Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

Factory name Representative Supplier name Principal name Audit company Type of audit

Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit

Factory location Position Products Principal location Audit date-s Time of arrival on site / leaving Critical violation-s

Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 9:30 am / 5:50 pm No

This Corrective Action Plan summarizes the critical violations (rated D in the completed Audit Questionnaire) and non-conformities (rated C). These findings are valid for the site / date-s covered by the audit and is subject to the limited number of interviews and documentary checks imposed by time constraints, as well as the accuracy of data and information provided by the factory. This Corrective Action Plan must be fulfilled with all findings clearly described, target date needs to be always reported (pendingmention or blank are not acceptable and need to be use for specific reason only). This Corrective Action Plan is the basis for the audit closing meeting with the factory management. It should be issued in the local language, signed by the factory management representative and the lead auditor and a copy given to the factory representative. If the factory management cannot make an immediate commitment to a corrective action and/or target date, the reasons invoked should be indicated by the auditor under Comments of factory representative. Corr ActionPlan ICS / 04/2011

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

The duly signed Corrective Action Plan in the local language as well as the typed, English translation one must be sent to the principal together with the other reporting documents. The principal who ordered this audit may reconsider some reported conclusions and corrective actions and pursue their implementation directly with the factory, as appropriate. The principal can return the Corrective Action Plan with his confirmation / comments as appropriate. Reliable and sustainable implementations of corrective actions are crucial for the continual improvements.

SECTION TITLE/NO

CRITICAL VIOLATION and / or NON CONFORMITY

RECOMMENDED

TARGET DATES RESPONSIBLE

COMMENTS OF FACTORY

CONFIRMATION and / or COMMENTS OF PRINCIPAL

CORRECTIVE ACTION

REPRESENTATIVE

Health & Safety / 8.14

In accordance with ICS code of conduct factory should

maintained accident/ injury/ sickness register maintained for the last two years.
Based from the documents review it was noted that facility is not maintaining accident / injury / sickness register for the last two years. Facility provided only one year records.

To conform to ICS Code of Conduct it is recommended that the facility should retain and provide 2 years injury records.

Mr. Abdul Ahad / Quality & Compliance

We will maintain 2 years injuries records from now on to comply with clients requirement.

Corr ActionPlan ICS / 04/2011

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

Health & Safety / 8.21

In accordance with ICS Code of Conduct Health & Safety 1. Suppliers shall provide safe and clean conditions in all work and residential facilities and shall establish and follow a clear set of procedures regulating occupational health and safety. Based from the documents review, the facility has devel-

To conform to ICS Code of Conduct it is recommended that the facility should develop an effective system of monitoring.

Mr. Abdul Ahad / Quality & Compliance

We have job description for our staff; we will incorporate and will develop a procedure within 1 month as per client requirement.

oped an organizational chart which describes the position and responsibilities of all representatives are not defined. No documentation
provided by the facility that in absence of the senior/first person, no other person is responsible for compliance and health & safety. Health & Safety / 8.27 In accordance with ICS Code of Conduct Health & Safety 1. Suppliers shall provide safe and clean conditions in all C To conform to ICS Code of Conduct it is recommended that the facility should develop and maintain Mr. Abdul Ahad / Quality & Compliance We will enhance the procedure and include these points as per client

Corr ActionPlan ICS / 04/2011

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

work and residential facilities and shall establish and follow a clear set of procedures regulating occupational health and safety. Based from the documents review and management interview, the facility has training records for fire safety but records do not provide the duties of fire fighting team and evacuation of employees to safe place/ assembly area in case of any emergency. Facility has posted photos of fire fighting team for easy identification. In accordance with ICS Code of Conduct Health & Safety 1. Suppliers shall provide safe and clean conditions in all work and residential facilities and shall establish and follow a clear set of procedures regulating occupational health

procedure including description of staff duties, fire wardens, use of equipment guiding occupants to safe places. Facility should also post fire fighting team photos on production floors for easy identification.

requirement.

Health & Safety / 8.40

To conform to local law, it is recommended that the facility should provide emergency exit doors opening in running direction.

Mr. Abdul Ahad / Quality & Compliance

We will open it outwards within 1 months.

Corr ActionPlan ICS / 04/2011

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

and safety. Based from the facility tour it was noted that one emergency exit door was found sliding type in stock area (warehouse) on ground floor block-2. In accordance with ICS Code of Conduct Health & Safety 1. Suppliers shall provide safe and clean conditions in all work and residential facilities and shall establish and follow a clear set of procedures regulating occupational health and safety. Based from the facility tour it was noted that one emergency exit staircase was found spiral type on first floor block-1. In accordance with ICS Code of Conduct Health & Safety 1. Suppliers shall provide safe and clean conditions in all

Health & Safety / 8.42

To conform to ICS Code of Conduct, it is recommended that the facility should provide emergency staircase without spiral case.

Mr. Abdul Ahad / Quality & Compliance

We will not aware with this requirement. We will check it with the client and will take appropriate action accordingly.

Health & Safety / 8.51

To conform to ICS Code of Conduct, it is recommended that the facility should provide all windows in the

Mr. Abdul Ahad / Quality & Compliance

We were not informed with this requirement from client and it was

Corr ActionPlan ICS / 04/2011

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

work and residential facilities and shall establish and follow a clear set of procedures regulating occupational health and safety. Based from the facility tour it was noted that windows provided in knitting halls and in office area near knitting were found with fixed glass. Facility has provided wooden hammer to break the window in case of any emergency. In accordance with the Pakistan Environmental Protection Act 1997 Section 11 prohibition of certain discharges or emission no person shall discharge or emit or allow the discharge or emission of any effluent or waste or air pollutant or noise in an amount concentration or level which is in excess of the National Environmental Quality

facility with internal release system.

not raised before in any audit. We will check without client and will proceed accordingly.

Health & Safety / 8.63

To conform to local law, it is recommended that the facility should comply with the requirements of Environmental Protection Act and conduct monitoring of its gaseous emission as required by law.

Mr. Abdul Ahad / Quality & Compliance

We will start to conduct monitoring as per law.

Corr ActionPlan ICS / 04/2011

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

Standards (NEQS). In accordance with SRO 528(1)/2001 Category B, Monitoring Gaseous Emission, Industrial units should submit gaseous emission monitoring report on quarterly basis. Based from the documentation review, it was noted the facility does not conduct monitoring of its gaseous emission of generator and boiler on regular basis as required by law. Last monitoring conducted on 8 January 2013. Health & In accordance with Factories Safety / 8.65 Act 1934 Chapter III Health & Safety, Section 33-A Hoist & Lifts (1) In every factory - (e) every gate referred to in clause (b) or clause (d) shall be fitted with interlocking or other efficient device to secure that the gate cannot be opened except when the cage is at the Corr ActionPlan ICS / 04/2011

To conform to local law, it is recommended that facility should provide proper fencing or other suitable safe guards to the cargo lift to prevent employees from falling hazard.

Mr. Abdul Ahad / Quality & Compliance

We will do it within 1 month.

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

landing and that the cage cannot be moved unless the gate is closed. Based from the facility tour, the interlocking system was not working in 2 out of 1 cargo lift. One cargo lift was found out of order on the day of audit. In accordance with the Factories Act 1934, Chapter III, Health & Safety, Section 31, Casing of New Machinery (1) in all machinery driven by power and installed in any factory after the commencement of the Labor Laws (Amendment) Ordinance 1972 (a) every set screw, belt or key on any revolving shaft, spindle, wheel or pinion shall be so sunk, encased or otherwise effectively guarded as to prevent danger.

Health & Safety / 8.68

To conform to local law, it is recommended that facility should provide emergency switches to all highlighted machineries.

Mr. Abdul Ahad / Quality & Compliance

We will provide emergency switches to washing machines and hydro extractor. But it is not workable to provide switches to dryer. We will provide complete analysis report to client.

Corr ActionPlan ICS / 04/2011

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

Health & Safety / 8.69

Based from the facility tour, it was noted that 3 out 7 washing machines, 3 out of 3 hydro extractor, 6 out of 6 dryer machines were found without emergency switches since machines were found rotating while their doors were open. In accordance with ICS re- C quirements, workers shall be specifically trained regarding risk of accidents at their workplace. Based from the documents and employees review interview employees were not trained regarding risk of accidents at their workplace. As per facility management, they provide trainings but do not maintain records. 1) In accordance with the Pakistan Environmental Protection Act 1997 section 11 prohibition of certain

To conform to local law, it is recommended that the facility should provide training to it employees regarding risk of accidents at their workplace.

Mr. Abdul Ahad / Quality & Compliance

We conduct trainings and will also maintain records within end of November 2013.

Health & Safety / 8.70

To conform to local law, it is recommended that the facility should to conduct monitoring of its effluent on

Mr. Abdul Ahad / Quality & Compliance

We will start to conduct monitoring as per law.

Corr ActionPlan ICS / 04/2011

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

discharges or emission no person shall discharge or emit or allow the discharge or emission of any effluent or waste or air pollutant or noise in an amount concentration or level which is in excess of the National Environmental Quality Standards (NEQS). In accordance with SRO 528(1)/2001 Category A, Monitoring Liquid Effluent, Industrial units should submit liquid effluent monitoring report on monthly basis. Based from the documents review, it was noted that facility does not conduct monitoring of its liquid effluent on as required by law. Last monitoring conducted on 8 January 2013. 2) In accordance with ICS Code of Conduct Health &

regular basis as required by law.

To conform to local law, it is recommended that the

Mr. Ahad

Abdul /

We will provide secondary

Corr ActionPlan ICS / 04/2011

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

Safety 1. Suppliers shall provide safe and clean conditions in all work and residential facilities and shall establish and follow a clear set of procedures regulating occupational health and safety. Based from the facility tour it was noted that no secondary containment was provided to chemicals in chemical store and to diesel in generator area. 3) In accordance with the Environmental Pakistan Protection Act 1997 section 11 prohibition of certain discharges or emission no person shall discharge or emit or allow the discharge or emission of any effluent or waste or air pollutant or noise in an amount concentration or level which is in excess of the Corr ActionPlan ICS / 04/2011 C

facility should provide secondary containment to chemicals and diesel drums.

Quality & Compliance

containment to chemicals and diesel in 2 months.

To conform to local law, it is recommended that the facility should make some arrangement to treat effluent water before being discharge to the general drain.

Mr. Abdul Ahad / Quality & Compliance

It is in our plan to build ETP in near future. We will start to conduct effluent monitoring as per law and will take necessary actions.

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

National Environmental Quality Standards (NEQS). Based from the facility tour it was noted that facility is discharging its effluent directly into general drain without any monitoring. 4) In accordance with Pakistan Environmental Protection Act 1997, Section 14, Handling of Hazardous Substances, no person shall generate, collect, consign, transport, read, dispose off, store, handle or import any hazardous substance except; (a) under a license issued by the Federal Agency and in such manner be prescribed. Based from the documents review, it was noted that facility is not disposing its hazardous waste to license contractors. Corr ActionPlan ICS / 04/2011 C To conform to local law, it is recommended that the facility should dispose its hazardous waste through licensed contractor. Mr. Abdul Ahad / Quality & Compliance We will make contract with hazardous waste license contractor by the end of December 2013.

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

Health & In accordance with ICS Code Safety / 8.73 of Conduct Health & Safety 1. Suppliers shall provide safe and clean conditions in all work and residential facilities and shall establish and follow a clear set of procedures regulating occupational health and safety.

To conform to local law, it is recommended that the facility should post MSDS to diesel.

Mr. Abdul Ahad / Quality & Compliance

We will post it within one week.

Based from the facility tour and management interview, it was noted that no MSDS for diesel was provided in generator area.
Health & Safety / 8.83 In accordance with the Sind Factories Rules 1975 provision of shelter during rest the occupier of every wherein factory workers are ordinarily employed, shall provide free of cost rooms for use of workers during period of rest. Based from the facility tout it Corr ActionPlan ICS / 04/2011 C To conform to local law, it is recommended that the facility should provide rest area for employees. more than 150 Mr. Abdul Ahad / Quality & Compliance We will provide it within 4 months.

Corrective action plan

Factory name Representative Supplier name Principal name Audit company Type of audit Keystone Enterprises Mr. Abdul Ahad Keystone Enterprises Carrefour Intertek Pakistan Initial Audit Factory location Position Products Principal location Audit date-s Critical violation-s Pakistan Quality & Compliance Manager Socks Pakistan 22 October 2013 No

was noted that facility did not provide any rest area for 225 employees. A closing meeting has been undertaken and corrective actions were discussed and agreed:
AUDITOR NAME: MIRZA GOHAR BAIG FACTORY REPRESENTATIVE NAME : MR. ABDUL AHAD POSITION: QUALITY & COMPLIANCE MANAGER PRINCIPAL REPRESENTATIVE: NIL

SIGNATURE

SIGNATURE

SIGNATURE

DATE: 22 OCTOBER 2013

DATE: 22 OCTOBER 2013

DATE: 22 OCTOBER 2013

LENGTH OF THE CLOSING MEETING : 45 MINUTES

Corr ActionPlan ICS / 04/2011