SMETA Corrective Action

Plan Report (CAPR)

Version 7
 Contents

Audit сontent

Audit and site details

Audit parameters

Audit attendance

SMETA declaration

Findings

Summary of findings

Non-compliances

Good examples

Management systems

Guidance

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 Audit content

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

The audit scope includes an assessment of the Workplace Requirements and the
Management Systems Assessment against the following Code Areas:

Included in a 2-Pillar audit

Labour Standards Code Areas

0: Enabling accurate Assessmen
1: Employment is Freely Chosen
1.A: Responsible Recruitment & Entitlement to Wor
2: Freedom of Association and Right to Collective Bargaining are
Respecte
4: Child Labour Shall Not be Use
5: Legal Wages are Pai
5.A: Living Wages are Pai
6: Working Hours are Not Excessiv
7: No Discrimination is Practice
8: Regular Employment is Provide
8.A: Sub-contracting and Homeworkers are Used Responsibl
9: No Harsh or Inhumane Treatment is Allowe
Health & Safety Code Area
3: Working Conditions are Safe and Hygieni
Environment Code Area
10.A: Environment 2-Pillar 

Included in a 4-Pillar audit:

Labour Standards Code Area

As 2-pilla
Health & Safety Code Are
As 2-pilla
Environment Code Area
10.A: Environment 2-Pilla
10.B: Environment 4-Pillar
Business Ethics Code Area
10.C: Business Ethics

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 (2) Where appropriate, non-compliances or non-conformances were raised
where either local law or the Base Code were not met, and recorded as non-
compliances on both the audit report, CAPR and on the Sedex Platform.

(3) Any non-conformance against customer code shall not be uploaded to Sedex,
but sent directly to the customer in question.

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Audit and site details

Audit details

Sedex company reference ZC415960353 Auditor company name LRQA

Date of audit 2025-02-25 Audit conducted by Sedex member

Audit pillars Labour Standards | Health and safety | Environment 4-Pillar | Business ethics

Site details

Sedex site reference ZS418615393 Site name AR-Tex Composite Ltd

Business name AR-Tex Composite Ltd Site address 1421 Bholail, Kashipur,
Fatullah, Narayanganj.,
Narayanganj, BD

Site phone +88 02 4760042 Site email compliance.artex@nrgroup-

bd.com

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Audit parameters

Time in and out Day 1

In 09:30
Out 17:43

Audit type Full initial

Was the audit announced? Semi announced

Was the Sedex SAQ available for Yes

review?

Who signed and agreed CAPR? Hasan Md. Shaifullah Sheraji / General Manager - HR, Admin & Compliance

Any conflicting information SAQ/Pre- No

Audit Info

Is further information available? No

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Audit attendance

Senior management Worker representative Union representative

A: Present at the opening meeting? Yes Yes No

B: Present at the audit? Yes Yes No

C: Present at the closing meeting? Yes Yes No

Reason for absence at the opening Currently factory has no trade union and it is not mandatory as per local law.
meeting

Reason for absence during the audit Currently factory has no trade union and it is not mandatory as per local law.

Reason for absence at the closing Currently factory has no trade union and it is not mandatory as per local law.
meeting

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SMETA declaration

Auditor team

SMETA declaration I declare that the audit underpinning the following report was conducted in accordance with
SMETA Minimum Requirements and the SMETA Auditor Manual.

1. Where appropriate non-compliances/ non-conformances were raised against the Base Code and
local law and recorded as non-compliances/ non-conformances on both the audit report, CAPR
and on the Sedex Platform.
2. Any non-conformance against customer code alone shall not be uploaded to Sedex, and will be
shared directly with the customer in question.
This report provides a summary of the findings and other applicable information found/gathered
during the social audit conducted on the above date only and does not officially confirm or certify
compliance with any legal regulations or industry standards. The social audit process requires
that information be gathered and considered from records review, worker interviews,
management interviews and visual observation. More information is gathered during the social
audit process than is provided here. The audit process is a sampling exercise only and does not
guarantee that the audited site prior, during or post–audit, are in full compliance with the Code
being audited against. The provisions of this Code constitute minimum and not maximum
standards and this Code should not be used to prevent companies from exceeding these
standards. Companies applying this Code are expected to comply with national and other
applicable laws and where the provisions of law and this Code address the same subject, to apply
that provision which affords the greater protection. The ownership of this report remains with the
party who has paid for the audit. Release permission must be provided by the owner prior to
release to any third parties.

Any exceptions to the SMETA None

Methodology must be
recorded here (e.g. different
sample size)

Lead auditor Md. Abu Saleh APSCA Number 21705311

Additional auditor Kazimd Masum APSCA Number 32400364

Md. Monzurul Islam APSCA Number 32200821

Abu Sarwar Mohammad APSCA Number 21705582

Mahabubur Rahman APSCA Number 21705290

Date of declaration 2025-02-25

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Site representation

Declaration I acknowledge that details from this report can change during the review process and that I will
be given the opportunity to dispute the content once the review has been published.

Full name Hasan Md. Shaifullah Sheraji

Title General Manager - HR, Admin & Compliance

Date of declaration 2025-02-25

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Summary of findings

Code area Workplace requirement Local law Finding

5.A. Living wages are paid 5.A.A Review workers' total pay including ben... NC ZAF600826327
5.A.B Put in place a wage improvement plan th... NC ZAF600826328
3. Working conditions are safe 3.H Where identified as necessary to reduce r... §1 NC ZAF600826329
and hygienic
3.M Ensure all machinery is installed, mainta... §2 NC ZAF600826330

10.A. Environment 2-Pillar 10.A.B Comply with relevant local, regional a... §3 NC ZAF600826331

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Local law issues

§1 In accordance with Bangladesh Labor Rules, 2015, Rule 67(2): The arrangement of safety and
health protection measures mentioned in Sub-section (1), the concerned manufacturing institute
must provide necessary equipment’s, including safety shoes, helmets, goggles, masks, hand
gloves, ear muffs, ear plugs, waist belts, aprons etc. and arrange training programs for the
workers in using these materials.

§2 In accordance with Bangladesh Labor Law 2006, section-63(1), [In every establishment the
following shall be securely fenced by the safeguards of substantial construction which shall be
kept in a position while the part of machinery required to be fenced are in motion or in use,
namely-(a) every moving part of a prime move, and every flywheel connected to a prime
mover;(b) the headrace and tailrace of every water wheel and water turbine;(c) any part of a stock-
bar which projects beyond the headstock of a lathe; and(d) unless they are in such position or of
such construction as to be as safe to every person employed in the factory as they would be if
they were securely fenced (i) every part of an electric generator, a motor or rotary converter;(ii)
every part of transmission machinery; and(iii) every dangerous part of any machinery ]

§3 In accordance with the condition #6.3 of the Captive Power Plant (CPP) license provided by
“Bangladesh Energy Regulatory Commission”, factory should collect environment clearance
certificate for the Captive power plant from Department of Environment (DOE).

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Findings: non-compliances

ZAF600826327

Code area Status

5.A Living wages are paid Open*

Workplace requirement Time given to resolve

5.A.A Review workers' total pay including benefits and compare it with a credible 'living wage' to
calculate a 'living wage gap', and understand what proportion of the workforce has a gap. Verification method
Collaborative action required
Issue title
904 - CAR: A living wage gap analysis has been completed but it is missing key elements Area of non-compliance/non-
conformance
Description Base code
During current assessment it was noted through documents review and management interview
that facility has calculated living wage but did not follow the methodology according to SMETA
requirements such as Full Fledge Anker methodology, Wage indicator typical family methodology
etc. They have calculated basis on their own methodology.

Corrective and preventative actions

It is recommended that facility should calculate living wage according to the SMETA requirements

* PDF generated at 04:50 (UTC) on 06 May 2025. View this finding on the Sedex platform for live updates and closure details.

ZAF600826328

Code area Status

5.A Living wages are paid Open*

Workplace requirement Time given to resolve

5.A.B Put in place a wage improvement plan that aims to pay workers a living wage within a
stated timeframe. Verification method
Collaborative action required
Issue title
905 - CAR: A wage improvement plan (with Living Wage as the goal) has not been completed Area of non-compliance/non-
conformance
Description Base code
During current assessment it was noted through documents review and management interview
that facility has not developed any improvement plan to pay workers according to living wage
calculation.

Corrective and preventative actions

It is recommended that the facility shall take necessary action to implement goal to pay employee
living wages.

* PDF generated at 04:50 (UTC) on 06 May 2025. View this finding on the Sedex platform for live updates and closure details.

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ZAF600826329 Due 2025-04-01

Code area Status

3 Working conditions are safe and hygienic Closed (2025-04-15)*

Workplace requirement Time given to resolve

3.H Where identified as necessary to reduce residual risk, provide (without charge to workers) and 30 days
ensure the use of appropriate personal protective equipment (PPE).
Verification method
Issue title Desktop audit
278 - Personal Protective Equipment (PPE) provided but incidents of workers not using PPE where
appropriate Area of non-compliance/non-
conformance
Description Local law
During the current assessment, it was noted through plant tour that 15% cutting & sewing section Base code
worker not using dust mask & headcover while working in cutting & sewing section in production
building, where a notable amount of dust was observed floating in the air in the mentioned areas.
Moreover 01 out of 01 canteen boy not using required PPE (Gloves, mask, head cover etc.) while
working in canteen.

Corrective and preventative actions

It is recommended that facility should ensure workers are using all required PPE as per
requirement.

Local law reference

In accordance with Bangladesh Labor Rules, 2015, Rule 67(2): The arrangement of safety and
health protection measures mentioned in Sub-section (1), the concerned manufacturing institute
must provide necessary equipment’s, including safety shoes, helmets, goggles, masks, hand
gloves, ear muffs, ear plugs, waist belts, aprons etc. and arrange training programs for the
workers in using these materials.

Evidence
Worker not using head cover.JPG
Worker not using face mask.JPG
Canteen boy not using required PPE.JPG

* PDF generated at 04:50 (UTC) on 06 May 2025. View this finding on the Sedex platform for live updates and closure details.

ZAF600826330 Due 2025-04-01

Code area Status

3 Working conditions are safe and hygienic Closed (2025-04-15)*

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Workplace requirement Time given to resolve
3.M Ensure all machinery is installed, maintained, and used in a safe manner. 30 days

Issue title Verification method

264 - Machines lack appropriate safety guards (e.g. eye or needle guards on sewing machines, Desktop audit
belt/hand guards on other machines)
Area of non-compliance/non-
Description conformance
During this current assessment, it was noted that 15% needle guard of sewing machine were Local law
found in displaced condition from actual position. Thus, the existing displaced needle guards will Base code
not protect workers from injury.

Corrective and preventative actions

It is recommended that factory management shall ensure that needle guard of sewing machines
in proper place.

Local law reference

In accordance with Bangladesh Labor Law 2006, section-63(1), [In every establishment the
following shall be securely fenced by the safeguards of substantial construction which shall be
kept in a position while the part of machinery required to be fenced are in motion or in use,
namely-(a) every moving part of a prime move, and every flywheel connected to a prime
mover;(b) the headrace and tailrace of every water wheel and water turbine;(c) any part of a stock-
bar which projects beyond the headstock of a lathe; and(d) unless they are in such position or of
such construction as to be as safe to every person employed in the factory as they would be if
they were securely fenced (i) every part of an electric generator, a motor or rotary converter;(ii)
every part of transmission machinery; and(iii) every dangerous part of any machinery ]

Evidence
Needle guard found displaced.JPG

* PDF generated at 04:50 (UTC) on 06 May 2025. View this finding on the Sedex platform for live updates and closure details.

ZAF600826331 Due 2025-04-01

Code area Status

10.A Environment 2-Pillar Closed (2025-05-06)*

Workplace requirement Time given to resolve

10.A.B Comply with relevant local, regional and national laws or regulations, and have the correct 30 days
documentation or permits, including for resource use (e.g. water, energy, material) and waste
disposal. Verification method
Desktop audit
Issue title
606 - Environmental certifications or environmental management systems documentation were Area of non-compliance/non-
not available to review conformance
Local law
Description
Base code
During current assessment, it was noted that factory did not have valid environmental clearance
certificate for captive power plant (CPP) which was expired on 30 December 2024. However,
factory management has applied on 05 December 2024 and still waiting to receive the renewed
certificate.

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Corrective and preventative actions
It is recommended that facility shall obtain the environment clearance certificate from the
concern authority.

Local law reference

In accordance with the condition #6.3 of the Captive Power Plant (CPP) license provided by
“Bangladesh Energy Regulatory Commission”, factory should collect environment clearance
certificate for the Captive power plant from Department of Environment (DOE).

Evidence
Environmental clearance certificate for captive power plant (CPP) which was expired.jpg

* PDF generated at 04:50 (UTC) on 06 May 2025. View this finding on the Sedex platform for live updates and closure details.

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Findings: good examples
No good examples

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Management systems

Policies and Communication

Resources Monitoring
procedures and training

1. Employment is freely chosen

1.A. Responsible recruitment and

entitlement to work

2. Freedom of association and right to

collective bargaining are respected

3. Working conditions are safe and

hygienic

4. Child labour shall not be used

5. Legal wages are paid

6. Working hours are not excessive

7. No discrimination is practiced

8. Regular employment is provided

Not addressed

Fundamental improvements required

Some improvements recommended

Robust management systems

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 Policies and Communication
Resources Monitoring
procedures and training

8.A. Sub-contracting and homeworkers

are used responsibly

9. No harsh or inhumane treatment is

allowed

10.A. Environment 2-Pillar

10.C. Business ethics

Not addressed

Fundamental improvements required

Some improvements recommended

Robust management systems

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 Guidance

The Corrective Action Plan Report summarises the site audit findings and a
corrective, and preventative action plan that both the auditor and the site
manager believe is reasonable to ensure conformity with the ETI Base Code,
Local Laws and additional audited requirements. After the initial audit, the form is
used to re-record actions taken and to categorise the status of the non-
compliances/ non-conformances.

Good practice examples should be pointed out at the closing meeting as well as
discussing non-compliances/ non-conformances and corrective actions,
Collaborative Action Required findings and the Management Systems
Assessment.

Next steps:
The site shall request, via Sedex, that the audit body upload the audit report,
NCs, CARs, MSA and good examples. If you have not already received
instructions on how to do this then please visit the Sedex Members’ E-
learning Platform
Sites shall action its NCs and document its progress via Sedex
Once the site has effectively progressed through its actions then it shall
request that the audit body verify its actions. Please visit Sedex Members’ E-
learning Platform for information on how to do this
The audit body shall verify corrective actions taken by the site by either a
"Desk-Top” review process via the Sedex Platform or by Follow-up Audit
Some NCs that cannot be closed off by “Desk-Top” review may need to be
closed off via a “Follow Up Audit” charged at normal fee rates. If this is the
case, then the site will be notified after its submission of documentary
evidence relating to that NC. Any follow-up audit must take place within
twelve months of the previous initial/periodic audit and the information from
the previous audit must be available for sign off of corrective action
For changes to wages and hours to be correctly verified it will normally require
a follow up site visit. Auditors will generally require to see a minimum of two
months wages and hours records, showing new rates in order to confirm
changes (note some clients may ask for a longer period, if in doubt please
check with the client)
The site shall develop and share with Sedex an action plan to work on CAR
findings, and take actions to work on these areas as identified.

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 The site should use the MSA gradings to help to improve internal systems,
focusing where their systems are weakest and the risks of harm are highest.
These actions should better prepare them for future audits and help sustain
compliance.

Management Systems Assessment (MSA)

A management system is defined as a comprehensive framework comprising of
processes, policies, procedures, and tools that are strategically designed and
implemented within a business to plan, organise, execute, monitor, and
continuously improve its activities. Management systems are the systems that
underpin how a company runs its day-to-day operations, makes decisions, and
helps avoid the recurrence of common problems. 

Where management systems are weak a site is at higher risk of non-compliance

over time, the SMETA MSA can help sites to proactively reduce the likelihood of
risks occurring. Sites should take actions commensurate with their size and
resources, focusing on where their systems are weakest and the likelihood of
risks is highest, based on their sector, location and workforce profile.  

The MSA Grades do not result in NCs, and will not be re-assessed in follow-up
audits. 

For more information on Management Systems please refer to the Management

Systems Workbooks.

Collaborative Action Required

The SMETA Workplace Requirements identify certain specific issues where a site
may not meet the Base Code, but the usual mechanisms of NC verification and
closure are not appropriate, for some or all of the following reasons;
The audited party does not have the capacity/ responsibility to close the issue
without support from other relevant stakeholders, such as commercial
partners/buyers.
Remediation of the issue requires an indeterminate and possibly extended
timeframe, rather than a predetermined deadline as set within the Sedex
platform.
There is a risk of adverse consequences if closure of a particular issue is not
approached with due consideration and time provided for adequate risk
assessment.
Evidencing effective remediation is complex and it is outside the capacity of
existing SMETA methodology to validate through evidence provided during an
onsite assessment alone.

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 These specific WRs have a Collaborative Action Required (CAR) finding raised
against them. 

Collaborative Action Required findings require a different way of working from

other NCs for buyer and supplier members. The activities required to close these
issues may involve actions from both buyers and suppliers, as well as additional
stakeholders such as third-party labour providers, impacted workers, local NGOs,
and trade unions. Due to the complexity of the issues and the spectrum of
potential stakeholders that may need to act, CARs may need long-term closure
plans, potentially spanning multiple years. To facilitate a longer-term approach
and to reduce the likelihood of undue pressure on suppliers to close issues that
may be out of their control, Sedex does not prescribe a closure date nor a
verification methodology for these findings. Sedex encourages all its members to
work collaboratively and responsibly on these issue areas, sharing
responsibilities and actions as appropriate.  

When developing a methodology to prioritise action on these more complex

areas, Sedex recommends following a due diligence process and prioritising
activities based on the most salient risks.

For Suppliers

Where CARs are raised suppliers should create an action plan for how they are
going to address these areas. Sedex also recommends suppliers reach out to
their buying partners to understand their expectations on these issues and start
a constructive dialogue. The action plans can be uploaded on to the Sedex
platform, which will change the status of the CAR finding from “open” to “in
progress”. Management and assessment of action plans is encouraged as an
activity between linked buyer and supplier members.

For Buyers

Where CARs are raised buyer members should prioritise resolution of these
issues based on a salient risk approach. Buyers should assess their own roles
and responsibilities in the closure of these findings, especially considering any
increased financial costs and how these may relate to the buyers own purchasing
practices. Buyers should work with suppliers to ensure that closure plans are
realistic, taking a long-term approach to improvement where it is necessary, and
working with multi-stakeholder initiatives, NGOs, Trade Unions and other third
parties to address these issues, which may be widespread. In the interests of
enabling transparency, collaboration and long-term effective remediation, the
application of commercial penalty against suppliers where these issues are
identified and action plans are in place is not encouraged.

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 For Auditors

Auditors will assess whether the CARs are met through the SMETA audit process
and raise the findings where relevant. Auditors will not assess the action plans
shared or provide guidance on closure methodology, due to the limitations of
assessing scope and responsibilities through a supplier site assessment alone.
CAR findings will be superseded and closed in periodic audits. The auditor will
assess the Workplace Requirements anew and raise a CAR in following audits
until there is no longer a finding to raise.

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 For more information visit https://www.sedex.com

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