or testing reports 1. Required permits, licenses or testing reports in required.
missing place but the process to secure and renew as
2. Two or more of minimum requirement elements required is not sufficiently documented or is
are missing or ineffective. missing some components
2. One of minimum requirement elements is missing
or ineffective, or a system element is not
adequately documented or is prohibited

Remote Verification Acceptable: YES

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B1.2 Potential for worker exposure to safety hazards (e.g. chemical, electrical and other energy sources, fire, vehicles, and fall hazards) are controlled
through proper design, engineering and administrative controls and safe work procedures
Conformance Requirements:
Site Observations Record Review
1) Controls 1) Controls
a) Engineering controls are used where a) Safe works practices are established and documented where
appropriate engineering controls are not feasible or do not completely control
2) Building the hazard.
a) Buildings are structurally sound b) Confined spaces hazards are evaluated before workers are
b) Confined spaces are identified. allowed to enter
3) Chemical c) A hot work permit system is in place for welding, cutting and
a) Chemicals are adequately and brazing.
effectively d) A safety inspection is performed daily or prior to each use for all
i) Categorized industrial powered vehicles
ii) Handled e) Electrical installations and wiring are regularly inspected and
iii) Stored maintained to prevent electrical shock hazards (damaged cords
iv) Moved within the facility. and plugs, frayed wiring, missing protective barriers, ...)
b) Control f) Lockout/tag out program is in place for work on equipment where
i) Access to hazardous substances stored energy (electrical, pneumatic, mechanical, …) or
is controlled inadvertent start-up could injure workers
ii) Potential employee exposure 2) Evaluation
methods are adequate and a) Documentation of procedures includes how the program is
effective such as evaluated and implemented
iii) Segregation
iv) Secondary containment
v) Ventilation
vi) Fire protection
vii) Appropriate storage cabinets
4) Fall
a) Stairways and elevated work areas are
provided with appropriate guardrails
and handrails and elevated work
platforms are rated for load capacity
b) Aisles, stairways, and work areas are
free of tripping hazards (stored
materials, electrical cords, ...)
c) Workers are provided with appropriate
fall protection for work in elevated
work areas (roof work, high lift fork
trucks, towers, ...). Buildings are
facilitated with tie-off points to
provide workers with safe anchor
points in the event that they need to
attach a harness.

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 5) Electrical and other energy sources
a) Precautions and controls of electrical
hazards are in place such as locked
cabinets, closed panels, unobstructed
access
b) Energized parts are protected from
accidental contact by enclosures and
barriers and all protective methods are
in place and not deficient
6) Vehicle
a) In areas where powered industrial
vehicles are used, pedestrian
walkways are clearly delineated and
physically separated, where possible,
from vehicle operation areas
7) Fire
a) Combustible storage is minimized and
limited to areas with adequate fire
detection and protection.
b) Flammable and combustible materials
are properly stored to prevent the
accumulation of vapors. Ignition
hazards (e.g. smoking, electrical
sparks, open flames, ...) are eliminated
in areas where combustible and
flammable materials are stored or used
or if there is a flammable atmosphere

Additional assistance:
Site Observations Record Review
1) Hazardous chemicals are covered in C3.1

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Rating:
Priority Major Minor Not Applicable
1. Imminent risk of loss of facility, life or limb One or more of the following is true: One or more of the following is true: Not Applicable
1. One or more occupational safety hazards do not 1. Control to limit worker exposure to occupational
have control measures to limit worker exposure safety hazards in place but not regularly monitored
2. Safety concerns are not evaluated or addressed 2. One of minimum requirement elements is missing
3. Fire risks identified were not addressed (e.g. bad or ineffective, or a system element is not
wiring, housekeeping of combustible materials, adequately documented or is prohibited
overloading in electricity)
4. Two or more of minimum requirement elements
are missing or ineffective.

Remote Verification Acceptable: NO

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B1.3 Appropriate Personal Protective Equipment (PPE) is consistently and correctly used where required to control safety hazards and worker
exposure
Conformance Requirements:
Site Observations Record Review
1) PPE requirements 1) PPE process
a) PPE selection is appropriate for the a) Adequate and effective process is implemented to assess worker
given hazard safety hazards and determine appropriate PPE for specific job
b) PPE requirements should be tasks and/or areas of the facility.
communicated to employees via b) PPE requisition and renewal procedures
posted signs and worn by all affected c) Adequate and effective notification and enforcement process for
people either performing those tasks or PPE use is in place
in the areas that require PPE 2) Records
c) Workers preforming tasks that require a) PPE adequacy evaluation records
PPE do so according to PPE procedure b) PPE inventory and replacement records
requirements c) PPE inventory, and logs to have new PPE
2) PPE availability d) Job specific PPE matrix
a) PPE should be made available e) Fit test record for respiratory protection equipment
b) PPE is in good and working condition
c) PPE is appropriately stored and
accessible

Additional assistance:
Site Observations Record Review
1) PPE requirements 1) PPE process
a) Minimum PPE requirements for a) Hazards such as high noise, chemical use including open surface
entering or working in any production tank operations, heavy equipment use, awkward positions, work
area with open surface tanks of at heights, overhead hazards, etc. should all be evaluated
hazardous chemicals where there is a b) PPE notification and enforcement process could include:
risk of contact with or exposure to the i) Signs and labels
contents of the tank include respirators ii) Regular enforcement by supervisors
appropriate to the level and type of iii) Work area inspections
inhalation exposure (if necessary), 2) Records
safety shoes, long sleeves, chemically a) PPE monitoring records
resistant gloves, and eye protection b) PPE cleaning records
(e.g. a full-face shield and safety 2) PPE notification finding must be covered in B8
goggles). 3) PPE includes both Occupational Health & Safety and Industrial
2) PPE availability Hygiene PPE
a) PPE should be made available and
worn appropriately by all who work or
reside in this area for long periods of
time (longer than exposure limit value)

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Rating:
Priority Major Minor Not Applicable
1. PPE is not worn, is not available to workers, is One or more of the following is true: 1. PPE is worn in required areas, but no inspection 1. No PPE is required.
worn incorrectly, or is the wrong type of PPE AND 1. PPE is not worn program on safe/valid use of PPE
there is immediate risk to workers 2. PPE is not worn correctly in required areas or while
performing tasks that require PPE
3. PPE is not in good condition / working order,
sufficient, visible or easily accessible

Remote Verification Acceptable: NO

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B1.4 Reasonable steps are in place to remove pregnant women/nursing mothers from working conditions with high hazards, minimize any workplace health
and safety risks to pregnant women and nursing and provide reasonable accommodations for nursing mothers
Conformance Requirements:
Site Observations Record Review
1) Pregnant workers are not working in job 1) General Policy
which has a hazard to the pregnant worker a) Adequate and effective policies and procedures are in place to
and her child minimize the Health & Safety impact in pregnant woman and
2) Reasonable accommodation for nursing nursing mothers
mothers are in place 1) Risk assessment
a) Adequate and effective risk management process is in place to:
i) Initially general risk assessment the potential hazards to new
and expectant mothers (before they have reported a
pregnancy) or any Significant Change
ii) After the worker has provided notification of pregnancy a
specific to the worker risk assessment of the worker’s job
will be carried
iii) A specific to the return to worker antenatal risk assessment
will be carried out.
iv) All reasonable efforts must be made to minimize the risk
identified in each of the 3 risk assessments
1) Reasonable accommodation to nursing mothers
a) Provide reasonable break time for a worker to express breast milk
for her nursing child for one year after the child's birth each time
such worker has need to express the milk.
b) Provide a place, other than a bathroom, that is shielded from view
and free from intrusion from coworkers and the public, which
may be used by an employee to express breast milk
2) Records
a) Personnel files contain specific to worker pre- and ante-natal risk
assessment and actions taken in line with policy
b) General risk assessment for pregnant workers reports and actions
taken (if any needed) are available for review

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Additional assistance:
Site Observations Record Review
1) General Policy
a) Applies to all types of workers (direct, indirect, dispatched,
young, interns, apprentices, …)
1) Risk assessment
a) General and specific to worker risk assessment must include
assessment of:
i) Lifting/carrying heavy loads;
ii) Standing or sitting still for long lengths of time;
iii) Exposure to infectious diseases
iv) Exposure to lead;
v) Exposure to toxic chemicals;
vi) Work-related stress;
vii) Workstations and posture;
viii) Exposure to radioactive material;
ix) Threat of violence in the workplace;
x) Long working hours;
xi) Extreme heat
xii) Excessive noise
b) Ante-natal risk assessment must include:
1) Working with organic mercury;
2) Working with radioactive materials;
3) Exposure to lead
1) Reasonable accommodation to nursing mothers
a) Location does not need to be a separate dedicated area
b) Location for breastfeeding activities:
i) Not be a toilet stall or a bathroom
ii) Private;
iii) Close to the workspace
iv) Clean
v) Secure
vi) Has a water supply (e.g., a sink)
vii) Has access to hygienic storage (e.g. a closed clean
cupboard)
viii) Breaks for expressing milk (pumping breaks) are not
compensated unless paid breaks are used to express milk

Rating:
Priority Major Minor Not Applicable
1. Pregnant workers are present and working with One or more of the following is true: One or more of the following is true: 1. All male facility/operation
immediate risk to worker and child 1. No general Policy 1. A General Policy is in place but in complete
2. No risk assessment for pregnant workers and 2. A risk assessment for pregnant workers and nursing
nursing mothers (2 or more elements missing) mothers is in place and performed but incomplete
3. No reasonable accommodation provided for (not all elements evaluated or some action
nursing mothers (2 or more elements missing) incomplete)
3. No reasonable accommodation provided for
nursing mothers but does not meet all criteria
Remote Verification Acceptable: NO

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 B2) Emergency Preparedness

Potential emergency situations and events are to be identified and assessed, and their impact minimized by implementing emergency plans and
response procedures, including: emergency reporting, employee notification and evacuation procedures, worker training and drills, appropriate fire
detection and suppression equipment, clear and unobstructed egress, adequate exit facilities and recovery plans. Such plans and procedures shall
focus on minimizing harm to life, the environment and property.

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B2.1 All required permits, licenses and inspection/testing reports for fire safety response equipment (including fire suppression equipment) and
emergency preparedness are in place and a process is implemented to ensure permits and licenses are up to date at all times
Conformance Requirements:
Site Observations Record Review
1) Posting of emergency numbers/procedures 1) Process
a) A documented process is in place to ensure permits are renewed
before current permits expire
2) Records
a) All required occupational safety permits and licenses are in place,
available for review and valid.
b) Occupational safety testing reports are in place, available for
review

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or
reminders/tasks/calendar appointments via an e-mail system.
2) Records
a) All occupational safety permits and licenses e.g.
i) Fire safety and emergency preparedness
b) Occupational safety testing reports e.g.
i) Fire safety inspection data
ii) Emergency preparedness data

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One of minimum requirement elements is missing 1. No permits or license required. No testing reports
1. Required permits, licenses or testing reports or ineffective, or a system element is not required.
missing adequately documented or is prohibited
2. Two or more of minimum requirement elements
are missing or ineffective.

Remote Verification Acceptable: YES

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B2.2 Adequate and effective fire detection, alarm and suppression systems are in place.
Conformance Requirements:
Site Observations Record Review
1) Detection 1) Process
a) Automatic heat and/or smoke a) Automatic fire sprinklers (if required by law or insurance
detection as required by insurance company), portable fire extinguishers, heat and smoke detection,
company and an alarm and notification system are inspected, tested and
b) Detector devices and system are in maintained for good state of operation on a regular basis, as
function required by insurance company or common practice
2) Alarm 2) Records
a) All buildings have a manual or a) The inspection frequency for portable fire extinguishers shall not
automatic fire alarm and notification be less than monthly. The inspection frequency for single unit
system smoke detectors shall not be less than semi-annually.
b) Fire alarm control system is free of b) Inspection for all other fire safety equipment, testing and
trouble/supervisory signals maintenance frequency shall not be less than that
(trouble/supervisory signals are required/recommended by the manufacturer, local code or
usually indicated by orange LED insurance company whichever is more stringent
lights). c) The inspection, testing and maintenance procedure, frequency
c) Fire alarm manual call-points or pull- and results are documented
stations are provided at or along egress
routes to exits
3) Fire suppression
a) Portable fire extinguishers are installed
b) Fire extinguisher inspection tags
c) automatic fire sprinklers as required by
insurance company
d) Fire hose inspection tag,
e) Fire water tank and water pressure are
normal
Additional assistance:
Site Observations Record Review
1) Fire suppression 1) If an insurance inspection has occurred within the last 12 months, ask
a) Normally open sprinkler control to see a copy. Any issues/concerns noted in the insurance inspection
valves are locked in full open position. report have an agreed corrective action plan. The agreed corrective
Fire pumps are set to run action plan is on track. Or if off-track additional measures have been
automatically. Large ducts or objects identified to bring it back on track.
do not obstruct sprinkler heads. Fire
extinguishers are in their designated
locations, fully charged and free of
signs of tampering and have evidence
(tags) that indicate they have been
inspected.
b) Asbestos-containing fire-suppression
materials—for example, blankets—are
prohibited.

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Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Not Applicable
1. No firefighting equipment 1. Firefighting equipment AND automatic detection 1. Systems are in place and inspection, testing and
2. No sprinkler or automatic detection system (if system AND alarm or notification systems are in maintenance procedures are documented and
required) place but not inspected, tested and maintained as implemented but the results are not recorded
3. No alarm or notification system is in place required by minimum requirements. 2. Isolated case of any single component (e.g. fire
4. Firefighting equipment AND automatic detection 2. Firefighting equipment AND automatic detection extinguisher, detector, …) of the system is not
system AND alarm or notification systems are in system AND alarm or notification systems are in functional however does not represent a systemic
place but ≥10% is not functional place but <10% is not functional failure.
3. Two or more of minimum requirement elements 3. One of minimum requirement elements is missing or
are missing or ineffective ineffective, or a system element is not adequately
documented or is prohibited

Remote Verification Acceptable: NO

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B2.3 All potential emergencies that could affect the site are identified and assessed, and adequate and effective emergency preparedness and response
programs (plans/procedures) are established.
Conformance Requirements:
Site Observations Record Review
1) Signage 1) Risk assessment
a) Adequate and effective signage is a) Adequate and effective risk assessment process is in place
observed with emergency number(s), considering
emergency team and emergency plot, i) Harm to life
evacuation, and response plan. ii) The environment
b) Maps are posted throughout the iii) Property
facility which clearly identify exit b) The risk assessment is current (updated when there is a Significant
routes and muster points in the correct Change or at least every 3 years)
orientation 2) Business continuity and resumption
2) Muster points a) Business continuity and resumption procedures are available,
a) Muster points have been established in current and adequate
safe locations to enable employee 3) Emergency response
accountability during an emergency. a) Documented current emergency response plans (ERP) are in
3) Emergency response kits place and available for review reflecting the risk assessment,
a) Emergency response kits are easily including notification of outside emergency services.
located and accessible near muster b) A post-emergency plan is in place which includes incident
points reporting, root cause investigation, and corrective/preventative
actions.
4) Records
a) Records are available for review:
i) Risk assessment
ii) Business continuity and resumption
iii) Emergency response
iv) CAPs resulting of post emergency evaluation (if applicable)
Additional assistance:
Site Observations Record Review
1) Muster points 1) Current = reflecting the actual situation of the facility/operation
a) Muster points will be both inside 2) Risk assessment
(tornado/extreme weather shelter-in- a) Risk assessment minimum elements:
place) and outside (fire, chemical i) Fire
release) ii) Chemical spill (if large quantity or especially hazardous
chemicals are used)
iii) Earthquake (if in earthquake zone)
iv) Severe weather (rain, flood, typhoon, frost, snow, or other
conditions as appropriate to the facility location, ...).
v) Work place violence
vi) Strike
3) Emergency response
a) ERP minimum elements
i) Specific roles
ii) Available for review upon request by employees.

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Rating:
Priority Major Minor Not Applicable
1. No risk assessment One or more of the following is true: One or more of the following is true: Not Applicable
1. No emergency response plan (ERP) in place 1. Risk assessment and ERP up to date and complete
2. No business continuity and resumption plan in place but no reporting procedure
3. ERP is in place but not covering all minimum 2. One of minimum requirement elements is missing
requirements or missing items identified as or ineffective, or a system element is not
significant / major risk in risk assessment adequately documented or is prohibited
4. Risk assessment, business continuity and resumption
or ERP are not current
5. Workers unaware of ERP
6. Lack of procedure for notification to outside
emergency services
7. Two or more of minimum requirement elements are
missing or ineffective

Remote Verification Acceptable: NO

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B2.4 Effective emergency exit access, exits, and exit discharge are adequate in number and location, readily accessible, and properly maintained
Conformance Requirements:
Site Observations Record Review
1) Clear and unobstructed egress (i.e. Exit access, 1) Process
exit and exit discharge) a) Adequate and effective process in place to ensure effective
a) An adequate number of effective exit emergency exit aces, exits and exit discharge with unobstructed
routes from every area egress in in place
b) Exit routes are separated by an 2) Records
appropriate distance and do not share a a) Inspection records for emergency support facilities (emergency
common exit. lighting, emergency exit signs, evacuation paths, exit
c) Exit routes are clear of obstructions enclosures, ...) are maintained and show these are inspected as
d) Exit discharges discharge to open per insurance requirements, or local practice whichever is
space/parking lot, and do NOT discharge stricter.
to an enclosed/gated/locked area
e) Exits are free of material storage; and
enclosures are not used for any other
purpose except for egress
f) All exit route doors (i.e. exit access
doors, exit discharge doors) which serve
high occupancy (>50) or hazardous
areas, open outward.
g) All exit route doors (i.e. exit access doors
and exit discharge doors) should open
without using a key, badge, code, special
knowledge, or effort.
h) All exit discharge doors must have listed
panic hardware installed or must be able
to be pushed open in a single motion.
2) Exit signs:
a) Exit signs are provided to mark exits on
every floor
b) Exit signs are illuminated and/or lighted
in the event of a power failure
c) Additional exit and/or directional signs
are provided at main passageways/aisles,
long corridors and at other locations
where the way to the nearest exit is not
clear.
3) Emergency lighting:
a) Emergency lighting provided and
installed to illuminate means of egress in
the event of a power failure.
b) Lighting shall provide adequate,
functional emergency lighting in stairs,
aisles, corridors, ramps, and
passageways leading to exits, and in
other areas as required by applicable
laws.
c) Either battery or backup generator may
power emergency lighting.

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 Site Observations Record Review
4) Separation:
a) Penetrations are limited to sprinkler
pipes, standpipes, and electrical
services, pipe and duct installation
serving the enclosures
b) Openings into the enclosures are
protected by fire rated doors or
window
c) Fire doors are in good condition, self-
closing or automatic closing (upon fire
alarm or detection of smoke)
d) Integrity of exit enclosures is
maintained

Additional assistance:
Site Observations Record Review
1) Non-conforming situations for exit route
doors (i.e. exit access doors and exit
discharge doors) include:
a) Multiple steps required to open doors
b) Anything requiring a tight grasp
c) Rolling doors that open vertically
2) Auditor must follow at least three
randomly selected egress routes out of the
building to the assembly/muster point

Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Not Applicable
1. No emergency support facilities present or in good 1. One (1) emergency exit blocked or lacking easy 1. All emergency support facilities are appropriate, in
operating condition throughout Auditee’s facility means of egress as defined in Minimum good condition and inspected, however inspection
2. Two (2) or more emergency exits are blocked or Requirements (i.e. require key, badge, code, records are not maintained or are incomplete.
lacking easy means of egress as defined in multiple steps or tight grasp or rolling doors) or exit 2. One of minimum requirement elements is missing
Minimum Requirements (i.e. require key, badge, discharge lacking approved panic hardware, or are or ineffective, or a system element is not
code, multiple steps or tight grasp or rolling doors) exit discharge doors which open inward when not adequately documented or is prohibited
or lack approved panic hardware permitted...
2. Emergency support facilities are generally in
working condition, however, there is at least one
missing component or exception.
3. Emergency support facilities not inspected.
4. Two or more of minimum requirement elements
are missing or ineffective

Remote Verification Acceptable: NO unless a Minor with only gaps in records or

documentation

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B2.5 Adequate and effective fire and other identified emergency situations and evacuation drills are conducted with all employees, and records are
maintained.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) ERP drill plan
a) Adequate and effective emergency evacuation drill program
i) Fire
ii) Other emergencies
2) Effectiveness evaluation
a) The effectiveness of each drill should be evaluated and
documented
b) A Corrective action plan for any deficiencies identified
3) Records
a) Records are available for the last 3 years
i) ERP drill plan
ii) ERP drill evaluation reports
iii) ERP drill CAPs

Additional assistance:
Site Observations Record Review
1) ERP drill plan
a) ERP drill plan must include at minimum
i) Annual evacuation drill for fire
ii) All workers
iii) Every area (including dormitory, cafeteria, warehouse,
office areas, productions floors, research and development
laboratories, shipping/receiving)
iv) All work shifts
v) One drill that is conducted at night; while it is dark outside)
vi) Appropriate frequency (other than fire emergency
situations) (frequency determined through the facility risk-
assessment see B2.3)
2) Effectiveness evaluation
a) Effectiveness evaluation includes
i) Time of the drill
ii) Time required to clear the building or otherwise respond to
the emergency
iii) Any deficiencies identified during the drill
2) Records
a) Records for last 3 years, including CAP and their status are
available for review and spot-checked to ensure corrections are
being made and implemented

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Rating:
Priority Major Minor Not Applicable
1. No emergency evacuation drill held in last 2 or One or more of the following is true: One or more of the following is true: Not Applicable
more years 1. No emergency evacuation drill held in last year or 1. Corrective actions from last drilled are off track or
drill was held but not for all areas and all shifts and not being tracked
at least one drill at night while it was dark outside. 2. One of minimum requirement elements is missing
2. Drill was held for all areas and all shifts however or ineffective, or a system element is not
post-drill evaluation was not done adequately documented or is prohibited
3. Drill was held for all areas and all shifts and post-
drill evaluation was done but corresponding
corrective actions were not determined or
documented
4. Two or more of minimum requirement elements
are missing or ineffective

Remote Verification Acceptable: YES

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B2.6 Designated emergency response personnel are provided adequate and effective PPE and training on an annual basis
Conformance Requirements:
Site Observations Record Review
1) Emergency response PPE is available, 1) ERT assignment
adequate and in good and working a) An emergency response team (ERT) is formed at each facility that
condition. shall be available during all working shifts
2) Emergency response PPE storage is clearly b) The ERT shall have the obligation and authority to direct the
marked, visible and easily accessible. Auditee’s response to emergencies to ensure the protection of
3) Badges, different colored attire/hard-hat, worker health and safety, the environment, and property
and office/cubicle signage may identify 2) ERT qualifications
emergency response team personnel a) ERT members have the required qualifications
3) ERT training
a) Emergency responders are trained on an annual basis.
b) Training will be dependent on responsibilities during an
emergency
c) Training material and training records are available for review
and up to date
Additional assistance:
Site Observations Record Review
1) ERT members = workers involved in the control, cleanup and disposal
of hazardous materials or other emergency response procedures (e.g.
firefighting)
2) It is expected that the facility will have a designated Emergency
Response Team (ERT), and this team will have the appropriate PPE for
their emergency response duties defined in A2.3 (Emergency
response). In some cases, an ERT might not exist, the justification must
be available and valid.

Rating:
Priority Major Minor Not Applicable
One or more of the following is true: 1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing 1. No ERT
1. PPE for ERT is not available are missing or ineffective or ineffective
2. PPE for ERT is not in good condition / working
order, sufficient, visible or easily accessible
3. No ERT in place

Remote Verification Acceptable: YES

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 B3) Occupational Injury and Illness

Procedures and systems are to be in place to prevent, manage, track and report occupational injury and illness, including provisions to: a) encourage
worker reporting; b) classify and record injury and illness cases; c) provide necessary medical treatment; d) investigate cases and implement
corrective actions to eliminate their causes; and e) facilitate return of workers to work.

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B3.1 All required permits, programs, licenses, and testing reports for occupational injury and illness are in place and a process is implemented to
ensure permits and licenses are up to date at all times
Conformance Requirements:
Site Observations Record Review
1) Required postings are current and located in 1) Process
public view. Some signage and information a) A documented process is in place to ensure permits are renewed
may be required to be posted in employee before current permits expire
common/break/cafeteria locations. 2) Records
a) All required occupational injury and illness permits and licenses
are in place, available for review and valid.
b) occupational injury and illness testing reports are in place,
available for review
c) Government certifications, permits, inspections, approval for the
onsite medical treatment facility is available for review
3) Medical professional certificates
a) Valid certificates for occupational health are available for review
(e.g. first responders ... where required).
b) If nurses or doctors are employed or doctor/nurse services are
used, a copy of their certificate/license is available for review
Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or
reminders/tasks/calendar appointments via an e-mail system.
1) Records
a) All occupational safety permits and licenses e.g.
i) Occupational health professional licenses
b) Occupational safety testing reports e.g.
i) Injury logs
ii) Respiratory protection (fit tests, medical evaluations)
iii) Hearing conservation programs
iv) Notice of availability of medical records

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One of minimum requirement elements is missing 1. No permits, programs, license or testing reports
1. Required permits, programs, licenses or testing or ineffective required. No testing reports required.
reports missing
2. Two or more of minimum requirement elements
are missing or ineffective

Remote Verification Acceptable: YES

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B3.2 Investigations to determine root cause(s) and implement corrective/preventive actions for work-related injuries/illness in the past three years
are performed and documented, communicated to affected employees, and tracked to closure.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Reporting
a) A system for workers to report health and safety incidents and
near-misses, as well as a system to investigate, track, and
manage such reports.
b) All reportable and non-reportable accidents are tracked;
documented, and investigated to minimize the potential for
future occurrence.
c) Occupational Injury and illness data for last 3 years are available
for review including surveillance data
2) Analysis
a) All accidents are investigated and analyzed for corrective and
preventive actions
b) Trend analysis of the occupational Injury and illness data is
performed on a regular basis, at least annually and corrective
actions are identified
3) Preventive Action
a) Corrective and preventive actions following accident
investigation or trend analysis were implemented (or are on
track) and verified as effective
b) If a worker has abnormal medical surveillance results or is
injured immediate appropriate preventive action will be taken
Additional assistance:
Site Observations Record Review
1) Surveillance data= pre-job, on-the-job, post-job, and post-emergency
medical data
2) Review number and type of first aid events, number and type of injuries
beyond first aid, and any fatalities.
3) Appropriate preventive action as a result of medical surveillance or
injury:
a) Worker shall be removed from the current job immediately and
offered another position in the facility.
b) Auditee is prohibited from terminating the labor contract with the
worker due to the medical surveillance results.
c) Auditee shall provide medical treatment to the worker.
d) Auditee shall provide re-examination to the worker.
e) Auditee shall cover the medical treatment, re-examination, and
rehabilitation cost for the worker.

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Rating:
Priority Major Minor Not Applicable
1. Reportable occupational accidents, injuries and One or more of the following is true: One or more of the following is true: 1. No injuries, accidents or illnesses in the past 3
illnesses are not reported to the governing agency as 1. No accidents, injury and illness are tracked or 1. Accidents, injuries, illnesses tracked, analyzed and years.
required by law incomplete records for last 3 years. prevented but no formal procedure
2. Accidents are tracked but no analysis, investigation 2. Corrective actions are off track
or corrective actions. 3. One of minimum requirement elements is missing or
3. Two or more of minimum requirement elements are ineffective
missing or ineffective

Remote Verification Acceptable: YES

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B3.3 An effective first aid process and adequate number of first responders are available to provide initial medical treatment for injured or ill workers
is in place
Conformance Requirements:
Site Observations Record Review
1) First Aid responders are easily identifiable 1) Policy
by badges, colored attire, office/work area a) Adequate and effective first response policies and procedures are
signage in place indicating severity of medical emergency and response
2) If applicable, an occupational medical clinic (first aid, infirmary, local external hospital).
is adequately staffed and supplied to respond 2) First Responders
to injuries a) The facility assigns a team of trained/certified first responders.
3) If the medical clinic is not open or operated 3) In-house infirmary or clinic:
24 hours per day, alternative resources such a) An operations log of onsite emergency occupational medical
as outside medical services are clinic is available and up to date (access might be restricted due
communicated to employees to privacy laws).
b) Documented procedures and supplies for the onsite occupational
medical clinic are available and adequate.
Additional assistance:
Site Observations Record Review
1) Policy
a) Injured workers are then sent to off-site medical facilities for
further treatment.
2) First Responders
a) It is possible that the role of trained/certified first responders is
performed by onsite medical professional team
3) If first responders do not have adequate training then list the
finding in B8 or B2.6 if they are part of the ERT.

Rating:
Priority Major Minor Not Applicable
1. No medical emergency personnel or procedures One or more of the following is true: 1. Availability of first responders is <10%. Not Applicable
1. First aid, occupational medical clinic or first
response procedures are inadequate
2. Occupational medical clinic has inadequate
supplies, staffing or access
3. Percentage of first responders is ≤10% of workers

Remote Verification Acceptable: YES

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B3.4 Adequate first response equipment and first aid kits to provide medical treatment for injured or ill workers are available to employees in
designated areas. The kits have adequate supplies and are inspected on a monthly basis.
Conformance Requirements:
Site Observations Record Review
1) First Aid kits 1) Maintenance procedure
a) Appropriate and completely stocked a) Adequate and effective maintenance procedure is in place for
placed /assigned first aid kits are inspection, maintenance, upkeep and stocking of all first response
available in designated locations. equipment and first aid kits
b) First aid kits are unlocked or if locked, b) Frequency is at least monthly for all inspections
first responder can access the key at all 2) Records
times. a) First aid kits have inventory list
2) First Response Equipment b) Inspection tracking records are available and up to date.
a) Appropriate and well maintained first
response equipment is available in
designated locations.
Additional assistance:
Site Observations Record Review
1. First response equipment = e.g. fire blanket, eye wash, emergency
shower, …

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. First aid kits are inadequate 1. First aid kits are adequate and stocked but contents
2. First response equipment is inadequate list missing
3. No stated process for access to First Aid kits during 2. First response equipment is adequate but inspection
all times of operation log is missing
4. Inspection schedule is not followed 3. First Aid kits inspection tracking records missing

Remote Verification Acceptable: YES

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 B4) Industrial Hygiene

Worker exposure to chemical, biological and physical agents is to be identified, evaluated, and controlled according to the hierarchy of controls.
Potential hazards are to be eliminated or controlled through proper design, engineering and administrative controls. When hazards cannot be
adequately controlled by such means, workers are to be provided with and use appropriate, well-maintained, personal protective equipment.
Protective programs shall include educational materials about the risks associated with these hazards.

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B4.1 All required permits, licenses and testing reports for potential Industrial hygiene exposures are in place and a process is implemented to ensure
permits and licenses are up to date at all times
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) A documented process is in place to ensure permits are renewed
before current permits expire
2) Records
a) All required industrial hygiene permits and licenses are in place,
available for review and valid.
b) Industrial hygiene testing reports are in place, available for review
c) Industrial hygiene sampling records for the past three years,
including sampling performed by government agencies as part of
a regulatory inspection are available for review.
Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or
reminders/tasks/calendar appointments via an e-mail system.
1) Records
a) All industrial hygiene permits and licenses e.g.
i) Use permits
b) Industrial hygiene testing reports e.g.
i) Industrial hygiene monitoring logs

Rating:
Priority Major Minor Not Applicable
1. No health risk evaluation process has been One or more of the following is true: 1. One of minimum requirement elements is missing 1. No permits or license required. No testing reports
implemented. 1. Required permits, licenses or testing reports or ineffective required.
missing
2. Two or more of minimum requirement elements
are missing or ineffective

Remote Verification Acceptable: YES

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B4.2 Appropriate controls according to the hierarchy of controls for worker exposures to chemical, biological and physical agents are implemented.
Potential hazards are eliminated or controlled through proper design, engineering and administrative controls.
Conformance Requirements
Site Observations Record Review
1) Adequate controls to reduce or eliminate 1) Risk assessment
worker exposure to chemical, biological and a) Adequate and effective risk assessment with associated industrial
physical agents are in place and effective hygiene sampling and testing, is in place to identify and assess the
including: potential hazards of chemical, biological, or physical agents.
a) Proper design (elimination and/or b) The risk assessment is updated when a Significant Change occurs
substitution) c) Risk assessment must include exposure to multiple chemicals
b) Engineering controls d) A health risk assessment with associated industrial hygiene
c) Administrative controls sampling and testing, is completed when a new chemical,
d) Adequate and effective PPE biological, or physical agent is introduced into the work
2) During normal working hour, workplace is environment, or when an existing process is changed that may
free from obvious odor, visible fume, dust, trigger an employee health risk.
and other conditions leading to potential 2) Control program
unhealthy feelings a) Adequate and effective documented program to control the
identified potential hazards to chemical, biological, or physical
agents is place and follows the hierarchy of controls
b) Regular evaluation plan to verify the effectiveness to
implemented controls and corrective actions if required. The
frequency should at least every 3 years unless a major change
requires re-evaluation
3) Records
a) Medical surveillance records are available for review pertaining
to respiratory evaluations to determine if worker is being harmed
from exposure to agents, or determining hearing loss or any other
medical concerns related to specific job activities.
Additional assistance:
Site Observations Record Review
1) Engineering controls = e.g. exhaust 1) Risk assessment
ventilation, enclosures, ... a) Hierarchy of hazard control is a system used in industry to
2) Administrative controls = limiting worker minimize or eliminate exposure to hazards. These are from most
exposure time; job rotation, … effective to least effective: 1. Elimination, 2. Substitution, 3.
3) If obvious odor, visible fume, dust, and Engineering controls, 4. Administrative controls, 5. PPE
other conditions leading to potential b) Exposure to multiple chemicals: is an exposure to multiple
unhealthy feelings exist, auditor should chemicals by a single route and exposure to multiple chemicals
perform detail interview and inspections. by multiple routes. A route can inhalation, ingestion, skin
exposure, …
c) Significant Change can be the introduction, elimination or
change of 1 chemical
2) Records
a) Surveillance records are not limited to respiratory, but various
exposures, such as skin contact, hearing loss, radiation, ….
3) A PPE finding is noted in B1.3

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Rating:
Priority Major Minor Not Applicable
One or more of the following is true: One or more of the following is true: One or more of the following is true: Not applicable
1. No risk assessment or control measures are in place 1. Potential hazards have been identified and risk 1. Potential hazards are controlled and minimized but
2. Potential hazards are evident assessment program is in place but controls are documentation and records are incomplete or does
inadequate. not follow the hierarchy of controls
2. Two or more of minimum requirement elements 2. No consideration of combined exposure to multiple
are missing or ineffective chemical

Remote Verification Acceptable: NO

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 B5) Physically Demanding Work

Worker exposure to the hazards of physically demanding tasks, including manual material handling and heavy or repetitive lifting, prolonged
standing and highly repetitive or forceful assembly tasks is to be identified, evaluated and controlled.

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B5.1 Worker exposure to the hazards of physically demanding work is identified, assessed, communicated and controlled effectively
Conformance Requirements:
Site Observations Record Review
1) Adequate controls to reduce or eliminate 1) Risk assessment
physical demanding work are in place and a) Adequate and effective risk assessment is in place to identify and
effective including: assess the potential hazards of physical demanding work.
a) Proper design b) The risk assessment is updated when a Significant Change occurs
b) Engineering controls 2) Control program
c) Administrative controls a) Adequate and effective documented program to control the
identified potential hazards of physical demanding work is place
and follows the hierarchy of controls
b) Program encourages and respond to early reporting of discomfort.

Additional assistance:
Site Observations Record Review
1) Physical demanding work=e.g. Heavy or 1) Control program
repetitive lifting, prolonged standing, ... a) A review and trend analysis of past 3 years of injuries related to
2) Engineering controls=e.g. Palletizers, lift physical demands of job duties.
tables, adjustable work platforms, … b) If there are no changes to the facility or work set up, there is no
3) Administrative controls=e.g. limiting need to re-assess (this “no-change” should be documented).
worker exposure time; job rotation, … c) Periodic ergonomic task analyses

Rating:
Priority Major Minor Not Applicable
1. No risk assessment or control measures are in place 1. Physically demanding work has been identified and 1. Physically demanding work is controlled and No physically demanding work
AND high frequency of physically demanding risk assessment program is in place but controls are minimized AND physically demanding work
work is evident inadequate monitoring program is adequate but documentation
is incomplete
Remote Verification Acceptable: NO

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 B6) Machine Safeguarding

Production and other machinery shall be evaluated for safety hazards. Physical guards, interlocks and barriers are to be provided and properly
maintained where machinery presents an injury hazard to workers.

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B6.1 All required permits, licenses and testing reports for machinery are in place and a process is implemented to ensure permits and licenses are up
to date at all times
Conformance Requirements:
Site Observations Record Review
1) Required postings are current and located in 1) Process
public view. a) A documented process is in place to ensure permits are renewed
before current permits expire
2) Records
a) All required machine safety permits and licenses are in place,
available for review and valid.
b) machine safety testing reports are in place, available for review
Additional assistance:
Site Observations Record Review
1) Some signage and information may be 1) Machine = any equipment with at least one moving part. Machines in
required to be posted in employee scope are machine operated by workers to perform their main task.
common/break/cafeteria locations Machine which are part of building or utilities (elevators, lifts, hoists,
boilers, compressors) fall under B1.
2) Process
a) A documented process e.g. a compliance calendar or
reminders/tasks/calendar appointments via an e-mail system.
3) Records
a) All machine (safety) permits and licenses e.g.
i) Machine permits
b) Machine (safety) testing reports e.g.
i) Machine testing logs

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One of minimum requirement elements is missing 1. No permits or license required. No testing reports
1. Required permits, licenses or testing reports or ineffective, or a system element is not required.
missing adequately documented or is prohibited
2. Two or more of minimum requirement elements
are missing or ineffective

Remote Verification Acceptable: YES

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B6.2 An adequate and effective machine-safeguarding program is implemented, and workers operate machinery safely
Conformance Requirements:
Site Observations Record Review
1) Emergency stops 1) Machine risk assessment
a) All machines have adequate a) Adequate and effective documented machine risk assessment
emergency stops process is in place including:
2) Safeguards b) Machine risk assessment program provides a method to identify
a) All machines have adequate machine safeguarding needs (pre-purchase/pre-installation
safeguards hazard review of all machinery.)
3) Operation 2) Control program
a) All workers operate machine safely. a) Appropriate method is used to ensure that safeguarding is
installed as needed to control the identified hazards,
b) Regular inspection and preventive maintenance of machine and
its safeguards and emergency stops.
3) Work instructions
a) Work instructions (if necessary or required) are available in a
language understood by the worker at machine (or within
proximity).
b) Safe machine operation documentation is in place and available.

Additional assistance:
Site Observations Record Review
1) Machine safeguards=e.g. machine pinch 1) Control program
points, points-of-operation, rotating shafts, a) Records demonstrating regular inspection and preventive
flywheels, chain drives, motor-driven maintenance of machine are available for review (3years)
movement, …

Rating:
Priority Major Minor Not Applicable
1. Worker operates machine unsafely with immediate 1. Worker operates machine unsafely without 1. Workers operate machines safely but work 1. No physical machine hazards
risk of life or limb immediate risk of life or limb instructions are incomplete
2. Machine safe guarding program is in place but
incomplete
Remote Verification Acceptable: YES, if minor, otherwise NO.

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 B7) Food, Sanitation and Housing

Workers are to be provided with ready access to clean toilet facilities, potable water and sanitary food preparation, storage, and eating facilities.
Worker dormitories provided by the Auditee or a labor agent are to be maintained clean and safe, and provided with appropriate emergency egress,
hot water for bathing and showering, and adequate lighting, heat and ventilation, individually secured accommodations for storing personal and
valuable items, and reasonable personal space along with reasonable entry and exit privileges.

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B7.1 All required health & safety licenses, permits, registrations and certificates related to food, sanitation and housing are in place and an adequate
and effective process is established to ensure permits and licenses are up-to-date at all times
Conformance Requirements:
Site Observations Record Review
1) Valid hygiene permit is placed on site (if 1) Process
applicable) a) A documented process is in place to ensure permits are renewed
before current permits expire
2) Records
a) All required food, sanitation and housing permits and licenses are
in place, available for review.
b) Food, sanitation and housing testing reports are in place, available
for review.

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or
reminders/tasks/calendar appointments via an e-mail system.
2) Records
a) Rented apartments must be permitted by the local government
b) food, sanitation and housing permits and licenses e.g.
i) Canteen/kitchen workers have valid health certificates.
c) food, sanitation and housing testing reports e.g.
i) Drinking water
ii) Food worker health tests
iii) Food sample testing
d) If local regulations require facility health inspections or other tests
or certificates, these are available and valid.
3) Drinking water
a) Water must be tested for those contaminants assessed to be at
risk for the local region and operations. Drinking water testing is
not required if local water utility company can attest water meets
World Health Organization (WHO) Guidelines for Drinking-
water Quality or equivalent standard
b) If drinking water is not a separate system or no additional
contamination can take place (e.g. filters, …) then report
only in B1.1

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Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One of minimum requirement elements is missing All of the following is true:
1. Required permits, licenses or testing reports are or ineffective, or a system element is not 1. No permits or license required
missing adequately documented or is prohibited 2. No testing reports required
2. Canteen/kitchen worker certificates are missing or 3. There is no dormitory, restaurant/canteen at the
expired facility.
3. Two or more of minimum requirement elements
are missing or ineffective

Remote Verification Acceptable: YES

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B7.2 Dormitories, bathrooms, employee spaces are clean, safe and well-maintained and meet international housing standards
Conformance Requirements:
Site Observations Record Review
1) Environment 1) Procedures
a) Dormitory and sanitary facilities a) Adequate and effective cleaning and sanitation program is in
(common areas, hallways, rest rooms, place.
…) are clean and properly b) Adequate and effective pest control program is in place
maintained. c) Adequate and effective preventive maintenance program
b) Clear, well-lit stairwells to allow for (including emergency response supporting facilities) is in place
safe exit from dormitories d) For rented apartments, performs a risk assessment and updates if
c) Building is heated in the winter (if there is a Significant Change, on-site inspections and emergency
applicable). procedures
d) Windows provide light and 2) Records
ventilation. a) Sanitation program tracking records are available for review and
e) Adequate lighting up to date.
f) Safe and sufficient electricity sockets b) Pest control log is available for review and up to date.
are provided. c) Preventive maintenance program logs available for review and
g) Sufficient space is available for each up to date.
worker
h) Individually secured storage
accommodations
2) Structure and lay-out
a) All facilities are separated by gender
and adequate in number.
b) Lodging and cooking facilities are
separate
c) Adequate domestic waste disposal
facilities
d) Adequate pest control
3) Emergency response
a) Adequate fire and heat detection,
alarm and notification and fire
suppression systems are in place
b) Adequate number of exit routes from
each floor.
c) Exit route doors accessible, well-
marked and unlocked from the inside
d) Adequate number of first kits are
available

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Additional assistance:
Site Observations Record Review
1) Adequate lighting = lighting is adequate for
reading, writing and other off-work
activities
2) individually secured storage
accommodations = storage for personal and
valuable items protected from unauthorized
access and accessible to the workers at any
time
3) Exit route doors unlocked from the inside =
doors may be locked from the outside only
if panic hardware, such as crash bars, are
used
4) The dormitory requirements shall apply
regardless of the nature of contract /
location / building (for example if rooms
are rented by the facility in nearby
residential areas for housing employees,
these standards will still apply

Rating:
Priority Major Minor Not Applicable
1. Dormitory/rented apartments is/are unsafe with One or more of the following is true: One or more of the following is true: 1. No worker housing.
immediate risk of loss of facility, life or limb 1. Dormitory and sanitary facilities are unclean or do 1. Dormitory and sanitary facility are safe, clean and
not minimum requirements (except adequate but procedures or records are missing or
documentation) incomplete.
2. Rented apartments are unsafe 2. Rented apartments are safe, clean and adequate but
3. Rented apartments did not have a risk assessment on-site inspections are irregular
or inspection
4. No emergency drills in rented apartments
Remote Verification Acceptable: NO

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B7.3 Canteens (cafeterias) are clean, well maintained, and well managed
Conformance Requirements:
Site Observations Record Review
1) Environment 1. Procedures
a) Canteen, kitchen and food preparation 1) Safe food handling procedures and hygiene standards (in
areas are clean and well maintained. refrigeration, storage, and preparation areas) are in place and
b) Exits must be adequate for the followed.
number of workers served. 2) Adequate and effective cleaning and sanitation program is in
c) Canteens are provided with adequate place.
hand washing facilities. 3) Adequate and effective pest control program is in place
d) Adequate pest control 4) Adequate and effective preventive maintenance program
2) Food workers (including emergency response supporting facilities) is in place
a) Food service workers wear masks, 5) Records
hairnets and gloves as necessary to a) Regular monitoring and reporting of safe food handling
prevent food contamination. procedures/hygiene
3) Emergency response b) Sanitation program tracking records are available for
a) Adequate fire and heat detection, review and up to date.
alarm and notification and fire c) Pest control log is available for review and up to date.
suppression systems are in place d) Preventive maintenance program logs available for review
b) Adequate number of exit routes from and up to date.
each floor.
c) Exit route doors accessible, well-
marked and unlocked from the inside
d) Maximum occupancy number is
posted on site
e) Adequate number of first kits are
available
4) Food storage:
a) Food storage and preparation areas
are clean
b) Food is stored properly (not on the
floor; refrigerated if necessary)
c) Raw and cooked food stored
separately, food kept covered, ...
d) Food is used or disposed of before the
marked expiration date
Additional assistance:
Site Observations Record Review

Rating:
Priority Major Minor Not Applicable
1. Canteen and kitchen is unsafe with immediate risk One or more of the following is true: 1. One of minimum requirement elements is missing 1. No cafeteria or food services.
of loss of facility, life or serious injury 1. Canteen and kitchen are unclean or ineffective, or a system element is not
2. Canteen and kitchen do not meet minimum adequately documented or is prohibited
requirements on canteen/cafeteria standards
3. Two or more of minimum requirement elements
are missing or ineffective
Remote Verification Acceptable: NO

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 B8) Health and Safety Communication

Participant shall provide workers with appropriate workplace health and safety information and training in the language of the worker or in a
language the worker can understand for all identified workplace hazards that workers are exposed to, including but not limited to mechanical,
electrical, chemical, fire, and physical hazards. Health and safety related information shall be clearly posted in the facility or placed in a location
identifiable and accessible by workers. Training is provided to all workers prior to the beginning of work and regularly thereafter. Workers shall
be encouraged to raise safety concerns.

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B8.1 Workers are provided with appropriate clearly posted workplace health and safety information and training in the language of the worker or in a
language the worker can understand for all identified workplace hazards that workers are exposed to. Workers shall be encouraged to raise safety concerns
Conformance Requirements:
Site Observations Record Review
1) Health and Safety communication clearly 1) Language
posted in the facility or placed in a location a) All communications and training must be in a language
identifiable and accessible by workers understood by the worker
2) Appropriate signs, placards and labels 2) Training:
identifying hazards (chemical, physical, a) Adequate and effective training program is in place following
biological, vehicular, …) good training program practice
3) A mechanism to raise safety concerns is b) Training program has minimum requirements (mechanical,
clearly visible electrical, chemical, fire, and physical hazards) training and
training identified in the training needs assessment but must
include
i) The correct use of appropriate PPE
ii) Types of potential emergencies that may occur at their work
location and what to do during an emergency, including
Internal and external muster points.
iii) Machine safety and the use of safeguards and emergency
stops.
iv) Reporting injuries and illnesses
v) Hazardous atmospheres and confined space work
procedures prior to entry of confined spaces
vi) Lock out-tag out procedures
c) Training is provided to all workers prior to the beginning of work
and regularly thereafter as per the training program.
d) Workers responsible for storage, clean up or disposal of chemical
releases should receive specialized training.
e) Occupational health professionals and first responders are trained
by external agencies or trained and certified by internal qualified
occupational health professionals such as medical doctor where
permitted by local law
3) Communication:
a) Adequate and effective communication program to
workers/employees is in place for all identified
b) Potential workplace hazards that workers are exposed to clearly
posted in the facility or placed in a location identifiable and
accessible by workers
c) Hazard communication procedure: all hazards present at the site
and action promoting of an H&S work place.
d) Internal and external muster points are communicated to all
employees and visitors

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 Site Observations Record Review
4) Safety concern notification
a) Adequate and effective program to receive, review and respond
to safety concerns reported. (e.g. incentive systems, ….).
b) Workers shall be encouraged to raise safety concerns
5) Evaluation
a) The training, communication and safety concern notification
programs must be evaluated on a regular basis not exceeding 3
years or sooner if there is a major change
6) Records
a) Training records include a verification of training effectiveness
b) Safety concern logs, evaluation records and action plans
c) Communication records, logs and materials
d) Training, communication and safety concern notification
evaluation reports and corrective action if required
e) Educational materials (e.g. safe work instruction, operating
instruction, …) about the risks associated with the hazards for
their positions are provided to workers to ensure safe execution
of the function. Examples of controls include personal protective
equipment (safety glasses, gloves, and ear plugs), operating
procedures (lock-out/tag-out, chemical mixing), and engineering
controls (ventilation, point of operation machine guarding,
building sprinkler systems).

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Additional assistance:
Site Observations Record Review
1) Good training program practice
a) H&S training needs analysis is conducted and is documented
b) A training matrix has been developed following the training needs
analysis (including but not limited to mechanical, electrical,
chemical, fire, and physical hazards)
c) A training plan is in place, building on the training matrix
d) A training program with materials and training records is in place,
adequate and up to date.
e) Training program is up to date and maintained through a
compliance calendar, work-order systems, and computer-based e-
mail/calendar system.
f) Refresher training schedules are established and implemented as
per schedule
2) Communication:
a) Updates should be made whenever new operations, chemicals,
machines or process are added in the facility or change
significantly
3) Records
a) Verification of training effectiveness=e.g. demonstrate that
workers have understood training and aims of training are
achieved (through a post training test, or worker interviews on the
training)

4) ERT member training must be reported in B2.6

Rating:
Priority Major Minor Not Applicable
1. No training and/or communication program in 1. Training and communications program in place but 1. Training and communications program in place but Not Applicable
place major hazards or program components missing communications are not updated in accordance
2. No training provided on one or more of the with developed schedule or training
minimum elements: chemicals, hazardous records/verification incomplete
substances (including waste), PPE, emergency
evacuation, machinery safety, reporting injuries
3. Two or more of minimum requirement elements
are missing or ineffective
4. No system in place to raise safety concerns
5. First responder training does not meet minimum
requirements in content or number

Remote Verification Acceptable: NO

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4. C. ENVIRONMENT
Participants recognize that environmental responsibility is integral to producing world class products. In manufacturing operations, adverse effects on
the community, environment and natural resources are to be minimized while safeguarding the health and safety of the public. Recognized management
systems such as ISO 14001 and the Eco Management and Audit System (EMAS) were used as references in preparing the Code and may be a useful
source of additional information.

GENERAL NOTES

• A risk assessment must be updated if there is a Significant Change.

• For facilities with significant EHS risks an EHS expert Auditor will be added to the audit team for an expert review of these policies, programs, and
performance.
• Where monitoring, testing, audits or other assessments are required and the law, licenses or permits are silent on the frequency must not exceed three years
unless there are significant changes to the process, facility or product use

C1) Environmental Permits and Reporting

All required environmental permits (e.g. discharge monitoring), approvals and registrations are to be obtained, maintained and kept current and
their operational and reporting requirements are to be followed.

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C1.1 The facility has obtained all required environmental permits, approvals, licenses and registrations
Conformance Requirements:
Site Observations Record Review
1) Any unidentified impacts to: 1) Process
a) Air emissions a) A documented process is in place to ensure permits, approvals,
b) Wastewater discharge registrations or licenses are renewed before current permits,
c) Storm water exposure approvals, registrations or licenses expire
d) Hazardous materials storage and use 2) Records
e) Generation of waste (solid and a) All required environmental permits, approvals, registrations and
hazardous) licenses are in place, available for review and valid.

Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or
reminders/tasks/calendar appointments via an e-mail system.
b) Any alteration that may change the status of registration and
permitted hazardous-waste generation to the appropriate local
and national regulatory agencies
2) Records
a) Environmental permits, approvals registrations and licenses e.g.
i) Operating permit
ii) Air emissions
iii) Wastewater discharge
iv) Storm water exposure
v) Hazardous materials storage and use
vi) Generation of waste (solid and hazardous)
b) Current copies of all hazardous waste vendor licenses and/or
approvals are on file.
Rating:
Priority Major Minor Not Applicable
Not applicable One or more of the following is true: 1. One of minimum requirement elements is missing 1. No permits, approvals, registrations or license
1. Required permits, licenses or testing reports or ineffective, or a system element is not required.
missing adequately documented or is prohibited
2. Two or more of minimum requirement elements
are missing or ineffective

Remote Verification Acceptable: YES

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C1.2 Reporting to environmental authorities as required by law is performed timely.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) A documented process is in place to ensure reports are submitted
before or on due date is in place
2) Records
a) Environmental testing reports are in place, available for review
and meeting the conditions of permits or licenses
Additional assistance:
Site Observations Record Review
1) Process
a) A documented process e.g. a compliance calendar or
reminders/tasks/calendar appointments via an e-mail system.
2) Records
a) Environmental testing reports e.g.
i) Air emissions
ii) Water emissions
iii) Waste
iv) Hazardous waste

Rating:
Priority Major Minor Not Applicable
1. Mandatory government reporting is late for more 1. Required reports missing, incomplete AND no One or more of the following is true: 1. No environmental reporting required
than 3 months process in place to ensure legally required reports 2. Required reports submitted but no process in place
are submitted in a timely manner to ensure legally required reports are submitted in
a timely manner
3. Required reports submitted in a timely manner but
incomplete

Remote Verification Acceptable: YES

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 C2) Pollution Prevention and Resource Reduction

Emissions and discharges of pollutants and generation of waste are to be minimized or eliminated at the source or by practices such as adding
pollution control equipment; modifying production, maintenance and facility processes; or by other means. The use of natural resources, including
water fossil fuels, minerals and virgin forest products is to be conserved by practices such as modifying production, maintenance and facility
processes, materials substitution, re-use, conservation, recycling or other means.

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C2.1 Adequate and effective programs, including objectives and targets, to identify, manage, minimize or eliminate at the source emissions and
discharges of pollutants and generation of waste and conserve the use of natural resources
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective programs to identify, manage, minimize
or eliminate at the source emissions and discharges of pollutants,
generation of waste and conserve the use of natural resources
including:
i) Materiality assessment: identify significant environmental
aspects and establish programs for monitoring and control
of these aspects.
ii) Clear annual objectives and targets are set for each
identified material emission source, waste including
hazardous waste and natural resource used demonstrating
annual progress not entailing excessive cost
(1) Reduce resource consumption
(2) Reduce waste and pollution generation
(3) Capture or reuse materials that would otherwise enter
waste streams
2) Records
a) Materiality assessment (updated when changes in machinery,
process or materials used or facility)
b) Data for each material emission and discharge of pollutants, waste
and natural resource
Additional assistance:
Site Observations Record Review
1) Elimination or minimization e.g. by practices such as adding pollution
control equipment; modifying production, maintenance and facility
processes; or by other means.
2) Natural resources = e.g. Water fossil fuels, minerals and virgin forest
products
3) Conservation of the use of natural resources e.g. By practices such as
modifying production, maintenance and facility processes, materials
substitution, re-use, conservation, recycling or other means.
4) Reduction programs are implemented where they don't present
increased worker harm or excessive cost
5) The goal of this provision is to confirm that a facility has done a
materiality assessment and understands its materials resource use and
environmental impacts and has set clear annual objectives to reduce this
impact.
6) The implementation of the programs to meet these reduction objectives
are covered in the individual environmental media provisions C3, C4,
C5, C7 and C8.

Rating:
Priority Major Minor Not Applicable

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 1. Reduction programs cause potential worker harm One or more of the following is true: One or more of the following is true: Not Applicable
1. No assessment of resource use and waste generation 1. Assessment of resource use and waste generation is
has been completed incomplete
2. No selection processes for all new hazardous 2. Selection processes for all new hazardous chemicals
chemicals is incomplete
3. No reduction objectives set 3. Reduction objectives set but incomplete for a
4. Two or more of minimum requirement elements are material component
missing or ineffective 4. One of minimum requirement elements are missing
or ineffective
Remote Verification Acceptable: YES

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 C3) Hazardous Substances

Chemical and other materials posing a hazard to humans or to the environment are to be identified, labelled and managed to ensure their safe
handling, movement, storage, use, recycling or reuse and disposal.

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C3.1 Hazardous substances including wastes are properly categorized, labeled, handled, stored, transported and disposed using government-approved
and/or licensed vendors.
Conformance Requirements:
Site Observations Record Review
1) Management 1) Policy
a) Hazardous substances are adequately a) Adequate and effective procedures are in place for
and effectively i) Reception
i) Categorized ii) Storage
ii) Handled iii) Dispensing
iii) Stored iv) Use
iv) Moved within the facility. b) Adequate and effective process to track, review, and approve the
2) Control use of all hazardous chemicals and shall obtain approvals for all
a) Access to hazardous substances is new purchases of hazardous chemicals prior to use.
controlled c) Selection processes for all new hazardous chemicals include a
b) Potential employee exposure methods thorough evaluation of less hazardous or non-hazardous
are adequate and effective such as alternatives.
i) Segregation 2) Hazard information (Environmental)
ii) Secondary containment a) Hazardous material information [labels and safety data sheet
iii) Ventilation (SDS formally MSDS)] or characterization in the case of
iv) Fire protection hazardous waste) is available at the points of use and storage in a
v) Appropriate storage cabinets language understood by the worker.
3) Hazard information 3) Records
a) Hazard signage and information a) Accurate chemical inventory records are maintained and available
[labels and safety data sheet (SDS for review.
formally MSDS) or characterization in b) Inspection records of hazardous substances and their points of
the case of hazardous waste) storage and use are maintained and available for review.
c) Copies of hazardous substances inventory, manifests and
shipping papers are maintained and available for review.
d) Documents only vendors approved and/or licensed by the local
regulatory authorities for transporting are used.

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Additional assistance:
Site Observations Record Review
1) Engineering and administrative systems 1) Records
intended to improve resource efficiency are a) Copies of hazardous substances inventory, manifests and
in good repair or operating at high capacity. receiving shipping papers e.g. may be related to:
2) Engineering and administrative systems for i) Air emissions;
improved resource efficiency adhere to the ii) Process wastewater storage;
hierarchy of resource efficiency when iii) Hazardous materials storage and use; and
feasible, showing preference (in order) for iv) Hazardous waste storage
the following functions: 2) Hazard information (Health & Safety) finding should be noted in
a) Prevention: unnecessary consumptive B8
processes are eliminated
b) Minimization: Process efficiency is
improved
c) Substitution: Using a more
environmentally benign or renewable
resource
d) Reuse, recycling, recovery: In that
order, in order to maximize the benefit
of resource consumption

3) Hazard information (Health & Safety)

finding should be noted in B8

Rating:
Priority Major Minor Not Applicable
1. Hazardous substances (including wastes) are used, 1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing 1. No hazardous substances (including wastes) used
handled or stored of in a manner that could result are missing or ineffective or ineffective, or a system element is not or stored on site.
in imminent loss of facility, life or cause severe adequately documented or is prohibited
bodily damage.

Remote Verification Acceptable: YES

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C3.2 Hazardous waste is safely disposed of including a disposal Supplier(s) assessment
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective procedures are in place for the safe return
and disposal of hazardous waste.
2) Reduction program
a) An adequate and effective reduction program with
i) Annual objectives
ii) Regular objective tracking
iii) Progress monitoring
iv) Adjustments made if off track
3) Hazard information (Environmental)
a) Hazardous material information [labels and safety data sheet
(SDS formally MSDS)] or characterization in the case of
hazardous waste) is available at the points of use and storage in a
language understood by the worker.
4) Vendor assessment
a) A periodic assessment and corrective action plan process to
evaluate whether the vendor (hazardous waste handler AND
transporter) is complying with contract terms and conditions
b) Assessments should occur at least every 3 years or when there is
a significant change
c) The assessment must occur before a new vendor (hazardous waste
handler AND transporter) is selected
5) Records
a) Documents that only vendors approved and/or licensed by the
local regulatory authorities for transporting and disposing of
hazardous waste are used
b) Assessments, visit minutes or Audit reports, with possible areas
for improvement are available for review.
c) Copies of hazardous waste shipping papers
d) Annual reduction targets, progress monitoring and corrective
actions plans if applicable

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Additional assistance:
Site Observations Record Review
1) Assessment
a) If corrective or improvement actions are identified, then
implementation is monitored and actions are completed or on
track.
b) If corrective actions are off track then additional actions are
identified to ensure corrective actions are completed by due date.
2) Objective setting finding is listed in C2.1
3) Auditor guidance: Reporting on this question will include the detail
of the current targets and current progress against the targets

Rating:
Priority Major Minor Not Applicable
1. Environmental emissions are evident that could One or more of the following is true: 1. One of minimum requirement elements is missing 1. No hazardous chemical waste generated or stored
cause imminent negative impact on the community 1. No control programs in place and there is a risk of or ineffective, or a system element is not on site.
(toxic air and water emissions, untreated waste environmental emissions adequately documented
water release, chemicals spill on hazardous 2. No baseline to reduce environmental impacts
substances released outside the facility, ...) 3. No hazardous waste vendor assessment
4. Two or more of minimum requirement elements
are missing or ineffective
Remote Verification Acceptable: YES

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 C4) Solid Waste

Participant shall implement a systematic approach to identify, manage, reduce and responsibly dispose of or recycle solid waste (non-hazardous).

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C4.1 Solid waste is managed and responsibly disposed of
Conformance Requirements:
Site Observations Record Review
1) Management 1) Policy
a) Waste is adequately and effectively a) Adequate and effective procedures are in place for
i) Categorized i) Storage
ii) Handled ii) Handling
iii) Stored iii) Transportation
iv) Transported within the facility. iv) Disposal.
2) Control b) Adequate and effective process to track, review, and approve the
a) Access to waste is controlled disposal of all waste
b) Potential employee exposure methods 2) Reduction program
are adequate and effective such as a) An adequate and effective reduction program with
i) Segregation i) Annual objectives
ii) Secondary containment ii) Regular objective tracking
iii) Ventilation iii) Progress monitoring
iv) Fire protection iv) Adjustments made if off track
3) Hazard information 3) Hazard information (Environmental)
a) Hazard signage and information and a) Material information [labels and safety data sheet (SDS formally
waste characterization and response MSDS)] or characterization in the case of waste) is available at
information the points of use and storage in a language understood by the
4) Reduction programs are visible within the worker.
facility. 4) Records
a) Accurate waste inventory records are maintained and available
for review.
b) Inspection records of waste and their points of storage are
maintained and available for review.
c) Copies of waste manifests and shipping papers are maintained and
available for review.
d) Documents only vendors approved and/or licensed by the local
regulatory authorities for transporting are used.
e) Annual reduction targets, progress monitoring and corrective
actions plans if applicable

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Additional assistance:
Site Observations Record Review
1) Engineering and administrative systems 1) Objective setting finding is listed in C2.1
intended to improve resource efficiency are 2) Hazard information (Health & Safety) finding should be noted in
in good repair or operating at high capacity. B8
2) Engineering and administrative systems for 3) Auditor guidance: Reporting on this question will include the detail
improved resource efficiency adhere to the of the current targets and current progress against the targets
hierarchy of resource efficiency when
feasible, showing preference (in order) for
the following functions:
a) Prevention: unnecessary consumptive
processes are eliminated
b) Minimization: Process efficiency is
improved
c) Substitution: Using a more
environmentally benign or renewable
resource
d) Reuse, recycling, recovery: In that
order, in order to maximize the benefit
of resource consumption

Rating:
Priority Major Minor Not Applicable
1. Environmental emissions are evident that could One or more of the following is true: 1. One of minimum requirement elements is missing 1. No solid waste generated or stored on site.
cause imminent negative impact on the community 1. No control programs in place and there is a risk of or ineffective, or a system element is not
(toxic air and water emissions, untreated waste environmental emissions adequately documented
water release, chemicals spill on hazardous 2. No baseline to reduce environmental impacts
substances released outside the facility, ...) 3. Two or more of minimum requirement elements
are missing or ineffective
Remote Verification Acceptable: YES

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 C5) Air Emissions

Air emissions of volatile organic chemicals, aerosols, corrosives, particulates, ozone depleting chemicals and combustion by-products generated
from operations are to be characterized, routinely monitored, controlled and treated as required prior to discharge. Participant shall conduct routine
monitoring of the performance of its air emission control systems.

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C5.1 Air emissions are routinely monitored and air emission control systems are routinely monitored for performance.
Conformance Requirements:
Site Observations Record Review
1) Equipment 1) Policy
a) Equipment for air emission treatment a) Adequate and effective procedures are in place for air emissions
is well maintained and appropriate and i) Treatment
identified ii) Discharge
2) Treatment b) Adequate and effective process to track, review, and approve the
a) Air emission are treated prior to discharge of all air emissions
discharge in accordance with permit c) Emergency response actions are defined in case the on-site air
requirement emissions treatment system malfunctions
3) Reduction programs are visible within the 2) Reduction program
facility. a) An adequate and effective reduction program with
i) Annual objectives
ii) Regular objective tracking
iii) Progress monitoring
iv) Adjustments made if off track
3) Equipment
a) Appropriate process air emission treatment systems are installed
and maintained that minimize the pollutant contribution of each
of its facilities include:
i) A routine preventive maintenance program
ii) System efficiency monitoring program
iii) A program to evaluate the integrity of existing process air
emission systems
4) Personnel:
a) A specific individual or individuals within the facility
organization who will be responsible for all aspects of process air
emission treatment
5) Records
a) Inspection records of air emission and their points of discharge
are maintained and available for review.
b) Testing and reporting records are maintained and available for
review
c) Revise the inventory after any changes to the production or
process that are likely to affect air emissions

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Additional assistance:
Site Observations Record Review
1) Engineering and administrative systems 1) Equipment:
intended to improve resource efficiency are a) A program to evaluate the integrity of existing process air
in good repair or operating at high capacity. emission treatment systems:
2) Engineering and administrative systems for i) Regularly test of the air emission system
improved resource efficiency adhere to the ii) Correct any identified deficiencies immediately
hierarchy of resource efficiency when 2) Personnel
feasible, showing preference (in order) for a) Waste water treatment responsibilities include:
the following functions: i) Maintenance
a) Prevention: unnecessary consumptive ii) Inspection of air emission treatment equipment
processes are eliminated iii) Monitoring of air emissions
b) Minimization: Process efficiency is iv) Responding to emergencies
improved 3) Auditor guidance: Reporting on this question will include the detail
c) Substitution: Using a more of the current targets and current progress against the targets
environmentally benign or renewable
resource
d) Reuse, recycling, recovery: In that
order, in order to maximize the benefit
of resource consumption

Rating:
Priority Major Minor Not Applicable
1. Environmental emissions are evident that could One or more of the following is true: 1. One of minimum requirement elements is missing 1. No air emissions - site does not have requirements
cause imminent negative impact on the community 1. Air emissions are not complying with discharge or ineffective for air emissions.
(toxic air and water emissions, untreated waste water requirement
release, chemicals spill on hazardous substances 2. Workers responsible for operating and maintaining
released outside the facility, ...) air emission treatment systems are untrained
3. Monitoring is not carried out on a regular basis
4. No baseline to reduce environmental impacts
5. Two or more of minimum requirement elements
are missing or ineffective

Remote Verification Acceptable: YES

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C5.2 Environmental noise levels are within regulatory limits
Conformance Requirements:
Site Observations Record Review
1) No excessive boundary noise 1) Policy
a) Adequate and effective procedures are in place for environmental
noise control including boundary noise sources are
i) Identified
ii) Evaluated
iii) Routinely monitored
iv) Controlled
b) Adequate and effective process to track and review environmental
noise
2) Equipment
a) Appropriate boundary-noise-control devices are installed and
maintained to control boundary noise levels include:
i) A routine preventive maintenance program
ii) System efficiency monitoring program
iii) A program to evaluate the integrity of existing boundary-
noise-control devices
3) Personnel:
a) A specific individual or individuals within the facility
organization who will be responsible for all aspects of
environmental noise control
4) Records
a) Testing and reporting records are maintained and available for
review
Additional assistance:
Site Observations Record Review
1) Boundary noise levels are evaluated per the permit conditions, upon
changes to “Receiving Land Use Category” in the neighborhood of the
facility, or if there are any community noise complaints and boundary
noise–level criteria are set accordingly.
2) Personnel
a) Environmental noise control responsibilities include:
i) Maintenance
ii) Inspection of boundary-noise-control devices
iii) Monitoring of boundary noise
iv) Responding to emergencies

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing 1. Site does not have requirements on environmental
are missing or ineffective or ineffective, or a system element is not noise
adequately documented or is prohibited

Remote Verification Acceptable: YES

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 C6) Materials Restrictions

Participants are to adhere to all applicable laws, regulations and customer requirements regarding prohibition or restriction of specific substances
in products and manufacturing, including labeling for recycling and disposal.

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C6.1 Adequate and effective program is in place for Materials Restrictions as a formal part of the procurement and manufacturing processes
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective procedures to measure and/or document
the chemical composition of products including:
i) A documented review process for comparing customer
requirements to own specifications
ii) A documented process to ensure materials, packaging and
components procured are in conformance with customer
requirements
iii) Documented requirements for conformance with the
Material Restrictions required to its material /parts
Suppliers
b) Statements and/or certificates of conformance and analytical data
to its customers upon request ae provided
2) Records
a) Chemical composition of products are on record
b) specifications, statements and/or certificates of conformance from
its Suppliers
c) Monitoring & reporting records from the past 3 years are available
and ready for review

Additional assistance:
Site Observations Record Review
1) Policy
a) A documented process to ensure materials, packaging and
components procured are in conformance with customer
requirements
i) Regular audits and assessments of the procedures are
performed to verify conformance.
ii) A formal process is in place to address discovery of non-
compliant materials or components and corrective actions
are tracked, implemented.
iii) Additional actions taken to ensure completion at due date if
corrective actions are not on track.
iv) Analytical data from material/parts Suppliers is
requested/required

Rating:
Priority Major Minor Not Applicable
1. No program is in place AND product has been One or more of the following is true: 1. One of minimum requirement elements is missing 1. Site is not subject to any requirements or customer
subject to regulatory action 1. No program is in place or ineffective, or a system element is not demands on this topic.
2. Two or more of minimum requirement elements adequately documented or is prohibited
are missing or ineffective

Remote Verification Acceptable: YES

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 C7) Water Management

Participant shall implement a water management program that documents, characterizes, and monitors water sources, use and discharge; seeks
opportunities to conserve water; and controls channels of contamination. All wastewater is to be characterized, monitored, controlled, and treated
as required prior to discharge or disposal. Participant shall conduct routine monitoring of the performance of its wastewater treatment and
containment systems to ensure optimal performance and regulatory compliance.

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C7.1 Adequate and effective procedures are in place to document, characterize, and monitor water sources, water discharge and control channels of
contamination
Conformance Requirements:
Site Observations Record Review
1) Water withdrawal 1) Water withdrawal
a) Water withdrawal and discharge points a) The source of water is clear
don't appear to heavily impact local b) A baseline of water use and adequate and effective annual
waterbodies (e.g. strongly colored reduction plan is implemented with objectives and corrective
discharge, acrid smell, floating debris). action plans if the implementation is off track.
2) Water discharge c) Annual reduction program should not harm workers or entail
a) Equipment excessive cost.
i) Equipment such as tanks, piping, 2) Water discharge
and storage vessels are a) Policy
compatible with the waste i) Adequate and effective procedures are in place for waste
materials being stored and water
transported. (1) Storage
b) Treatment (2) Treatment
i) Industrial and/or sanitary (3) Discharge
wastewater is treated in b) Adequate and effective process to track, review, and approve the
accordance with permit discharge of all waste water
requirements. c) Emergency response actions are defined in case the on-site waste
ii) Wastewater treatment system is water treatment system exceeds its capacity or if it malfunctions
in operation and appears based d) Hazard information
on visual inspection to be i) Waste water characterization and response information is
operating effectively. available at the points of use and storage in a language
c) Discharge understood by the worker.
i) Wastewater is discharged to a e) Equipment
municipal treatment system or to i) Appropriate process wastewater treatment systems are
surface water installed and maintained that minimize the pollutant
3) Reduction programs are visible within the contribution of each of its facilities include:
facility. (1) A routine preventive maintenance program
4) Control of internal water channel (2) System efficiency monitoring program
contamination (3) A program to evaluate the integrity of existing process
a) Internal water channels wastewater collection systems
i) Water channels look free of 3) Control of internal water channel contamination
contamination a) Adequate and effective procedures to control internal water
ii) Water channels are protected channel contamination including:
from contamination (e.g. b) Potential contamination sources to water channels are identified
Absence of pools of standing c) Adequate and effective emergency response plan to control water
water and grease/oil slicks near channel contamination
storm drains.) d) Appropriate emergency response equipment inspection and
b) Emergency response maintenance process
i) Appropriate emergency response e) Investigation of past spills/water channel contamination and
equipment / materials are in corrective/preventive action plan
place to respond to a possible
water channel contamination

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 4) Personnel
a) At least one responsible for all aspects of process wastewater
discharge including treatment, water channel contamination
prevention and water-related emergency response and reporting
activities
2) Records
a) Identified water channel contamination sources
b) Description of spills/water channel contamination for past 3 years
c) Preventive/corrective action plan for past spills/contamination
d) Additional actions taken to ensure completion at due date if
corrective actions are not on track.
e) Accurate waste water inventory records are maintained and
available for review.
f) Inspection records of wastewater and their points of storage are
maintained and available for review.
g) Copies of waste water manifests and shipping/discharge papers
are maintained and available for review.
h) Documents only vendors approved and/or licensed by the local
regulatory authorities for transporting are used.
i) Annual reduction targets, progress monitoring and corrective
actions plans if applicable

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Additional assistance:
Site Observations Record Review
1) Engineering and administrative systems 1) Water withdrawal
intended to improve resource efficiency are a) Source of water = on-site (e.g. Surface withdrawal, aquifer via
in good repair or operating at high capacity. well) or off-site via municipal or private company service
2) Engineering and administrative systems for b) Good practice is to understand where the municipal or private
improved resource efficiency adhere to the company service withdraws its water
hierarchy of resource efficiency when c) Good practice: A water risk assessment that considers
feasible, showing preference (in order) for competitive use, water quality, and scarcity has been conducted
the following functions: in the last 3 years for the facility's location using reference tools
a) Prevention: unnecessary consumptive such as:
processes are eliminated i) WWF Water Risk Filter,
b) Minimization: Process efficiency is ii) WRI Aquaduct,
improved iii) WBCSD Global Water Tool
c) Substitution: Using a more iv) The Water Footprint Assessment Tool
environmentally benign or renewable v) GEMI Local Water Tool
resource 2) Water discharge
d) Reuse, recycling, recovery: In that a) Equipment:
order, in order to maximize the benefit i) A program to evaluate the integrity of existing process
of resource consumption wastewater collection systems:
b) Regularly test of the process wastewater system
c) Correct any identified deficiencies immediately
3) Personnel
a) Waste water treatment responsibilities include:
i) Maintenance
ii) Inspection of Wastewater Treatment Plant (WWTP)
iii) Monitoring of waste water discharge
iv) Responding to emergencies
4) Objective setting finding is listed in C2.1
5) Hazard information (Health & Safety) finding should be noted in
B8
6) Auditor guidance: Reporting on this question will include the detail
of the current targets and current progress against the targets

Rating:
Priority Major Minor Not Applicable
1. Environmental emissions are evident that could One or more of the following is true: 1. One of minimum requirement elements is missing Not Applicable
cause imminent negative impact on the community 1. Person responsible for water is untrained. or ineffective
(toxic air and water emissions, untreated waste 2. No control programs in place and there is a risk of
water release, chemicals spill on hazardous environmental emissions
substances released outside the facility, ...) 3. No baseline to reduce environmental impacts
4. Two or more of minimum requirement elements
are missing or ineffective

Remote Verification Acceptable: NO

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 C8) Energy Consumption and Greenhouse Gas Emissions

Energy consumption and all relevant Scopes 1 and 2 greenhouse gas emissions are to be tracked and documented, at the facility and/or corporate
level. Participants are to look for cost-effective methods to improve energy efficiency and to minimize their energy consumption and greenhouse
gas emissions.

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C8.1 Energy consumption and all relevant Scopes 1 and 2 Greenhouse gas (GHG) emissions are tracked and documented
Conformance Requirements:
Site Observations Record Review
1) Greenhouse Gas emissions 1) Energy consumption
a) There is no significant energy a) The sources of electricity and other energy are clear
consumption or GHG emissions at the b) A baseline of energy use (by source)
facility that are not tracked and c) Energy use has been reported to the corporate HQ (if applicable)
documented or customers at the customers’ request
2) Greenhouse Gas emissions
a) Emissions statement includes value of Scope 1 and 2 emissions,
with a description of its boundary and source (e.g. emissions,
purchased electricity, ...)
b) GHG emissions has been reported to the corporate HQ (if
applicable) or customers at the customers’ request
3) Records
a) Records should be available showing facility data submitted as
contribution to corporate-level energy consumption and GHG
emissions or at the customers’ request
b) Annual consumption/use of all Scopes 1 and 2 GHG emission
sources are tracked and documented

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Additional assistance:
Site Observations Record Review
1) On-site combustion (incinerators, diesel 1) Definitions
generators, burning of waste on-site), a) GHG = greenhouse gases such as carbon dioxide, methane, water
purchased electricity (un-metered electricity vapor, and nitrous oxide but also include the chlorofluorocarbons
consumption at the facility), significant (cfcs), hydrofluorocarbons (hfcs) and Perfluorocarbons (pfcs), as
leakage of refrigerants (from HVAC units or well as sulfur hexafluoride (SF6)
other refrigeration equipment), or other b) Scope 1 GHG emissions are all direct GHG emissions
GHG-generating production processes (cfcs c) Scope 2 GHG emissions are all indirect GHG emissions from
and hfcs from solvents and foams, for consumption of purchased electricity, heat or steam. This does
example). not include transportation, waste generated in operations, travel,
commuting, use or end of life product treatment (Scope 3 GHG
emissions)
2) Records
a) Documentation on GHG emissions
i) On-site combustion: oil, coal, diesel, natural gas, propane,
garbage, ….
ii) Copies of records of total quantity of fuel combusted on-site
over the previous calendar year should be available for
review, or should be easily extrapolated from fuel bills and
other purchased fuel records.
iii) Purchased electricity
iv) Renewable energy use –If facility purchases renewable
energy through their utility company, this should be
documented as well.
b) Description of boundary defined for reporting (such as: financial
control, operational control, or equity share)
c) Description of how energy consumption and other GHG sources
are converted into GHG emissions using internationally accepted
GHG protocol
3) Auditor guidance: Reporting on this question will include the detail
of the current targets and current progress against the targets

Rating:
Priority Major Minor Not Applicable
Not applicable 1. Energy and fuel consumption data is not tracked, or 1. Facility and company have energy and fuel 1. Facility does not directly pay for fuel or electricity
significantly incomplete AND no Scopes 1 and 2 consumption data but do not calculate their GHG (energy consumption is paid for and managed by
GHG emissions data is available for the facility or emissions building owner, and not reported to company). For
company. example, if company is tenant in fully serviced
leased building, it is expected that company will at
least make a good faith effort to obtain this data, or
effectively estimate for the purposes of GHG
reporting.
Remote Verification Acceptable: YES, unless significant energy consumption or GHG
emissions that are not documented are discovered on-
site.

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C8.2 Cost-effective methods to improve energy efficiency and to minimize their energy consumption and all relevant Scopes 1 and 2 greenhouse gas
(GHG) emissions are implemented.
Conformance Requirements:
Site Observations Record Review
1) Technology or management strategies to 1) Reduction program
minimize energy consumption and GHG a) An adequate and effective reduction program with
emissions are visible. i) Annual objectives
2) Reduction programs are visible within the ii) Regular objective tracking
facility. iii) Progress monitoring
iv) Adjustments made if off track
b) The programs must be structured with roles and responsibilities,
written procedures, targets, monitoring and reporting.
2) Records
a) Accurate energy and GHG emissions inventory records are
maintained and available for review.
b) Inspection records of energy and GHG emissions and their points
of use are maintained and available for review.
Additional assistance:
Site Observations Record Review
1) This could include: 1) Procedures to effectively manage energy consumption (may include a
a) Building automation technology, “start-up, shut-down” procedure for the facility, staging for boilers and
programmable thermostats, lighting chillers, ... …) if the facility is large or complex enough to warrant these
controls, or energy-efficient heating, procedures
cooling, lighting, and ventilation
technology
b) Use of on-site combustion or vehicles
that are fuel efficient, or use a less
GHG--intensive source (natural gas,
electric, cellulosic ethanol, …).
c) Purchasing or installing on-site
renewable energy
d) Use of high-efficient
collection/treatment systems to
absorb/treat cleaning agents
e) Use of refrigerants with low global
warming potential (GWP) in Heating,
Ventilation, and Air Conditioning
(HVAC) systems

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. Company has made no discernable effort to 1. Company has made some investments or plans to 1. Company does not pay for fuel or energy consumed
identify opportunities to minimize energy improve energy efficiency and GHG emissions, but on-site.
consumption and GHG emissions. has not documented these energies and GHG
emissions reductions.

Remote Verification Acceptable: NO

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5. D. ETHICS

D1) Business Integrity

The highest standards of integrity are to be upheld in all business interactions. Participants shall have a zero-tolerance policy to prohibit any and
all forms of bribery, corruption, extortion and embezzlement.

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D1.1 Adequate and effective policy and procedures to uphold the highest standards of integrity in all business interactions with a zero tolerance to
any and all forms of bribery, corruption, extortion and embezzlement.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policy and procedures to uphold the
highest standards of integrity in all business interactions with a
zero tolerance to any and all forms of bribery, corruption,
extortion and embezzlement
2) Investigation and sanctions
a) Adequate and effective monitoring program
b) Appropriate investigation process when there is an alleged
violation.
c) Appropriate sanctions when a violation is confirmed/proven and
preventive action plan
d) Adequate and effective procedure is in place to protect
workers/employees from retribution for refusing to do anything
in Non-conformance with the “highest standard of integrity”
policy and communicate/volunteer their decision.
3) Records
a) Investigation reports on alleged violations
b) Sanctions in personnel files for proven/confirmed violations and
preventive action plan
c) Personnel files, leave records and disclosure records confirms no
negative consequence for any worker/employee refusing to do
anything in Non-conformance with the “highest standard of
integrity” policy
d) Confirmation in personnel records that the policy was
communicated in an understandable form

Additional assistance:
Site Observations Record Review
1) ALL Ethics investigation and sanctions findings must be listed in
this AC

Rating:
Priority Major Minor Not Applicable
1. Confirmed case of Ethics breach (all of D section) 1. No detailed and understandable policy and One or more of the following is true: Not Applicable
without investigation or corrective action plan or procedures implemented 1. Partial policy or procedures or implementation
corrective action plan not implemented) excluding 2. Confirmed case has been documented and 2. Confirmed case without completed corrective
fraudulent documents which is listed in D3.1) investigated but no progress has been made to action plan within the timeline specified in the
implement corrective action procedures and / or policy.
Remote Verification Acceptable: NO

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 D2) No Improper Advantage

Bribes or other means of obtaining undue or improper advantage are not to be promised, offered, authorized, given or accepted. This prohibition
covers promising, offering, authorizing, giving or accepting anything of value, either directly or indirectly through a third party, in order to obtain
or retain business, direct business to any person, or otherwise gain an improper advantage. Monitoring and enforcement procedures shall be
implemented to ensure compliance with anti-corruption laws.

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D2.1 No identified risk or evidence of bribes or obtaining undue or improper advantage being promised, offered, authorized, given or accepted.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective procedures are in place that ensure:
i) Gifts: Gifts to or from suppliers and customers is not
excessive in cost and frequency.
ii) Bribes: Bribes or other methods of obtaining undue or
improper advantage are not being promised, offered,
authorized, given or accepted.
iii) Conflict of interest: encourages workers/employees to
declare conflicts of interest
b) Ensure compliance with anti-corruption laws
2) Monitoring
a) Facility has a program to regularly monitor its business to ensure:
i) Workers or agents do not make or accept improper offers,
bribes or undue/improper advantage
3) Records
a) Declarations of conflict of interest are recorded.
Additional assistance:
Site Observations Record Review
1) If labor agents are used, then these procedures also need to be
implemented at the labor agent level.
2) Investigation and sanctions findings must be listed in D1.1

Rating:
Priority Major Minor Not Applicable
1. Confirmed case of bribery, improper advantage, 1. No detailed and understandable gift or similar 1. Partial policy) or procedures or implementation Not Applicable
corruption, extortion, or embezzlement with no policy and procedures implemented
corrective action plan.
Remote Verification Acceptable: YES

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 D3) Disclosure of Information

All business dealings should be transparently performed and accurately reflected on Participant’s business books and records. Information regarding
participant labor, health and safety, environmental practices, business activities, structure, financial situation and performance is to be disclosed in
accordance with applicable regulations and prevailing industry practices. Falsification of records or misrepresentation of conditions or practices in
the supply chain is unacceptable.

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D3.1 No identified risk or evidence of misreporting, record falsification, misrepresentation or evidence of communicating inaccurate information to
the public
Conformance Requirements:
Site Observations Record Review
1) If publically communicated company 1) Policy
information is posted then it is accurate a) Public information must not make false or misleading statements
about the Auditee's products, services, opportunities, position, ....
b) Formal program to ensure public Auditee statements are not false
or misleading
c) Adequate and effective procedures to
i) Record: Ensure that all business dealings should be
transparently performed and accurately reflected on
Participant’s business books and records
ii) Inspect: Inspect/assess/audit records verifying they are not
falsified and accurate.
iii) Investigate: investigate misrepresentation by workers,
managers and their agents.
2) Records
a) Financial and annual reports about the Auditee’s business
operations are available and ready for review
b) Inspection and investigation records are available for review
Additional assistance:
Site Observations Record Review
1) Scope:
a) Information regarding participant labor, health and safety,
environmental practices, business activities, structure, financial
situation and performance is to be disclosed in accordance with
applicable regulations and prevailing industry practices.
b) Falsification of records or misrepresentation of conditions or
practices in the supply chain is unacceptable
c) Unintentional errors are out of scope for this question.
2) Records
a) Examples
i) E.g. Good accounting policies, procedures, and record
keeping, internal controls to ensure the accuracy of
information
ii) E.g. Annual periodic third party financial audit to confirm
that accounts are in order
3) Auditors will cross check a number of different business records to
ensure records align and are accurate.
4) NOTE: Includes all kinds of publically communicated company
information (job posting, product details, company/facility promotion
(booklet/flyer), commercial advertising, press releases, website, ...)
5) Investigation and sanctions findings must be listed in D1.1

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Rating:
Priority Major Minor Not Applicable
1. Documents are fraudulent 1. No detailed and understandable policy and 1. Partial policy or procedures or implementation Not Applicable
procedures implemented
Remote Verification Acceptable: YES

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 D4) Intellectual Property

Intellectual property rights are to be respected; transfer of technology and know-how is to be done in a manner that protects intellectual property
rights and customer and supplier information is to be safeguarded.

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D4.1 No identified risk or evidence of Intellectual Property or business information loss or unauthorized disclosure (the Auditee’s own and that of
their customers/suppliers)
Conformance Requirements:
Site Observations Record Review
1) Is IP and business information visibly 1) Policy
protected a) Adequate and effective policy and program is in place to review
and protect
i) The information received from suppliers, customers as part
of the contracting process.
ii) IP ownership and ensure protection of IP
2) It measures
a) Guidelines about the distribution/dissemination of information to
protect information from suppliers and customers and IP
3) Contracts
a) Non-disclosure agreement (separate or part of employment
contract) for workers and management is in place

Additional assistance:
Site Observations Record Review
1) Information from suppliers and customers could include:
a) Names and contact information for key customer personnel
b) Contract pricing and volumes
c) Names of sub-contractors and materials/components suppliers, ...
d) Their identities and trademarks
e) Third-Party Intellectual Property (IP)
f) Patent records
g) Copyright-protected content.
2) Customers could include channel partner and other business
relationships
3) Suppliers could include representatives, agents, sub-contractors
and other business relationships
4) Investigation and sanctions findings must be listed in D1.1

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No detailed and understandable policy and 1. Partial policy or procedures or implementation Not applicable
procedures implemented
Remote Verification Acceptable: YES

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 D5) Fair Business, Advertising and Competition

Standards of fair business, advertising and competition are to be upheld.

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D5.1 No identified risk or evidence of non-conformance with fair business, advertising and competition standards
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policy and procedures ensuring fair
business, advertising and competition standards are upheld
including
i) Safeguards are in place to prevent collusion with other
companies on product pricing or other factors that could
reduce competition
ii) Monitoring procedures related to fair business, advertising
and competition are in place
Additional assistance:
Site Observations Record Review
1) Investigation and sanctions findings must be listed in D1.1

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No detailed and understandable policy and 1. Partial policy or procedures or implementation Not Applicable
procedures implemented
Remote Verification Acceptable: YES

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 D6) Protection of Identity and Non-Retaliation

Programs that ensure the confidentiality, anonymity and protection of supplier and employee whistleblowers are to be maintained unless prohibited
by law. Participants should have a communicated process for their personnel to be able to raise any concerns without fear of retaliation.

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D6.1 No identified risk or evidence of retaliation or reduced protection of identity
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
a) Adequate and effective policy and procedures ensuring protection
of identity and non-retaliation are in place including
i) Safeguards are in place to prevent reduced protection of
identity and retaliation
ii) Monitoring procedures related to protection of identity and
retaliation are in place
b) Adequate and effective policy and procedures to ensure
protection of Whistleblowers and/or users the of the grievance
mechanism(s) (internal and external)

Additional assistance:
Site Observations Record Review
1) Investigation and sanctions findings must be listed in D1.1
2) Findings on grievance mechanisms (internal and external) are
listed in E8.1

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No detailed and understandable policy and 1. Partial policy or procedures or implementation Not Applicable
procedures implemented
Remote Verification Acceptable: YES

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 D7) Responsible Sourcing of Minerals

Participants shall have a policy to reasonably assure that the tantalum, tin, tungsten and gold in the products they manufacture does not directly or
indirectly finance or benefit armed groups that are perpetrators of serious human rights abuses in The Democratic Republic of Congo or an adjoining
country. Participants shall exercise due diligence on the source and chain of custody of these minerals and make their due diligence measures
available to customers upon customer request.

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D7.1 Adequate and effective Conflict Minerals Policy and Management Program that is designed and implemented to reasonably assure that
purchasing of the 3TG minerals does not finance or benefit armed groups that are perpetrators of serious human rights abuses in the Democratic Republic
of the Congo or an adjoining country.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Policy
Adequate and effective Conflict Minerals Policy and Management Program
that is designed and implemented to reasonably assure that purchasing of the
3TG minerals does not finance or benefit armed groups that are perpetrators
of serious human rights abuses in the Democratic Republic of the Congo or
an adjoining country including
i) Publicly communicated.
ii) Cover all 3TG included in the company’s products
iii) Commit the company to exercise due diligence on the origin
and chain of custody of minerals in accordance with the
OECD Due Diligence Guidance.
iv) NOT to source 3TG that directly or indirectly benefit armed
groups that are perpetrators of serious human rights abuses
in the Democratic Republic of the Congo or an adjoining
country including
2) Program requirements
a) The facility shall implement the conflict minerals management
program within its own operation(s), including:
i) Identifying a senior management person responsible for
implementation of the due diligence program
ii) Including sourcing requirements in written agreements
and/or contracts with suppliers.
iii) Mitigate any risks identified in accordance with the OECD
Due Diligence Guidance including suspend or terminate the
business relationship with the supplier when the risk
mitigation is unsuccessful
iv) Reviewing the procedures, on an annual basis, to ensure
conformance and improve where process improvements
have been identified.
3) Records
a) Maintaining records related to conflict minerals due diligence for
a minimum of five (5) years
b) Annual review and improvement plan (if applicable)
c) Mitigation plans with suppliers if any risk is identified
d) Additional actions taken to ensure completion at due date if
mitigation actions are not on track.

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Additional assistance:
Site Observations Record Review
1) Publicly communicated=e.g. posted to the company’s website (include
URL), contained within a Corporate Responsibility Report, and/or
Supplier Code of Conduct or other official public company
communications.
2) Serious human rights abuses=defined in annex II of the OECD Due
Diligence guidance
3) Conflict minerals= Tantalum, Tin, Tungsten and Gold or 3TG
4) Covered Countries= Democratic Republic of the Congo (DRC) and
adjoining countries (Angola, Burundi, Central African Republic,
Republic of the Congo, Rwanda, South Sudan, Tanzania, Uganda and
Zambia
5) For rating, documentation means supplier request and two follow
up requests are made if no information is received.

Rating:
Priority Major Minor Not Applicable
1. Confirmed purchasing of minerals from conflict 1. No existence of clear Conflict Free Minerals policy 1. Less than 25% of 3TG sources do not have a 1. No Tin, Tungsten, Tantalum and Gold (3TG)
sources in the Covered Countries and no and/or Conflict Minerals and management system, due-diligence and documentation in place mineral material or containing components
documented action taken by auditee to address the more than 25% of 3TG sources do not have a due-
issue. diligence and documentation in place

Remote Verification Acceptable: NO

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 D8) Privacy

Participants are to commit to protecting the reasonable privacy expectations of personal information of everyone they do business with, including
suppliers, customers, consumers and employees. Participants are to comply with privacy and information security laws and regulatory requirements
when personal information is collected, stored, processed, transmitted, and shared.

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D8.1 No identified risk or evidence of unauthorized disclosure of personal information
Conformance Requirements:
Site Observations Record Review
1) Personal information is visibly protected 1) Policy
a) Adequate and effective policy and procedures ensuring protection
of personal information are in place including
i) Safeguards are in place to prevent unauthorized disclosure
of personal information
ii) Monitoring procedures related to protection of personal
information are in place
Additional assistance:
Site Observations Record Review
1) Scope:
a) Everyone Auditee does business with, including suppliers,
customers, consumers and employees.
b) Requirements apply when personal information is
i) Collected
ii) Stored
iii) Processed
iv) Transmitted
v) Shared.
2) Investigation and sanctions findings must be listed in D1.1

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No detailed and understandable policy and 1. Partial policy or procedures or implementation Not Applicable
procedures implemented
Remote Verification Acceptable: YES

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6. E. MANAGEMENT SYSTEM

E1) Company Commitment

Corporate social and environmental responsibility policy statements affirming Auditee’s commitment to compliance and continual improvement,
endorsed by executive management and posted in the facility in the language of the workers or in a language the workers can understand.

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E1.1 Adequate and effective policies/Code(s) that are endorsed by executive management, covering: A) Labor B) Health & Safety C) Environment
and D) Ethics.
Conformance Requirements:
Site Observations Record Review
1) Corporate social and environmental 1) Statement/Code signed/endorsed by the highest-level manager at the
responsibility policy statements in a facility or company with a stated commitment to regulatory compliance
language understood by each worker is and other requirements and commitment to continuous improvement
visible to all workers 2) The policy statement is appropriate for the nature and scope of the
facility’s operations.
Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. if a valid ISO 14001 certificate is in place the
Auditor will not verify the Environmental Management System)
2) The executive endorsement of the code can be absent when policy/Code
is publicly displayed (e.g. intra or internet site).
3) Operating Procedures: Accurate and transparent disclosure of
information (example: accuracy of company records, accurate
reporting in books and records, disclosed in accordance with law /
prevailing industry practices)
4) For Ethics, items/principles in BOLD must be covered at a minimum
in at least one of their code of business ethics, standards of business
conduct, business principles or code of conduct or similar document.
The words do not have to match, but the principles need to be there:
a) General Ethics: conduct business with honesty/integrity
(examples: avoid conflicts of interest, stealing, extortion,
embezzlement, protect corporate assets, compete fairly),
protection of identity and non-retaliation (example:
whistleblower, anonymous reporting)
b) Legal compliance: Anti-Corruption or Anti-Bribery, Anti-Trust,
Privacy, Intellectual Property (IP) Protection, Responsibly
Sourcing Minerals

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement elements 1. No endorsement of senior management,
are missing or ineffective 2. One of minimum requirement elements is missing or
2. Does not contain commitment to continuous ineffective, or a system element is not adequately
improvement and legal compliance documented or is prohibited
3. Percentage of workers not aware of code content is 3. Percentage of workers not aware of code content is
>20% ≤20%
Remote Verification Acceptable: YES

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 E2) Management Accountability and Responsibility

The Participant clearly identifies senior executive and company representative[s] responsible for ensuring implementation of the management
systems and associated programs. Senior management reviews the status of the management system on a regular basis.

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E2.1 Responsibilities and authorities are adequately and effectively defined and assigned for all employees/workers (senior managers to workers) for
implementation of management systems, and for compliance with laws, regulations and codes pertaining to: A) Labor B) Health & Safety C)
Environment and D) Ethics.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Senior representative
a) A senior is representative assigned responsibility for
implementing programs
i) To ensure compliance with laws and regulations and the
requirements of the RBA
ii) Is authorized to implement programs, procedures and
corrective actions as needed for regulatory compliance and
RBA conformance
2) Assignment
a) Responsibilities and authority of each organizational level are
documented in position plans, job descriptions and/or the facility's
management system documentation
i) For normal situations
ii) For emergency situations

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. if a valid third-party ISO 14001 certificate is in
place the Auditor will not verify the Environmental Management
System)

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One of minimum requirement elements is missing Not Applicable
1. Two or more of minimum requirement elements or ineffective, or a system element is not
are missing or ineffective adequately documented or is prohibited
2. No identified management representative
authorized to implement the management system
of a component

Remote Verification Acceptable: YES

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E2.2 An adequate and effective management review and continuous improvement process for A) Labor, B) Health & Safety, C) Environment and D)
Ethics performance and management systems are established
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective annual management system review
process is in place
2) Records
a) System review meetings
b) Preventive corrective action plan following the review
c) Management review meeting presentation materials/analysis/data

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. If a valid ISO 14001 certificate is in place the
Auditor will not verify the Environmental Management System)
2) Management review minutes include e.g.
a) Agenda
b) Presentation material (references)
c) Date
d) Who was present (including senior manager)
e) Progress towards objectives
f) Results of Audits
g) Completion of corrective/preventive actions
h) Risks/issues
i) Other information needed to determine the effectiveness of the
management system and identify improvement opportunities
j) Agreed preventive/corrective actions

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: 1. One of minimum requirement elements is missing Not Applicable
1. Two or more of minimum requirement elements or ineffective, or a system element is not
are missing or ineffective adequately documented or is prohibited
2. Senior management does not assess annually

Remote Verification Acceptable: YES

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 E3) Legal and Customer Requirements

A process to identify, monitor and understand applicable laws, regulations and customer requirements, including the requirements of this Code.

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E3.1 An adequate and effective compliance process to monitor, identify, understand and ensure compliance with applicable laws and regulations and
customer requirements pertaining to: A) Labor B) Health & Safety C) Environment and D) Ethics is established
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective quarterly compliance process to maintain
a current understanding of applicable legal and customer
requirements:
i) Identify
ii) Track
iii) Assess
iv) Integrate
v) Implement
vi) Records
2) Records
a) Accurate and up to date compliance register
b) A compliance calendar or reminders/tasks/calendar appointments
via an e-mail system.
c) Summaries of applicable laws and regulations and the key
customer requirements that impact the operations
d) New/changed operations/policies/procedures as a result of the
review process for new requirements

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. if a valid ISO 14001 certificate is in place the
Auditor will not verify the Environmental Management System)

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing Not Applicable
are missing or ineffective or ineffective, or a system element is not
adequately documented or is prohibited

Remote Verification Acceptable: YES

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 E4) Risk Assessment and Risk Management

A process to identify the legal compliance, environmental, health and safety and labor practice and ethics risks associated with Auditee’s operations
Determination of the relative significance for each risk and implementation of appropriate procedural and physical controls to control the identified
risks and ensure regulatory compliance.

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E4.1 An adequate and effective risk management process to identify, assess, and minimize/mitigate/control its risks in the areas of: A) Labor C)
Environment and D) Ethics is in place
Conformance Requirements:
Site Observations Record Review
1) Control measures are in place for identified 1) Process
risks a) Adequate and effective risk assessment process using the
hierarchy of controls or equivalent process is in place to identify
the most significant risks (including applicable legal requirements
and applicable customer requirements).
b) The risk assessment is updated when there is a Significant Change
c) Any identified risk has an action plan to minimize such risk and
procedural controls and/or improvement objective.
d) Effectiveness of controls is evaluated on a regular basis
2) Records
a) Formal risk assessment reports
b) Corrective/preventive action plan for identified risks
c) Procedural controls are documented
d) Where controls are not yet in place an implementation plan (with
owners and due date) is in place and on track
Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. if a valid ISO 14001 certificate is in place the
Auditor will not verify the Environmental Management System)
2) Scope of the risk assessment:
a) Every site operation/process
b) Physical location
c) Consideration of multiple chemical exposures, combined physical
and chemical exposure effects, and extended work periods (as
applicable)
3) For Ethics, - Risk assessment takes into account business circumstances
(country of operations, stakeholders, ...) and covers at minimum
honesty, integrity, intellectual property protection, bribery, corruption,
fraud/embezzlement, embezzlement, extortion, legal, ethical, fair
business/marketing practices, reporting violations, whistleblower
protection, kickbacks, bribes, privacy, unlawful payments, ...
4) Health and Safety Risk assessment is covered in B1.2

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Rating:
Priority Major Minor Not Applicable
1. Imminent and significant impact are confirmed on One or more of the following is true: One or more of the following is true: Not Applicable
facility, life, limb or community without action 1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing
are missing or ineffective or ineffective, or a system element is not
2. No risk process adequate for the scope and nature adequately documented or is prohibited
of the operations and no controls in place 2. Risk process adequate for the scope and nature of
the operations AND risk assessment performed but
no adequate controls in place
3. No consideration of multiple chemical exposures

Remote Verification Acceptable: YES

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 E5) Improvement Objectives

Written performance objectives, targets and implementation plans to improve the Auditee’s social performance, including a periodic assessment of
Participant’s performance in achieving those objectives.

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E5.1 An adequate and effective performance management process for A) Labor, B) Health & Safety, and D) Ethics, including setting performance
(improvement) objectives and targets, developing and implementing improvement plans, regularly reviewing progress toward achieving targets, and
making appropriate adjustments if needed is in place
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective annual performance management process
within formal and communicated indicators, objectives and
targets
b) Additional action plans if indicator, objective or target is off track
2) Records
a) Formal target, indicator and objective tracking
b) Implementation plans
c) Regular progress reporting
Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. If a valid ISO 14001 certificate is in place the
Auditor will not verify the Environmental Management System)
2) Process
a) Scope of indicators, objectives and targets:
i) Consideration of risk assessment results
ii) Legal and regulatory requirements
iii) Company standards/requirements.
3) The process should also include
a) Assignment of owners
b) Implementation plans
c) Completion dates
d) Communication of objectives to workers (as appropriate).
e) How frequently progress in meeting objectives is reviewed
f) Objectives and targets are clearly designed to achieve continual
improvement
4) Auditor guidance: Reporting on this question will include the detail
of the current targets and current progress against the targets
5) Environment objectives, targets and performance are addressed in
C2.1

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Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing
are missing or ineffective or ineffective, or a system element is not
2. No targets established adequately documented or is prohibited
3. No review takes place on progress 2. Targets are established but no review takes place
3. No corrective actions taken if progress is off track
Remote Verification Acceptable: YES

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 E6) Training

Programs for training managers and workers to implement Participant’s policies, procedures and improvement objectives and to meet applicable
legal and regulatory requirements.

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E6.1 An adequate and effective training process is established for all managers/workers on all policy/procedures/job related aspects and performance
targets related to A) Labor, B) Health and Safety C) Environment, and D) Ethics
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) adequate and effective training to workers/managers:
i) New employee orientation plan
ii) Training needs analysis
iii) Training plan
iv) Training material
v) Training records
vi) Training frequency
vii) Training efficiency verification
b) Minimum training topics are covered
2) Evaluation
a) The training programs will be evaluated on a regular basis not
exceeding 3 years or sooner if there is a Significant Change
3) Records
a) Training records include a verification of training effectiveness
b) Training evaluation reports and corrective action if required
c) Educational materials

Additional assistance:
Site Observations Record Review
1) This includes conformance section training – this section must
always be completed even if a valid systems certificate is available
(e.g. ISO 14001 for environment)
2) Health & Safety training is listed in B8
3) For ethics: this includes workers but also all subcontractors,
Suppliers, business partners and other relevant parties

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 Site Observations Record Review
4) Minimum training topics
a) Labor
i) Freely Chosen Employment (avoidance of forced, involuntary or
exploitative prison, indentured, bonded (including debt
bondage), trafficked or slave labor)
ii) Worker Terms and Conditions
iii) Non-retention of personal documentation
iv) Freedom of movement
v) Legal minimum working age
vi) Young worker protection
vii) Apprentice/Intern/Student Worker employment
viii) Working hours including overtime
ix) Mandated breaks, holidays and vacation days, including time off
when ill or for maternity leave
x) Wages statement and wage calculation
xi) Disciplinary procedures
xii) Non- discrimination and harassment
xiii) Reasonable accommodation for religious practices
xiv) Freedom of Association/Collective Bargaining and peaceful
assembly
b) Environment
i) Reduction programs
ii) Hazardous waste handling, storage and disposal
iii) Solid waste handling, storage and disposal
iv) Air emissions and air emission control systems
v) Material restriction
vi) Water use, discharge and internal water channel contamination
protection
vii) Storage and disposal
viii) GHG/ Energy use, reduction and maintaining energy and fuel-
consuming operations
c) Ethics
i) Upholding the highest standards of integrity in all business
interactions
ii) Obtaining undue or improper advantage being promised,
offered, authorized, given or accepted
iii) Intellectual Property Protection
iv) Fair Business, Advertising and Competition
v) Non-retaliation or protection of identity
vi) Purchasing of the 3TG minerals does not finance or benefit
armed groups or contribute to serious human rights abuses in
Conflict-Affected and High-Risk Areas
vii) Unauthorized disclosure of personal information
d) Management Systems
i) Responsibilities and authorities are adequately and effectively
defined
ii) Grievance and complaints systems

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Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing
are missing or ineffective or ineffective, or a system element is not
2. Two or more focus areas are missing in the adequately documented or is prohibited
communications (policy, performance, practice, 2. One focus area is missing in the communications
expectations) (policy, performance, practice, expectations)

Remote Verification Acceptable: YES

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 E7) Communication

Process for communicating clear and accurate information about Auditee’s policies, practices, expectations and performance to workers, Suppliers
and customers.

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E7.1 An adequate and effective worker/manager, Supplier and customer communication/reporting process for A) Labor, C) Environment, and D)
Ethics policies, practices and performance is established
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective worker/manager, Supplier and customer
communication/reporting process to Suppliers is in place
i) Suppliers
(1) Correspondence to Supplier management
(2) Contract terms and conditions requiring Suppliers to
conform to the RBA code and comply with all
applicable CA
ii) Customers
(1) Recruitment practices and performance (including
freely chosen employment, e.g. Demographics of
labor and list of labor agents/ contractors with
percentage of workforce, costs to workers (in total
absolute numbers and per contract base) and labor
agent/contractor fees).
iii) Workers / Managers
(1) The minimum communication topics are covered
2) Evaluation
a) The communication programs will be evaluated on a regular basis
not exceeding 3 years or sooner if there is a Significant Change
3) Records
a) Communications records include a verification of communication
effectiveness
b) Educational materials
c) Presentations to Suppliers

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Additional assistance:
Site Observations Record Review
1) This includes conformance section communications – this section
must always be completed even if a valid systems certificate is
available (e.g. ISO 14001 for environment)
2) Health & Safety communications is listed in B8
3) Submitting SAQ to customers does not qualify as
disclosure/communication to customers
4) Minimum Communications topics
a) Labor
i) Freely Chosen Employment (avoidance of forced,
involuntary or exploitative prison, indentured, bonded
(including debt bondage), trafficked or slave labor)
ii) Worker Terms and Conditions
iii) Non-retention of personal documentation
iv) Freedom of movement
v) Legal minimum working age
vi) Young worker protection
vii) Apprentice/Intern/Student Worker employment
viii) Working hours including overtime
ix) Mandated breaks, holidays and vacation days, including
time off when ill or for maternity leave
x) Wages statement and wage calculation
xi) Disciplinary procedures
xii) Non- discrimination and harassment
xiii) Reasonable accommodation for religious practices
xiv) Freedom of Association/Collective Bargaining and peaceful
assembly
b) Environment
i) Reduction programs
ii) Hazardous waste handling, storage and disposal
iii) Solid waste handling, storage and disposal
iv) Air emissions and air emission control systems
v) Material restriction
vi) Water use, discharge and internal water channel
contamination protection
vii) Storage and disposal
viii) GHG/ Energy use and reduction
c) Ethics
i) Upholding the highest standards of integrity in all business
interactions
ii) Obtaining undue or improper advantage being promised,
offered, authorized, given or accepted
iii) Intellectual Property Protection
iv) Fair Business, Advertising and Competition
v) Non-retaliation or protection of identity
vi) Purchasing of the 3TG minerals does not finance or benefit
armed groups or contribute to serious human rights abuses
in Conflict-Affected and High-Risk Areas
vii) Unauthorized disclosure of personal information
d) Management systems
i) Grievance and complaints systems

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Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing
are missing or ineffective or ineffective, or a system element is not
2. Two (2) or more focus areas are missing in the adequately documented or is prohibited
communications (policy, performance, practice, 2. One (1) focus area are missing in the
expectations) communications (policy, performance, practice,
expectations)

Remote Verification Acceptable: YES

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 E8) Worker Feedback, Participation and Grievance

Ongoing processes, including an effective grievance mechanism, to assess employees’ understanding of and obtain feedback on or violations against
practices and conditions covered by this Code and to foster continuous improvement.

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E8.1 An adequate and effective grievance/complaint process where work-related and Code-related grievances or complaints without fear of reprisal
or intimidation is established can be confidentially communicated
Conformance Requirements:
Site Observations Record Review
1) Grievance and complaint channels are 1) Process
clearly communicated a) Adequate and effective process to anonymously report grievances
2) Internal communication of the grievance and complaints without fear of reprisal.
mechanism must be in workers’ native b) The grievance mechanism is internal (for workers and staff) and
language(s) and visible external (for workers of suppliers, local community or interested
actors AND Whistleblowers)
c) Clear grievance channels so anyone is comfortable reporting
grievances and so that reporting is encouraged
2) Investigation and actions
a) Auditee shall promptly investigate the validity of the any
grievance or complaint and take prompt remedial action if the
claim is valid
b) All who file a grievance or complaint shall have their identity
protected and Auditee will ensure a no reprisal or intimation
approach
3) Records:
a) Grievance/complaint records are in place for a period of at least
12 months
b) Workers are provided with written information on how to report
grievances and complaints
Additional assistance:
Site Observations Record Review
1) This includes conformance section communications – this section
must always be completed even if a valid systems certificate is
available (e.g. ISO 14001 for environment)
2) If finding of retaliation is in regard to an ethics violation or the
identity of a grievant is not protected, the finding should be
reported in D
3) Auditor guidance: evidence to show actions have been taken for the
grievance/complaints in the past 12 months” may need to spot check 1
or 2 case records.

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Rating:
Priority Major Minor Not Applicable
1. Confirmed case not investigated or without 1. Two or more of minimum requirement elements are 1. One of minimum requirement elements is missing Not Applicable
corrective action plan missing or ineffective or ineffective, or a system element is not
2. No anonymous reporting channels adequately documented
3. No action has been taken/recorded for the
grievance/complaint for 3 months
Remote Verification Acceptable: NO

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E8.2 An adequate and effective process to solicit and encourage worker participation, input and feedback for improvement
Conformance Requirements:
Site Observations Record Review
1) Feedback channels are clearly 1) Process
communicated and visible (suggestion box, a) Adequate and effective process to obtain worker input and
...) feedback such as:
i) Worker surveys
ii) Suggestions boxes
iii) Worker focus groups
iv) Joint worker-management committees
v) Worker/union representatives
vi) Process improvement teams.
2) Evaluation and actions
a) Auditee shall promptly evaluate the validity of the any input of
feedback and take prompt action if the input/feedback is valid
3) Records:
a) Input/feedback records are in place for a period of at least 12
months
b) Workers are provided with written information on how to provide
input/feedback for improvement
c) Action plans are available, implemented or on track.

Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. if a valid third-party ISO 14001 certificate is in
place the Auditor will not verify the Environmental Management
System)

Rating:
Priority Major Minor Not Applicable
Not Applicable 1. No feedback mechanism(s) in place 1. One of minimum requirement elements is missing 1. No worker communication
or ineffective, or a system element is not
adequately documented or is prohibited

Remote Verification Acceptable: NO

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 E9) Audits and Assessments

Periodic self-evaluations to ensure conformity to legal and regulatory requirements, the content of the Code and customer contractual requirements
related to social and environmental responsibility.

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E9.1 An adequate and effective self-audit process to periodically assess conformance with the RBA Code pertaining to: A) Labor B) Health & Safety
C) Environment and D) Ethics.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Adequate and effective self-audit process to periodically assess
conformance with:
i) Applicable regulatory requirements
ii) RBA Code requirements
iii) Own policies, standards and management system
iv) Other requirements to which the facility subscribes
b) Audit findings are reviewed by senior management.
2) Records
a) Self-audit Reports
b) Corrective Action Plans a s a result of the Self Audit, additional
actions if the Corrective Action Plan is off-track
Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. if a valid third-party ISO 14001 certificate is in
place the Auditor will not verify the Environmental Management
System)
2) Audit scope:
a) All areas of the facility,
b) All processes, physical conditions and work practices
c) Review of documents and records
d) Interviews with individuals responsible for SER.

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. No Audits carried out 1. One of minimum requirement elements is missing
2. Two or more of minimum requirement elements or ineffective, or a system element is not
are missing or ineffective adequately documented or is prohibited
3. Scope does not include regulatory compliance 2. Scope includes regulatory compliance but not
customer requirements

Remote Verification Acceptable: YES

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 E10) Corrective Action Process

Process for timely correction of deficiencies identified by internal or external assessments, inspections, investigations and reviews.

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E10.1 Has established an adequate and effective corrective actions process to rectify and close Non-conformances for A) Labor B) Health & Safety
C) Environment and D) Ethics.
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) adequate and effective corrective actions process is in place which
contains the following:
i) Corrective action reports/plans and tracking tables
ii) additional actions are taken when a corrective action is off
track
iii) A demonstrated link between the CAP and the performance
management objectives and targets.
iv) Closure of action items is confirmed by a management
representative after verification by the appropriate person
2) Records
a) Records documenting the non-conformance
b) Corrective action plan for each non-conformance
c) Progress reports on the Corrective Action plan
d) Closure verification reports (with mgmt. confirmation)
e) Copies of any regulatory citations/violation notices received in
the past three years, including any communications with the
agencies are available for review.

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Additional assistance:
Site Observations Record Review
1. Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. if a valid third-party ISO 14001 certificate is in
place the Auditor will not verify the Environmental Management
System)
2. Scope of corrective action plan:
a. All identified non-conformances identified via internal or external
Audits, assessments, inspections, investigations and reviews against
with the RBA Code including legal and customer requirements
3. Corrective action reports/plans and tracking tables
a. Root cause analysis of the finding to ensure the system gap
is addressed
b. Specific corrective actions
c. Owners of the action
d. Due dates are established to address all Audit issues.
4. appropriate person = auditor, inspector, officer of the party which
determined the non-conformance or their designate
5. If closure was not verified by an independent third party or the
original government agency, Auditor must verify closure
6. Auditor guidance: General public record search by Auditors is
performed to learn if the regulatory authorities have imposed corrective
action or penalties in last 3 years for each component.

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: The following are true:
1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing 1. No Audit or evaluation performed
are missing or ineffective or ineffective, or a system element is not 2. Auditee has NOT been subject to any labor
2. One or more unaddressed regulatory actions or adequately documented or is prohibited regulatory actions in the past 3 years. 3 data points
penalties. 2. Regulatory actions or penalties are addressed but are required to show there was no case in the past 3
off track and no corrective actions are taken to get years.
them back on track

Remote Verification Acceptable: YES

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 E11) Documentation and Records

Creation and maintenance of documents and records to ensure regulatory compliance and conformity to company requirements along with
appropriate confidentiality to protect privacy.

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E11.1 Adequate and effective documentation and records process with appropriate levels of access to ensure privacy for A) Labor, B) Health &
Safety, C) Environment, and D) Ethics
Conformance Requirements:
Site Observations Record Review
1) Documents are securely stored with 1) Process
authorized access only a) Adequate and effective documentation and records process with
appropriate retention (on and off site) and appropriate levels of
access to ensure privacy conforming to
i) Regulatory (including record retention laws)
2) Records
a) A listing/table of documents and records retained required is
available for review
b) Record retention is conform the requirements
c) Minimum records are available for review
Additional assistance:
Site Observations Record Review
1) Requirements apply for each component. Components are Labor,
Health & Safety, Environmental and Ethics. If a component has a valid
certification, then this is considered conformance for that component
on this question (i.e. If a valid third-party ISO 14001 certificate is in
place the Auditor will not verify the Environmental Management
System)
2) Minimum records:
a) Records of wages paid and hours worked
b) Verification of worker age
c) Financial Audit reports
d) Non-Disclosure Agreements (NDAs)
e) Contract terms and conditions
f) Self-Audit reports
g) Regulatory compliance evaluations
h) Risk assessments
i) Work practices and procedures
j) Performance in meeting objectives and targets
k) Reports of inspections by regulatory agencies
l) Incident investigations
m) Worker complaints
n) Training records
o) Management System Review minutes and action items
p) Corrective action records.
q) Conflict of interest declarations are available in personnel files

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Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: Not Applicable
1. Two or more of minimum requirement elements 1. One of minimum requirement elements is missing
are missing or ineffective or ineffective, or a system element is not
2. Does not meet regulatory requirements adequately documented or is prohibited
2. Meets regulatory requirement but not customer
requirements

Remote Verification Acceptable: NO

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 E12) Supplier Responsibility

Process to communicate Code requirements to Suppliers and to monitor Supplier compliance to the Code.

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E12.1 The RBA Code requirements have been communicated to the next tier major Suppliers
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) Suppliers
i) Supplier program (identification of Major Suppliers,
definition of what is major)
b) Communication
i) Adequate and effective communication process with its
Major Suppliers on the code and its requirements or inserted
the requirements of the code and its provisions into the
contract it has with Major Suppliers.
c) Contracts
(1) Suppliers
(a) Enforcement language on the implementation of
the RBA Code
(2) Labor Agents and Contractors
(a) Enforcement language on the implementation of
the RBA Code regarding Labor and Ethics CA
(b) Compliance with legal requirements in both
home and sending country.
(c) Workers can resign without penalty
(d) Conform with all AC regarding workers in their
operations
2) Records
a) Contract with Suppliers and Labor Agents and Contractors
b) Communication materials to Suppliers and Labor Agents and
Contractors
c) Enforcement notification to Suppliers and Labor Agents and
Contractors
Additional assistance:

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 Site Observations Record Review
1) * =sample size is square root of total workers on site of Suppliers and/or
through a labor agent/contractor
2) Penalty includes no threat of punishment, fines, violence, or
withholding wages
3) Supplier is determined by the criteria defined by the Auditee (annual
spending, critical component to core business, more than once
purchase, within ICT industry supply chain, ...). For the scope of this
code provision the “next tier major supplier” definition will always
include any labor agents/contracts and on-site service providers that fall
outside the scope of sections A3 and A4.
4) Additional specific forced labor requirements for Labor Agents
and Contractors are listed in A1. Forced labor findings Labor
Agents and Contractors are rated in A1
5) Hazardous waste vendors’ findings /corrective action plans which
are missing / off track are rated in C3.
6) Auditor guidance: Determining which suppliers are a Supplier (=
“next tier Major Supplier”) is a process which must be verified
during the audit

Rating:
Priority Major Minor Not Applicable
Not Applicable One or more of the following is true: One or more of the following is true: No Suppliers
1. There is no RBA Supplier implementation 1. RBA Supplier implementation procedures exist but
procedure and there are no documented the percentage of Suppliers that have not been
communication vehicles with Suppliers. communicated to is ≥20%
2. Percentage of workers working thru Labor Agents 2. Percentage of workers working thru Labor Agents
and Contractors that cannot state how their and Contractors that cannot state how their
employment terms and conditions meet the employment terms and conditions meet the
relevant labor requirements of the RBA code is relevant labor requirements of the RBA code is
>20%* >5% and ≤20%*

Remote Verification Acceptable: YES (NO, if non-conformance for Labor Agents and
Contractors)

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E12.2 Adequate and effective process to ensure that the Suppliers implement the RBA Code
Conformance Requirements:
Site Observations Record Review
Not Applicable 1) Process
a) RBA code implementation process for Suppliers is available and
includes
i) A risk assessment.
(1) If a self-reported risk assessment is used such as an
SAQ then information needs to be validated and/or an
Audit performed to verify risk information.
(2) An audit (VAP or CMA) or an AMA (if done by a
third-party Qualified Audit Firm is accepted).
ii) An obligation to go through the CAP process with the
Supplier If non-conformances are detected
iii) A commitment to not immediately de-source at a priority
non-conformance discovery state but only at the non-
implementation of the CAP process
2) Records
a) Verification visit reports for self-reported risk assessment
b) An Audit (CMA or VAP), an AMA (if done by third-party
qualified Audit Firm is acceptable)
c) A corrective action plan for non-conformance areas identified
d) A verification mechanism that corrective actions are implemented
Additional assistance:
Site Observations Record Review
1) Supplier is determined by the criteria defined by the Auditee (annual
spending, critical component to core business, more than once
purchase, within ICT industry supply chain, ...). For the scope of this
code provision the “next tier major supplier” definition will always
include any labor agents/contracts and on-site service providers (such
as security guards, janitorial services, ...) that fall outside the scope of
sections A3 and A4.
2) If an alternative risk-based approach exists (in lieu of a fixed number
of assessment/audits) there is documented criteria, guidelines,
execution of assessments/audits and finding closure tracking
3) Remote / desk-audit or focused audit processes and guidelines used
on smaller, specialized facilities or service providers where a full
RBA audit is not appropriate
4) Additional specific forced labor requirements for labor
agents/contractors are listed in A1.
5) Hazardous waste vendors’ findings /corrective action plans which
are missing / off track are rated in C3.
6) Forced labor findings for labor agents or contractors are rated in
A1

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Rating:
Priority Major Minor Not Applicable
1. For indirect full time assigned workers of on-site One or more of the following is true: 1. One of minimum requirement elements is missing 1. No Suppliers to facility
service providers a priority non-conformance is 1. Two or more of minimum requirement elements or ineffective, or a system element is not
confirmed on provision A3 or A4 are missing or ineffective adequately documented or is prohibited
2. No CAP in place for the majority of Suppliers
(where applicable)

Remote Verification Acceptable: YES (NO, if non-conformance for labor

agents/contractors)

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