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SA8000 Introduction & Basic Auditor Training 2012

Social Accountability International 2012

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Learning Objectives
Describe basic auditor attitude, skills and knowledge Describe how to plan and conduct a management-system based social audit Describe the fundamentals about the management system approach Describe the SA8000 principles, its origin, intent, and its relationship to other codes and standards Describe the role and responsibilities of the auditor Describe the structure of the certification system

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Course Structure
Five Days Sections: Certification and the process of continual improvement The planning and conduct of a social system audit The management systems approach to control Audit Process and Auditor Tools Objective evidence and its role in the process SA8000 Principles and associated requisites Field application of SA8000 requirements Exam Format: Short answer fill-in, true-false, and multiple choice Open book exam Passing grade 75%
Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Learning Methods
Formal presentation lecture Group exercises Case studies Virtual tours of certified facilities Real time interactive with tutor

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Trainer Introductions Who We Are Our Background Lead Trainer Qualification process

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Student Introductions
Name Job title/responsibility Knowledge of SA8000 and social auditing Reason for attending course 45 second time allowance

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Class Rules
Turn off cell phone Comfort breaks as needed Safety considerations Complaints and concerns No smoking Be on time

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Day 1 Agenda
Introduction to SA8000 Introduction to Auditor Competencies What Makes a Good Auditor? Introduction to Management Systems Social Compliance Initiatives Auditor Competencies Auditing for Social Management Systems

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Introduction To SA8000

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000
SA8000 was developed in 1997 by Social Accountability International (SAI) as a best practice labor standard. It covers 8 labor standards as outlined by the International Labor Organization (ILO) the Universal Declaration of Human Rights (UDHR) and other International Conventions.

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

The SA8000 Standard


Child Labor Forced Labor Health & Safety Freedom of Association Discrimination Disciplinary Practices Working Hours Remuneration
Management System Child labor shall not be used People have the right to change jobs and shall not be forced to work People must not be endangered at work People have the right to organize and be heard at work through collective bargaining Hiring, promotions and wages must be equal and fair People must not be abused at work and free from all corporal punishment Overtime is limited, voluntary and paid at a premium People must earn enough to live on during a regular work week A management system is the key to managing ongoing compliance, including requirement for a worker representative

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Comparison of National Labor Laws & Standards


Issue
Working hours in Thailand

SA8000
12 hours overtime allowed per week, in peak periods Overtime hours paid at a premium Overtime hours paid at a premium

National Labor Law


36 hours overtime per week allowed

SA8000 versus labor law most favorable to the worker applies.

Overtime wages in Hong Kong Morocco

No premium wage required Hour averaging allowed

Child labor in Turkey & Brazil

No work for children under 15

Apprentice programs allow child labor

Migrant labor in Malaysia

Personnel should not be required to lodge identity papers

Companies allowed to hold passports

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Law of Unintended Consequences


Most codes of conduct impose compliance with local regulations on suppliers as a contractual condition: Unforeseen consequences:
Laws in Thailand allow up to 36 overtime hours per week so workers can earn more money Some National laws allow retention of migrant workers passports for purposes of control Some National laws allow monthly hour averaging which will not assure that overtime hours are paid at premium rate Many countries have laws which require discrimination Some countries outlaw labor unions

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

The Element Requirements Overview

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Child Labor Standard


The company shall not engage in the use of child labor. The company will provide for remediation of children found to be working below legal age and shall provide financial support for such children in attending school. The company shall promote the education of children and young workers. The company shall not expose children or young workers to situations that are hazardous, unsafe, or unhealthy.

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Forced Labor Standard


Company shall not engage in or support use of forced or compulsory labor Company shall not engage in or support human trafficking Personnel shall not be required to lodge deposits or identity papers upon commencing employment or as a condition of continued employment Personnel shall have the right to leave the premises after completing the standard workday Personnel shall have the right to terminate their employment after giving reasonable notice

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Health and Safety Standard


Company shall provide for a safe and healthy work environment A senior management representative shall be appointed and accountable for implementation (if appropriate) Company shall ensure that all employees receive regular and recorded safety training (annually or based upon need) Company shall establish methods to detect, avoid and respond to threats to health and safety of workers (preventive action) Company shall provide clean bathrooms and access to potable water and adequate food storage If provided, dormitories shall be clean, safe, and meet basic needs Company shall maintain written records of all accidents Company shall provide at its expense personal protective equipment Company shall address special risks to new and expectant mothers Company shall provide first aid and assist the worker to obtain follow-up medical treatment for work related injuries

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Freedom of Association Standard


The company shall effectively inform personnel that they are free to join an organization of their choosing and that doing so will not result in retaliation The company shall respect the workers right to form and join trade unions and to bargain collectively When these rights are restricted by law, the company shall allow workers to freely elect their own representatives Company shall ensure that representatives of workers and any personnel engaged in organizing workers have access to members and are not subject to discrimination

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Discrimination Standard


The company shall not engage in, or support, discrimination in hiring, remuneration, access to training, promotion, termination or retirement based on race, caste, birth, national or social origin, family responsibilities, marital status, religion, disability, gender, sexual orientation, union membership, political opinions, age Company will not interfere with personnels rights to observe practices or meet needs related to the above list Company shall not allow any behavior that is threatening, abusive, exploitative or sexually coercive Company shall not subject personnel to pregnancy or virginity tests

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Discipline Standard


The company shall treat all personnel with dignity and respect The company shall not use:
corporal punishment mental or physical coercion verbal abuse harsh or inhumane treatment

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

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SA8000 Working Hours Standard


The company shall comply with applicable laws and industry standards on working hours and public holidays The normal work week, not including overtime, shall be defined by law but shall not exceed 48 hours Personnel shall receive at least one day off following every six consecutive days of working, with exceptions only where national law and a freely negotiated collective bargaining agreement allows All overtime work shall be voluntary (with the exception below), shall not exceed 12 hours per week, and shall not be on a regular basis Companies may require non-voluntary overtime work only when there is short term demand AND there is a collective bargaining agreement in place

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Remuneration Standard


Wages should be sufficient to meet basic needs and provide discretionary income Deductions shall not be made for disciplinary purposes except where allowable by national law and collective bargaining agreement All wages and benefits shall be clearly written and detailed for all workers All overtime shall be paid at a premium rate as defined by national law or collective bargaining agreement, or if none in place, at prevailing industry standard Labor-only contracting arrangements, consecutive short-term contracts and false apprenticeship schemes shall not be used to avoid remuneration obligations

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

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Break
15 minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Introduction to Management Systems

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

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Management System Elements


Management system for oversight to ensure stability and effectiveness through ongoing evaluation and analysis of compliance process Internal audits to evaluate system effectiveness and to provide input to management review for development of corrective action Corrective action system to address root causes and for effective remediation of identified weaknesses in the management system

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Management System Requirements


Senior management shall direct the implementation of SA8000 Standard and conduct periodic reviews of performance. Policies must:
be clearly documented and communicated to all personnel be accessible and comprehensible to all personnel be understood and implemented at all levels

The company shall establish procedures for engagement with all stakeholders The company shall appoint a management representative responsible for implementing SA8000 Workers shall be allowed to elect an SA8000 worker representative. In unionized facilities, the union will have the responsibility for this function.

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SA8000 Management System (continued)


The SA8000 Guidance Document is the official interpretative guidance for implementing SA8000 as well as FAQs The company shall provide a confidential means for all personnel to report non-conformances risk free. The company shall take preventive as well as corrective actions as necessary. The company shall allow access to its premises for the purposes of auditing. The company shall maintain proper documentation. The company shall monitor the social compliance of its suppliers, sub-contractors and sub-suppliers.

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

The Triangle of Control

Corrective Actions

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Plan Do Check Act


PLAN

ACT

MONITOR

DO

CHECK
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Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Management Systems Components


Policy Management Representative SA8000 Worker Representative Management Review Planning & Implementation Control of Suppliers, Sub-contractors and Sub-suppliers Corrective Action Response to Concerns of Employees Outside Communication and Stakeholder Engagement Access for Verification Records

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SA8000 Control of Sub-Contractors Standard


The Supplier Shall: Establish and maintain appropriate procedures to select subcontractors on their ability to meet the requirements of the standard Maintain appropriate records of a sub-contractors ability to meet the standard and evidence of their doing so Provide home-workers with a similar level of protection as that of directly employed personnel

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Lunch
60 Minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

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Managing Change and Social Balance

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Managing Change
Social issues are never fixed but managed Two stage process - discovery and resolution Corrective actions taken by client will not be dictated by auditor but must be accepted passive control System must be kept in balance over life of contract Judicious use of Non-conformance Report (NCR) is key to controlling compliance with system requirements Auditor must judge severity of lack of compliance to manage time allowed for resolution

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Root Causes of Non-Conformance


Competence and Attitude

Organizational Design

Lack of Communication

Ineffective Training

Lack of Accountability

Lack of Resources and Time

Shadow Systems

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Finding The Balance


Discrepancy between laws and standard elements
Whichever is in the best interest of the worker Should not violate the local or national laws

Maintaining a social issue balance of all issues


Problems are never fixed long term Chronic problems must be managed over time to improve

Finding opportunities and setting expectations


Client often not aware of expectations Client needs guidance for continual improvement

Auditor must manage account over life cycle

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Two Dimensions of a the Social Audit


One - Discovery
The auditor must identify non conforming issues using records and documents, interviews both internally and externally and personal observation

Two So What?
Auditor must decide level of acceptance Auditor must define expectations Auditor must manage process through continual improvement without consulting Above all, what will be done and when?

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Shades of Gray

Auditors must interpret situations within the context of the complete management system and not treat them as isolated events. Assign the level or grade of non conformity which attains the goal of compliance in an acceptable time frame as determined by the auditor Base decisions on: SA8000 standard requirements Laws and international norms Input from external and internal sources Industry/sector knowledge Experience Personal values and bias Facts

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Non-Conformance Report (NCR)


Formal documentation describing the finding and requiring a corrective action plan
States auditors finding related to the failures to meet SA8000 requirements Classifies finding as Major, Minor or Observation An NCR may be written for one finding or a group of findings in a similar category, e.g., health and safety

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Major vs. Minor Non-conformances


The use of Major and Minor NCRs
Major NCR Absence or breakdown in system to meet requirement Degree of risk to workers rights or safety as determined by auditor is high Degree of control exerted by management to ensure compliance is low and ineffective Company may not be certified unless the Major NCR is closed out Minor Oversight or non-systemic problem, often an oversight A one off to a requirement as determined by the auditor A Minor non conformity will not prevent certification Observations non binding and aimed at value added
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Clients Understanding of NCRs


Setting the stage with the client
NCRs are opportunities to improve they are the tools to identify weaknesses in the operation and are what the company is essentially paying for. Must not be blame based which will create defensive behavior NCRs are tools to manage continual improvement in a controlled manner Refrain from using attack words such as violation and the pronoun you as they create a barrier between the client and the audit team. The certification process is a service which is designed to improve the workplace and the company.
Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Using NCRs for Improvement


Auditors use Majors to highlight problems demanding immediate attention and will defer certification until resolution achieved Auditors can use Minor NCRs as a tool to encourage continual improvement With a Minor non conformance the company may be certified or, if certified, retain certification if the auditor sees significant improvement and a plan for goal attainment Key ongoing problem areas which often require extended periods to resolve:

Working hours Remuneration Control of suppliers Discrimination

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

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Break
15 minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Social Compliance Initiatives And Certification

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Corporate Codes
To reduce risk, leading companies established social codes of conduct for their suppliers
Corporate codes have varying levels of labor compliance Suppliers frustrated with numerous corporate codes and disparate requirements

Virtually all corporate codes address the same core ILO conventions although such codes do not address living wage. Rather they stipulate that the supplier must conform with local wage regulations.

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Perspective: Corporate Codes


Powerful Company
Company Code of Conduct

SUPPLIER 1 SUPPLIER 2 SUPPLIER 3 SUPPLIER 4 SUPPLIER 5

SUPPLIER 6

SUPPLIER 7

SUPPLIER 8

SUPPLIER 9

SUPPLIER 10

SUPPLIER 11

SUPPLIER 12

SUPPLIER 13

SUPPLIER 14

SUPPLIER 15

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Suppliers Perspective: Corporate Codes


BRAND
Accessories

BRAND
Accessories

BRAND
BRAND
(Footwear)

(Apparel)

BRAND
(Footwear)

BRAND
Accessories

BRAND
Accessories

BRAND (Apparel) BRAND


Accessories

SUPPLIER 1

BRAND (Apparel)

BRAND
Accessories

BRAND
(Footwear)

BRAND BRAND (Apparel)


(Footwear)

BRAND
Accessories

BRAND
Accessories

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Industry Codes
Industry codes emerging to create standards within specific industries
ICTI Toy industry EICC Electronics industry WRAP - Apparel

Industry codes may overlook difficult compliance issues specific to their industry wages, overtime, freedom of association, discrimination, etc.

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Convergence of Codes
BSCI
Alliance of 800+ European Retailers Supplier audit system uses SA8000 as Best Practice

Global Social Compliance Programme (GSCP)


Created by retailers - Wal-Mart, Carrefour, Tesco, etc. Recently joined by major brands: HP, Chiquita, etc.

ISO26000 - initially a guidance, not a standard

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Certification System


Guidance SAI

SA8000 SAAS

Training Certification Bodies Certification Bodies Facility Certification Bodies Certification Bodies Facility Facility Facility

Facility Facility

Facility Facility

Facility Facility

Facility Facility

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Characteristics
SA8000 Certification
Audit requested by applicant company Audit performed by certification body under license Management system based Regularly scheduled audits Multi-industry/ cross sectors Burden of proof on supplier to prove compliance Audit team must consult with external sources such as NGOs, trade unions, etc. SA8000 Certificate is driver

Code of Conduct
Typically ordered by brand Audit performed by brand or contracted third party Management system being increasingly adopted Audits typically are not announced to provide element of surprise Some audits seen as hostile by factories Audit often done at time of order placement Auditors typically complete report and move to next job. Little continuity. Purchase order is driver

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Closed Assessment Systems 1st Party Assessment


Brand or Supplier Brand Audits itself Internal Audit Brand audits supplier directly using staff or indirectly using audit company

2nd Party Assessment


Supplier

Auditor

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Open Assessment System

3rd Party Assessment


Brand Certification Body

Supplier Brand

Independent Verification & Certification often at request of Brand


Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Brand

Three Year Audit Cycle


Certification Audit
Covers all elements of SA8000
Number of days dependent upon number of workers, sector and risk levels

Surveillance Audit
Partial Coverage

Unannounced

Surveillance Audit
Partial Coverage

Surveillance Audit
Partial Coverage

Surveillance Audit
Partial Coverage

Surveillance Audit
Partial Coverage

Every six months

Recertification Audit
After 3 Years
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End of Day Quiz


15 Minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Questions and Answers


15 Minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

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Day 2

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Review of Day 1 and Photo Tour

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SA8000 Element Child Labor

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Child Labor Standard


The company shall not engage in the use of child labor. The company will provide for remediation of children found to be working below legal age and shall provide financial support for such children in attending school. The company shall promote the education of children and young workers. The company shall not expose children or young workers to situations that are hazardous, unsafe, or unhealthy.

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Child Labor: Guiding Principles


Child labor is never allowed. Young workers may be employed, but must be granted special protection:
No night work Maximum of 10 hours per day for work, school and transportation Maximum of 8 hours per day working Can only work outside of school hours if subject to compulsory education laws

Child is defined as anyone less than 15 or the local legal school or working age if higher. Young workers are between the minimum working age as defined above and 18.

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Child Labor: What the Auditor Looks For


Interviews
Children Workers Trade Unions and NGOs

Policy Visual Pay records Medical records Birth certificate or ID Schooling effectiveness
Child interview Records

Cambodia - Courtesy of Jon Warren

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Common Non-conformances
Apprentice programs permitting children to work growing in some countries to alleviate socio-economic problems Child labor policy not effectively communicated to workers and interested parties Lack of procedures to verify age such as:
National ID card School records Birth certificate Family book Medical records

No remediation plan in place as not seen as necessary No specific procedures to control use of children and assure proper protection within allowable guidelines

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Corrective Actions What Would You Accept?


Develop a remediation plan which would cover what company would do in the eventuality that children were employed. Engage with local stakeholders to develop proactive plans to address child labor issues If found, provide education and compensatory salary for children until of legal age.

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Break
15 minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Element: Forced Labor

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SA8000 Forced Labor Standard


Company shall not engage in or support use of forced or compulsory labor Company shall not engage in or support human trafficking Personnel shall not be required to lodge deposits or identity papers upon commencing employment or as a condition of continued employment Personnel shall have the right to leave the premises after completing the standard workday Personnel shall have the right to terminate their employment after giving reasonable notice

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Forced Labor: Guiding Principles

Courtesy of Dana ORourke

The right to choose your workplace The right to retain your own personal documents and money Freedom to leave the workplace after work The right to resign

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Class Group Exercise- Forced Labor


30 Minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Forced Labor: What the Auditor Looks For


Worker contracts Security guard contracts Payroll records Overtime Records Interviews
Worker Managers NGO and Trade Unions Security guards

Recruiting policies and procedures Recruiting agency contracts Hiring and termination documents

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Common Non-conformances
Company holds passport or working papers
voluntary letters of agreement not acceptable

Company does not give worker a copy of their contract


Worker may not officially exist and paid off the books

Company holds first month salary as a deposit Company requires worker to pay for job training
A company must pay for job-related training Cost versus investment mentality

Company requires worker to sign termination letter as condition of employment Company offers a personal loan that worker cannot repay Company requires worker to pay a recruiting fee
May be paid through a recruiting agency

Company requires workers to work overtime or risk loss of job

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Corrective Actions What Would You Accept?


Develop training for workers to explain their rights Pay all job related training expenses Invest in work force for stability, loyalty and reduced worker turnover Clearly define workers freedom in employment contract, including right to obtain documents if desired

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Group Exercise
Forced Labor

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Lunch
60 Minutes

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SA8000 Element- Health & Safety

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Health and Safety Standard


Company shall provide for a safe and healthy work environment A senior management representative shall be appointed and accountable for implementation (if appropriate) Company shall ensure that all employees receive regular and recorded safety training (annually or based upon need) Company shall establish methods to detect, avoid and respond to threats to health and safety of workers (preventive action) Company shall provide clean bathrooms and access to potable water and adequate food storage If provided, dormitories shall be clean, safe, and meet basic needs Company shall maintain written records of all accidents Company shall provide at its expense personal protective equipment Company shall address special risks to new and expectant mothers Company shall provide first aid and assist the worker to obtain follow-up medical treatment for work related injuries

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Guiding Principles
People must not be endangered at work Company must take all necessary precautions to mitigate work-related risks Workers must be provided proper personal protective equipment at company expense The company must assure the health and well being of expectant mothers The company is responsible for assuring the proper medical care of a worker injured in a workplace accident.

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Health & Safety: What the Auditor Looks For


Observations Worker interviews Records Accident log Ambient measurements Broken needle control log Fire Drill log First aid kit log Health and safety risk analysis Health inspection log Local inspection reports Mask filter replacement records Medical treatment records Sanitation inspection records Safety training records Medical personnel qualification records Dormitory related licenses Chemical storage and handling records

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Dormitories (on and off site)


Verify:
Space adequacy Segregated quarters Clean bathroom facilities Storage areas Fire fighting equipment Emergency evacuation plans and records Hot water availability Monthly rental fee, if any (no more than cost) Monthly deductions, e.g electricity, water Adequate exits Restricted access Sleeping items provided Proper safety signage Adequate pest extermination Fire drills conducted Cooking areas sanitary Clean toilets Potable water

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Corrective Actions What Would You Accept?


Worker committees formed to review ways in which workplace can be improved. Ongoing, periodic training programs to maintain worker focus and awareness on safety Encourage worker involvement in monitoring process for risks and opportunities for improvement. Prepare and maintain a risk analysis.

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Group Role Play- Health and Safety


60 Minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Break
15 Minutes

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SA8000 Element: Freedom of Association


Right to Collective Bargaining

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Freedom of Association Standard


The company shall effectively inform personnel that they are free to join an organization of their choosing and that doing so will not result in retaliation The company shall respect the workers right to form and join trade unions and to bargain collectively When these rights are restricted by law, the company shall allow workers to freely elect their own representatives Company shall ensure that representatives of workers and any personnel engaged in organizing workers have access to members and are not subject to discrimination

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Guiding Principles
People have the right to be heard at work, bargain collectively and organize Management should not exert influence of any kind to deter the formation of a union Management should not provide or pay for training of its workers which presents a biased viewpoint of organizing Management cannot interfere with or discriminate against workers who choose to organize Worker representatives must have access to management Workers must be allowed to meet for work related and personal issues

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Challenges to FOA
Free Trade Zone special regulations Migrant/foreign labor constraints Negative Perceptions of FOA
Governments
Union may impede investment in economy Potential obstacle to government control Global competitive disadvantage

Suppliers
Increase in wage and benefit expense Impose production constraints increasing costs Reduce competitiveness

Brands
Increase price for products Increase potential for supply disruption

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Benefits of Freedom of Association Gives workers a vehicle for collectively addressing other workplace issues (wages, hours, workplace conditions) Fosters dialogue between workers and managers Provides workers with legal recourse on workplace issues Involves workers in the production process Cultivates good industrial relations

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

FOA: What the Auditor Looks For

Worker interviews Worker representative Management review Worker meeting minutes NGO and trade union interviews Company actions taken to improve worker conditions Collective agreements

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Common Non-conformances
Management favors one union over another Workers do not have access to information or representatives Company advises workers that unions will discourage investment and reduce orders Union registration or collective bargaining is delayed Corruption or Yellow Unions Union organizers are harassed, fired or discriminated against or Blacklisted

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Corrective Actions What Would You Accept?


This issue is elusive, and there are so many variables that this is a difficult situation Ex 1: someone is terminated with extreme prejudice because they were involved in organizing activities. CA: Bring him back and give him lost wages Ex. 2: Company is paying for external training of workers on labor relations, but with an anti-union bias. CA: Company must cease and desist and provide training with a qualified group with a nonbiased point of view

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Group Role Play- Freedom of Association


60 Minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

End of Day Quiz


15 Minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

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Day 3

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Review of Day 2 and Photo Tour

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SA8000 Element: Discrimination

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Discrimination Standard


The company shall not engage in, or support, discrimination in hiring, remuneration, access to training, promotion, termination or retirement based on race, caste, birth, national or social origin, family responsibilities, marital status, religion, disability, gender, sexual orientation, union membership, political opinions, age Company will not interfere with personnels rights to observe practices or meet needs related to the above list Company shall not allow any behavior that is threatening, abusive, exploitative or sexually coercive Company shall not subject personnel to pregnancy or virginity tests

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Basis for Discrimination


Gender based Maternity Sexual harassment Job restrictions Lower pay levels Sexual orientation Union organizing Age Political affiliation Physically challenged Blind Deaf Ethnicity Race Caste Religion Nationality

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Guiding Principles
People should be hired, promoted and compensated solely based on their ability to do the job All workers should have equal access to training, tools and opportunities for advancement All workers should be free from harassment by management or other workers Positive discrimination may be allowable in cases where it protects disadvantaged or excluded groups and provides them special opportunities

Negative Denial of benefits, jobs and opportunities

Positive Designed to protect disadvantaged groups

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Defining Intent

X X

Medical Exam

Medical Exam

Used to screen workers

Used to protect workers

Denial of Job Opportunity for Women

Denial of Job Opportunity for Women

Retain job for men

Protection of women

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Discrimination: What the Auditor Looks For


Discrimination Policy Must define discrimination and work related rules Must establish goals and objectives for continual improvement Must establish communication channels with a no risk path Must provide for diversity training to sensitize workers Must be monitored periodically and incorporated into management reviews for corrective action Interviews With all personnel Records Management review Internal audits Complaints Improvement initiatives Payroll

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Common Non-conformances
Pregnancy testing to deny women employment Women denied equal benefits, pay and opportunities for promotion Manager distribution not reflective of workplace demographics Retribution for union activities Job applicant criteria based on physical characteristics Workers over a certain age not hired Workers hired or advanced based on religion or race HIV status

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Corrective Actions What Would You Accept?


Define discrimination policy for company in terms of what is and is not allowed Identify weak areas for ongoing improvement with goals and objectives Develop long term remediation plan with milestones Train workers and provide periodic updates on company initiative Establish risk free communication channels for workers to bring issues to management

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Class Group Exercise- Discrimination


30 Minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Break
15 Minutes

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SA8000 Element: Discipline

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

SA8000 Discipline Standard


The company shall treat all personnel with dignity and respect The company shall not use:
corporal punishment mental or physical coercion verbal abuse harsh or inhumane treatment

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Guiding Principles
All personnel must be treated with respect and dignity People must not be abused at work physically, verbally or mentally People must be free of all corporal punishment

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Discipline: What the Auditor Looks For Policies concerning acceptable discipline Supervisor logs, including written warnings and disciplinary actions taken Training programs and log Interviews with workers and supervisors Interviews with NGOs and trade unions

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Common Non-conformances
No clear guidelines for acceptable discipline Workers unclear about what is and is not allowed Supervisors creating their own disciplinary procedures outside of company policy Bathroom restrictions Withholding material on production line Change of job assignments to lower pay rate

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Corrective Actions What Would You Accept?


Training on company policies Establish good flow of communication between workers and managers Clearly documented policies and step-by-step procedures on allowable progressive discipline Promote employee feedback Internal surveys seeking employee input to problems and improvements Create safe communication channels for complaints

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SA8000 Element: Working Hours

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SA8000 Working Hours Standard


The company shall comply with applicable laws and industry standards on working hours and public holidays The normal work week, not including overtime, shall be defined by law but shall not exceed 48 hours Personnel shall receive at least one day off following every six consecutive days of working, with exceptions only where national law and a freely negotiated collective bargaining agreement allows All overtime work shall be voluntary (with the exception below), shall not exceed 12 hours per week, and shall not be on a regular basis Companies may require non-voluntary overtime work only when there is short term demand AND there is a collective bargaining agreement in place

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Guiding Principles
Overtime is limited, voluntary and paid at a premium Workers should make sufficient wages in a normal work week so overtime is not necessary to meet basic living needs Companies can require workers to do overtime to meet short term demand if there is a collective bargaining agreement Workers should work to live and not live to work Prevent excessive hours to protect workers from injury

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Overtime Guidelines
12 hours overtime beyond regular weekly hours is high end of overtime limit not a norm Total work hours including overtime may vary depending upon the regular work week as defined by law 12 hours per week overtime acceptable for industry peak periods Short term excessive hours OK if action plan is effective, implemented as scheduled and verified Company must demonstrate viability of plan to auditor
Specify actions to be taken Define responsibilities Establish time frame for implementation

Company must manage the overtime process ongoing Hour averaging is not acceptable

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Working Hours: What the Auditor Looks For Payroll records Pay slips Wage calculations Purchase orders and shipping documents Time sheets Production capacity calculations Worker and external interviews Contracted workers

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Common Non-conformances
Excessive hours often caused by:
Workers demand for overtime as part of contract Peak season work Short dated orders from buyer Harvest which is time sensitive

Security guards work excessive hours as a pre-condition of employment set by them Clock out workers after normal shift and resume work for cash payment Overbooking orders which exceed capacity to be competitive Banking hours overtime hours often paid out in regular hours Averaging of hours down time often offset by excessive hours at regular wage.
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Banking hours
A system which provides for time off with pay in lieu of wages
Must be legal Must be voluntary Must be paid at the equivalent rate for the overtime hours worked Must be in accordance with any prevailing collective agreements

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Hour Averaging
Laws are often legislated to benefit local industry and give it a competitive advantage Examples:
Total annual work hours in the trade zone are 2,232 and overtime will not be paid until this total is attained. Worker works double shifts for two weeks and doesnt work for two weeks. Since total hours for month dont exceed monthly regular work hours there is no overtime payment.

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The Overtime Argument


Workers often demand to work overtime (to supplement income) Companies are competing for a limited supply of workers Companies need to work overtime to meet customer delivery dates Buyers are putting more pressure on shorter delivery dates to reduce inventory costs

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Corrective Actions What Would You Accept?


Increase capacity
Increase shifts Expand production infrastructure

Better production planning Controlled outsourcing with partners Process redesign to increase efficiency Assure basic wage meets worker needs
Higher basic wage reduces worker pressure for overtime Higher basic wage reduces turnover of personnel and reduces training and quality costs

Flexible work force Negotiate realistic objectives with buyer


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Lunch
60 Minutes

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Group Exercise Working Hours


30 Minutes

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SA8000 Element: Remuneration

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SA8000 Remuneration Standard


Wages should be sufficient to meet basic needs and provide discretionary income Deductions shall not be made for disciplinary purposes except where allowable by national law and collective bargaining agreement All wages and benefits shall be clearly written and detailed for all workers All overtime shall be paid at a premium rate as defined by national law or collective bargaining agreement, or if none in place, at prevailing industry standard Labor-only contracting arrangements, consecutive short-term contracts and false apprenticeship schemes shall not be used to avoid remuneration obligations

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Remuneration Guiding Principles


People must earn enough during the regular work week to support their family without depending upon overtime hourly payments. Services available to employees for a fee such as dormitories, food plans and medicine, if paid, shall be voluntary and provided at no more than the cost to provide the service Companies can choose to pay by the hour or for performance using a quota based system Wages must be:
Understood by workers Paid in currency in a convenient manner Paid in a timely and regular fashion Accurately calculated Paid in accordance with contract

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Understanding Wages
Three types of wage:
Minimum wage set by national law and designed to be low to compete globally in the market. Industry wage prevailing wage in the region for type of sector/work typically higher than the minimum wage. Used to attract skill sets in an industry. Basic Needs Wage (BNW) calculated to provide worker with adequate remuneration based on analysis of needs using a formula predicated on the cost of the local food basket.

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Remuneration Rules
Company must guarantee a daily wage which meets the basic needs wage level. Overtime must be paid at the applicable premium rate if working hours exceed the legally defined regular work hours. Company must pay set-up time if it is required.

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Remuneration: What the Auditor Looks For


Payroll records
Sample worker payments for accuracy Concentrate on bonus, overtime and deductions Payment of social insurance (migrant workers, worker-employer agreements) Bonus systems (team and individual)

Consult with NGOs and Trade Unions


Any dispute with the wage calculation should be substantiated with analysis or alternative data sources

Cross-check Full Compliance with SA8000


Where free association and collective bargaining are effective, unions may be able to verify that the wage meets basic needs

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Common Non-conformances
Overtime not paid at premium rate either hourly or by piece Workers do not understand how their wages are calculated Employers alternate wage calculation from hourly to piece rate for overtime or vice-versa to reduce overall wage Excessive deductions for room, board to offset wages paid Workers basic needs wage does not include taxes, union dues and health insurance Regional costs are not factored into BNW calculation using formula Quotas set too high to assure consistent attainment by workers Failure to guarantee minimum or industry wage per day.

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Piece Rate vs. Hourly Wage


Workers can be paid by the piece or by the hour either method meets requirements Piece rate is the amount paid for each completed item Hourly wage or quota system must assure BNW wage level per day Pay calculation method must not be mixed it must be one or the other

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Piece Rate Model

# x (factor) ( )

Accelerator (1.3) (1.3) e.g. 120 pieces X 0.215 : 120 X 0.215

# x .2795

Quota = 120 pieces in 8 hours =8 120

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Group Exercise - Remuneration


Worker Interviews

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120 pieces x (piece rate) ) 120 x (


Must = at least min wage =

Regular Hours

(bonus) ( )

# of pieces x (OT rate) #x( )

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Overtime

Types of Quotas
Group quotas
Group or line quotas pay all workers equally Incentive is bonus based Workers have little control over group results High turnover and new workers reduce productivity Sequential line operations can produce bottlenecks in productivity affecting wages.

Personal quotas
Workers have more direct control over productivity Paid more for doing more Not susceptible to reduction of productivity due to employee turnover. Better motivation for workers

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Not Making Quota: Basic Causes


Quota established too high for consistent attainment 100% quota attainment should equal basic daily wage Lack of necessary skill sets by operator Lack of adequate training Inadequate time to develop skill sets prior to assuming productivity position in line Poor production planning/ lack of raw materials Machine problems/maintenance Production process organizational design Excessive hours on production line causing fatigue

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Corrective Actions What Would You Accept?


Calculate and verify an adequate wage level using government statistics and NGO/Trade Union references Design realistic quotas or incentive plans

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Control of Sub-Contractors and SubSuppliers

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SA8000 Control of Sub-Contractors Standard


The Supplier Shall: Establish and maintain appropriate procedures to select subcontractors on their ability to meet the requirements of the standard Maintain appropriate records of a sub-contractors ability to meet the standard and evidence of their doing so Provide home-workers with a similar level of protection as that of directly employed personnel

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Guiding Principles
All companies in the supply chain (suppliers, brands and retailers) are accountable for the social compliance of all preceding steps in the supply chain Brands should use their leverage with suppliers to demand socially accountable practices Suppliers should use their leverage with sub-contractors to demand socially accountable practices Brands should strive to be aware of, and be accountable for, the social compliance of the sub-contractors Social compliance policies, procedures and expectations should be clearly documented and communicated throughout the supply chain

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Supply Chain Control


PO APPAREL BRAND

SUPPLIER SUPPLIER: TEXTILE Sub-Supplier: Zippers Sub-Contractor: Extra Capacity Sub-Contractor: Embroidery

Sub-Supplier: Dyes

Sub-Supplier: Thread Sub-Supplier: Dormitory Sub-Supplier: Cleaning Sub-Supplier: Cafeteria

Sub-Supplier: Yarns

Sub-Supplier: Security Cotton Cotton Produce Meat

Cotton Cotton

Cotton Cotton

Cotton Cotton

Paper

Tools

Bakery

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Control of Sub-contractors: What the Auditor Looks For Map of sub-contractors Plan to control and manage sub-contractors Analysis of results of direct and second party audits Certification Sub-contractor social compliance commitment letters from senior management Training materials and presentations to suppliers Self evaluations of suppliers

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Typical Sub-Contractor Control Plan


Identify a few prime (1st Tier) suppliers Notify them of program and intent Meet with them to discuss mutual strategy going forward Establish mutual goals and objectives Track and monitor the process Establish incentives Premium payment (carrot) Preferred vendor list (carrot) Contractual agreement to enforce conformance (stick) Modify plans as required with change in suppliers

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Managing Sub-Contractors
Control of sub-contractors largely dependent on:
Percent of revenue represented (20-40% is target) Alternative sourcing options available (may be sole source) Industry/sector constraints Laws and social norms may prevent conformance

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Managing Sub-Contractors
Methods of control:
Perform audits directly (second party) Require certification or conformance to SA8000 Ask for system procedures/policies/audits Ask for completion of conformance questionnaire Ask for code of conduct audit reports Letter of management commitment to comply Contact and monitor suppliers through electronic means Electronic means, e.g. pdf files, photos, Skype, e-mail, internet.

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Control of Sub-contracted Workers


SA8000 Certified Factory
Employees get: Wages Benefits Hours* Health & Safety* Training* Companies trying to reduce fixed costs rely on sub-contractors and employment agencies. Compliance becomes an issue of accountability and indirect control.

Sub-Contractors

Employment Agencies

*Direct Control
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Personnel & Service Suppliers Industrial park hiring agents Employment agencies Homeworkers On-site service suppliers
Cafeteria Medical Security Maintenance Cleaning

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Common Non-conformances
Unauthorized use of second tier sub-contractors without supplier awareness Not monitoring home-workers Use of non-compliant employment agencies or service contractors Compliance not addressed in purchase orders or supply contracts Management system not focused on controlling subcontractors Use of sub-contractor commitment letter as proof of compliance Compliance expectations not clearly communicated to subcontractors

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Corrective Actions What Would You Accept? Positive approach from Buyers
Premium for compliance Put on approved vendor list Provide training Development of Strategic Suppliers - Partnering approach for mutual benefit Provide suppliers with non-circumvent assurance

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Group Exercise Control of Contractors


30 Minutes

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End of Day Quiz


15 Minutes

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Day 4

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Auditing For Social Management Systems

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Auditing
Audit: Systematic, independent and documented process for obtaining audit evidence and evaluating it objectively to determine the extent to which audit criteria are fulfilled (ISO19011: 2011).

In the fields of observation chance favors only the prepared mind.


Louis Pasteur

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SA8000 Auditor Reference Sources


Auditor references:
SA8000:2008 standard SA8000 Guidance Document, the 2011 updated guidance addendum and FAQs listed on SAI website SA8000 basic and advanced course materials Certification Body certification procedures
SA8000 specific requirements drawn from SAAS Procedure 200, SAAS advisories and ISO/IEC 17021 Supporting CB documentation regarding basic wage calculation, NGO engagement and contacts and sector/regional issues to be addressed

ISO Guide 19011-2011 Guidelines for management systems auditing (ISO/IEC 17021) National and local Laws and Regulations ILO Conventions (web site www.ILO.org)
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Relevant Terminology
Audit Auditor Auditee Audit Team Audit Program Audit Criteria Audit Finding Audit Conclusion Objective Evidence Non-conformance Corrective Action Preventive Action Personnel

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The Audit Cycle


Corrective action and follow up Audit planning

Report of the audit

Audit preparation

Conduct of audit

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A Typical Audit Process


Initiating the audit

Conducting document review

Preparing for the on-site audit activities

Conducting on-site audit activities

Preparing, approving and distributing the audit report

Completing the audit

ISO19011 breaks down the audit process into six distinct activities Initiating the audit Conducting the document review Preparing for the audit Conducting the audit Preparing the audit report Completing the audit

Conducting audit follow-up

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Audit Process: The Two-Stage Requirement


In the SA8000 system, the Audit Process should be divided into two stages
Stage 1: Fact Finding and Initial Visit Stage 2: Audit Visit

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Stage 1: Fact Finding and Initial Visit


Conduct initial visit
Review critical areas (high risk) and chronic conditions, e.g. toxins, machinery, etc. and devote appropriate time to most relevant issues

Review documents and policies / procedures


Work place and employee demographics Applicable elements, e.g. overtime, basic needs wage calculation, control of supplier plan. Management system for basic elements- management review, audits, corrective actions

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Stage 2: Audit Visit


Conduct the formal assessment on-site
Develop audit paths for each auditor to maximize coverage Schedule and conduct group and individual interviews of workers and management Assess risk as appropriate Collect information and verify

Prepare findings and write NCRs as appropriate Conduct closing meeting and clarify team expectations of issues to be addressed by client

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Stage 1 - Audit Planning


Determine number of audit days based on total number of employees include contractors Verify audit scope and number of sites Verify work shifts Identify activities and processes involved Determine size of audit team and qualifications required Obtain subject matter expertise as needed Consider gender mix if applicable Create a basic wage calculation and plan for stakeholder engagement typically off site Collect applicable laws and regulations Arrange for travel and logistics
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Audit Scope
The audit scope defines the extent and boundaries of the audit, such as:
Physical locations, Organizational units, Activities and processes, Region

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Scope Considerations
Certifications typically done for a self-contained site such as a farm or factory Multi site certificates are allowed but are subject to controls for sampling
Agricultural farms Package delivery and temporary employment agencies

Certificates cannot cross country boundaries Split operations of a business are not allowed for the purpose of reducing audit days
Certifying one of several different production lines Certifying one of several production buildings

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Group Exercise: Scope


15 Minutes

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Stage 1 - Audit Plan Components


Audit objectives Audit criteria Audit scope Dates, places and on site activities Individual audit paths for auditors, i.e. roles and responsibilities of auditors Proper allocation of resources by expertise Identification of auditees representative Materials to be made available to audit team by client Logistical arrangements as required

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Stage 1 - Audit Preparation


Assigning of responsibilities to team members
Based upon skill sets and expertise Minimize overlap Maximize use of resources

Prepare work documents


Sampling plans Recording forms note objective evidence Checklists industry and region specific
Ensure adequate coverage of subjects Data to be used in audit report

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Stage 1 - Checklists
Provide a road map and path to audit Identify key points to cover to ensure coverage
Structure in line with standard requirements Include topics of special interest identified by external sources Add items identified as high risk in industry or region Concentrate verification in areas of likely concerns

Provide document references for cross check Provide document for notations of objective evidence for audit report and client file Provide a guide for each auditor Maximize resources
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Stage 2
Conduct of Audit
Conduct opening meeting Collect and inspect documents Conduct interviews Conduct interviews with external stakeholders Research and understand local labor conditions

Reporting the Audit


Conduct closing meeting Prepare the audit report

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Stage 2 Conduct Opening Meeting


Introduction of team Sign in sheet used to document attendance Review audit scope Explain audit process and criteria Explain non conformities and the grading system Confirm communication channels Provide opportunity to ask questions Confirm logistical arrangements

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Class Exercise Record Verification


30 minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Stage 2 - Collect and inspect documents


Payroll Time cards Personnel files Management review and corrective actions Policies Health and safety records Business licenses Worker contracts Production planning Plan to map and control suppliers
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Introduction of Interviews The Process

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Stage 2 - Conduct Interviews


Conduct early in audit to allow time for data verification 30% of audit time devoted to interviews 100 or 5% of worker population as target Mix one-on-one with group interviews Consider necessity of off-site interviews Conduct on site interviews of workers and managers Evaluate necessity of off site interviews for workers if risk a probability Conduct external interviews with stakeholders
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Stage 2 Key Points on Interviews


Provide data for audit report Provide data which is used for verification and validation
Information obtained from workers should be verified

Are critical to the process of discovery Are biased Yield conflicting information

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Stage 2 Interview Preparation


Worker selection is critical Audit team chooses workers independently using:

Payroll Time cards Observation


All jobs and all shifts included for initial audit 100 workers or 5% - 10% of worker total Consider worker diversity to assure proper mix of female, migrant, minority populations

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Stage 2 Interview Techniques


Explain the situation and purpose of your presence Ask permission to take notes Create rapport (present workers with your business card) Minimize the threat (do not allow management in the vicinity) Maintain control of the interview and overall process Maintain perspective Establish two way communication Assure anonymity Project interest and concern Guarantee workers will be paid for their time
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Stage 2 Common Interview Mistakes


Common Interview Mistakes
Acting superior to the interviewee Dont listen to what is being said Dont allow the worker to complete their response Sitting in a power seat auditor has the power in worker perception Jumping to conclusions subsequent responses from workers will then be filtered to confirm the auditors conclusion Using leading questions to obtain the answer that the auditor wants Not looking at the person being interviewed

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Stage 2 Interview Questions


The two tier question stopping too soon
Does the company provide hot water? Yes, but for how long?? Is the lighting in the production area generating sufficient lumens? Yes, but does the company turn on all of the lights?? Is personal protective equipment issued to workers? Is it adequate and are workers capable of using it??

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Stage 2 External Validation Knowledge of local laws and labor codes Knowledge of external information sources critical NGOs (non-governmental organizations) Trade unions Interested third parties Newspapers Universities Government websites Customs and social norms Knowledge of industry/sector Subject Matter Expertise necessary
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Stage 2 Audit Conclusions


Preparing audit conclusions from objective evidence
Documents and records Feedback from interviews Personal observations

Grading the non conformances


Major systemic failure Minor a one off situation not systemic in nature Observation not obligatory but intended as a value added input for consideration

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Stage 2 Conduct Closing Meeting


Attendance should be recorded Present formal findings to client management team Divergent opinions should be resolved Recommendations should be reviewed with client team not binding Worker representative, if one is elected, should be in attendance

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Stage 2 Prepare the Audit Report


Preparing the audit report
Include audit objective, scope and criteria of audit Identification of participants Detailed audit findings Audit conclusions Agreed upon follow up action plans Statement of the confidential nature of the contents of report Distribution list of recipients To be completed within a defined period of time. Submission to CB for review and approval

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Introduction to Auditor Competencies


What Makes a Good Auditor?

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Influences on Auditor Performance


Focus of an Auditor Training Program
Internal (Attitude, Skills, Knowledge)

Auditor
External (Certification Body)

Internal (CB Management) Governance (mission-driven) External (Scheme Requirements) Global Scope

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Auditor Competencies
There are three broad categories of competency for for the social auditor:
Attitude Skills Knowledge

Attitude

Skills

Knowledge

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Auditor Attitude

Auditor Competencies: Examples

Personal and cultural bias toward discrimination Receptivity to listening to differing views Willingness to investigate below the surface

Auditor Skills
Effectively interviewing workers Comparing documents for inconsistencies Drawing information from NGOs and unions

Auditor Knowledge
National laws Standard Knowledge of common problems in the region

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Underlying Problems with Auditor Competencies


Attitude
Bias toward either management or workers Cultural bias toward discrimination Unwillingness to investigate below the surface

Skills
Poor interviewing techniques Inadequate information from external stakeholders Lack of time management Poorly written non-conformances and audit reports

Knowledge
Misunderstanding application of law vs. standard Weak knowledge of specifics steps in audit process Understanding which documents will provide greatest insight
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The Players

Lead Auditor team leader Auditor team member

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Role Of The Auditor


Audit conformity of practice against the requirement of the standard Ensure that auditor expectations are communicated to client in terms of levels of acceptance Provide clarity to client on intent and meaning of requirements Reach conclusions based upon audit evidence Identify opportunities for improvement value added Establish positive and constructive relationship to attain client buy in to the process. Manage client actions with non conformance reports Position findings as opportunities for improvement rather than penalties

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Auditor Competencies
There are three broad categories of competency for for the social auditor:
Attitude Skills Knowledge

Attitude

Skills

Knowledge

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Group Exercise: Auditor Competencies


30 Minutes

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Auditor Attitude Requirements


Cultural awareness and sensitivity (such as attitude toward discrimination) Evaluating conflicting evidence Willingness to engage with external stakeholders Investigative approach Neutral attitude toward management and workers Open-minded and as objective as possible Ability to empathize with all parties Professionalism and discretion Ability to lead or be part of team, as appropriate
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Auditor Skill Requirements


Document review Interviewing workers and managers Visual observation Physical inspection Stakeholder engagement, including interviews with NGOs and trade unions Identifying needed corrective actions Analyzing the severity of problems and whether systemic

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Auditor Skills Requirements


Verification Time management Audit planning and coordination with client and audit team Researching relevant laws and collecting data Audit report writing Effective sampling techniques Specialized skills specific to your standard

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Auditor Knowledge Requirements


Relevant UN and ILO Conventions ISO management system principles, including ISO 19011:2000 (ISO/IEC 17021) ISO 14001 Environmental standard SA8000 Standard Relevant industry or corporate codes National and local law Trade agreements and treaties Common problems in region Audit procedures and protocols
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Role and Responsibilities of the Team Leader


Communicate audit requirements to client Plan the assigned audit Manage and support the team Conduct the management systems audit Lead the opening and closing meetings Draft report of audit results Maintain integrity and confidentiality

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Development of an Audit Plan

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Day 5 Agenda
Questions and Answers for Exam Preparation Final Exam

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BSCI
Business Social Compliance Initiative Protocols and Requirements

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Overview on BSCI for BSCI Auditors 2012

BSCI Module

199

Understanding the topdown development approach of BSCI Understanding the linkage between SA8000 and BSCI Understanding the auditing and reporting procedures

BSCI Module

200

100

The Business Social Compliance Initiative (BSCI) is a business driven organization created in 2002 that aims at helping companies to improve working conditions in their global supply chains. Its members, now numbering more than 700 Brands, implement one single Code of Conduct driving a specific, consistent methodology for all their products.
*FTA is the Foreign Trade Association

BSCI Module

201

Implement a uniform procedure and code of conduct for improving worker conditions in its supply chain Share expectations, technical knowledge and, assistance with their suppliers Focus on monitoring of suppliers to measure compliance and drive continual improvement Reduce audit burden on suppliers caused by multiple audits Focus on partnering with suppliers and reward improvements through long term relationships
BSCI Module 202

101

o
o

The ILO Conventions, the United Nations' Universal Declaration of Human Rights,

the UN's Conventions on children's rights and the elimination of all forms of discrimination against women,

the UN Global Compact and the OECD Guidelines for Multinational Enterprises.

BSCI Module

203

Development approach: Assess suppliers against the BSCI code to determine levels of compliance and determine what needs to be done to meet code requirements. Partnership : BSCI and its members work with suppliers to educate, assist and implement a management system approach that will improve workplace conditions. BSCI SA8000 linkage: BSCI has incorporated SA8000 standard requirements into its code to promote best practice with its supply chains.
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102

External audits Members Commitment

Stakeholders Relations Capacity Building

INTEGRITY

BSCI Module

206

103

Audit may be requested by a trading partner (Brand) for one of its suppliers Audit may be requested by a factory directly
Factory must demonstrate it has a formal relation with one or more of the BSCI members

All requests for audits must be directed to a SAAS accredited certification body.

BSCI Module

208

104

Self Assessment by supplier raising suppliers awareness Details of supplier facility and production supplied to audit team facilitate audit planning Declaration of consent supplier release document allowing audit performance and use of data Initial audits performed every three years to maintain supplier conformance (unless certified to SA8000) Corrective Action Plans (CAPS) written by auditors for suppliers to manage compliance and improvements Re-audits follow up within 12 months of findings to assure effectiveness of plans to improve

BSCI Module

209

The plan of action recording what measures have to be taken within a given time frame limit to remedy a deviation against the BSCI Code of Conduct
Must have a clear and accurate description of noncompliance Must define a specific implementation timeframe within maximum of 12 months from the day of the audit. Must be constructive in nature and in line with the BSCI development approach and its pillars of action. Immediate notification of BSCI member company or BSCI executive office if zero tolerance issues encountered.

105

In the event that any decision should depart from the national legal regulations, the auditor is required to present his/her decision comprehensively in the Social Audit Report giving reasons for the decision.
In Thailand the law allows workers to work up to 36 hours of overtime per week. In some countries it is illegal to organize a trade union. Malaysia, UAE (Dubai) and Macau, among others, allow factories to hold worker passports. Many countries deny women equal rights and equal pay in the workplace

The physical and mental protection of the individual and observance of dignity and human rights are the key values for consideration.
BSCI Module 211

Certification bodies accredited by SAAS for SA8000 are qualified to perform BSCI audits. Certified auditors meeting SAAS protocols to perform SA8000 audits
SA8000 basic auditor course SA8000 advanced auditor course Prescribed field experience Continual improvement training

BSCI Module

212

106

Fluent in local language (at least one auditor) Working knowledge of English Knowledge of local customs and culture Time management Health and safety knowledge Environmental systems knowledge Knowledge of the BSCI system Knowledge of the sector being audited

BSCI Module

213

BSCI audits periodically reviewed through field evaluations by SAAS accreditation auditors
Ensure that auditors are qualified in accordance with requirements
Training Skills Experience

Assure that audits are conducted in accordance with BSCI protocols

BSCI Module

214

107

THE BSCI CODE OF CONDUCT System Rules and Functioning Implementation Guidelines BSCI Database BSCI Glossary

Management Manual Self assessments E-learning tools, handbook for Primary producers
Audit Questionnaires Audit Guidelines Audit Reports Farm Summary Report

BSCI Code of Conduct

BSCI Primary Production tools

BSCI industrial tools

Primary Production Food

Processed Food

Manufactured Non-Food

108

Use this for industrial production

Use these TWO for primary production: one for the packing house

This is to report your finding at sample of farms you visited

Facility size
1-100 workers 101-250 workers 251-500 workers 501-750 workers 751-1000 workers 1001 workers +

Initial Audit duration


1.5 days 2.5 days 3 days 3.5 days 4 days 4.5 days

Re-audit duration
1 day 1 day 1 day 1 day 2 days 2 days

109

Welcome
Introductory Meeting

Interview with Management

Document review

Site inspection

Interview with employees

Evaluation
Information evaluation and assessment, Preparation of Corrective Action Plans (CAPs)

Final Meeting
Agreement on CAPs Signing of audit documents by Senior Management

Audit Report
Preparation by Auditor Sending to Management Forwarding of copy to retailing company by supplier

In Primary Production internal audits documentation has to be reviewed.

Documents
In Primary Production internal auditor has to be interviewed

In Primary Production workers at the Farm have to be interviewed.

Interview with workers

Interview with Management

110

To be conducted with both workers and managers Critical to fact finding process 50% individual and 50% in group no strict limit on total interviews Auditor selects the workers to be interviewed Time allowance 20 minutes individual and 30 minutes for groups. No coaching No management on site Off site interviews dependent upon time and need
BSCI Module 221

Audit report a formal summary of audit findings and actions required


Part A details of company structure, organization and operation Part B BSCI code of conduct - mandatory verification and compliance Part C Management system elements (best practice SA8000) mandatory verification but optional implementation

Audit questionnaire a detailed list of questions for each of the defined elements
BSCI Module 222

111

Part B BSCI Social Requirements


B. B. B. B. B. B. 1: Management Practice 2: Documentation 3: Working Time 4: Compensation 5: Child Labour / Young Employees 6: Forced Labour / Disciplinary Measures / Prison Labour B. 7: Freedom of Association and Collective Bargaining B. 8: Discrimination B. 9: Working Conditions B.10: Health and Social Facilities B.11: Occupational Safety and Health B.12: Dormitories B.13: Environment

Part C Best Practice for Industry


C. 1: Policy C. 2: Planning and Implementation C. 3: Management Review C. 4: Control of Subcontractors / Suppliers / Sub-Suppliers C. 5: Control of Homeworkers C. 6: Compensation C. 7: Child Labour C. 8: Evasion C. 9: Outside Communication

Part B:

Part C:

112

Audit Results Part B and Part C

The lowest score for any question will be carried over to the total score for the respective section. All questions must be answered with yes, no or N/A.

BSCI Module

226

113

o o o o o o

Declaration of consent Photos Employees Record Sheet Production Unit Record Sheet Child Labour Record Sheet if applicable Farm Summary Audit report, when farms have been audited.
UPLOADING THE ANNEXES IS ALSO MANDATORY

Critical to the process to assure that appropriate actions are taken. Desirable to have the same certification body follow up on the initial audit. Failure to correct problem(s) will result in another re-audit Any new deviations identified from the code will be reported and a re-audit scheduled

228

114

Before entering a new producer, search for it with the search function to avoid double entries of the same producer. The creation of a new record automatically generates the assignment of login codes for the supplier to access his own data, sign the Code of conduct and fill out the self-assessment online.

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UPLOADING IS PART OF THE AUDIT PROCESS AND IS MANDATORY

Punctuality: Submit report within 10 working days of audit Accuracy: the data in the electronic version is the same as the one in the PDF report Consistency: The information is is presented in a uniform manner Completeness: All fields and relevant annexes are included. Integrity: The auditor is competent and presents a professional image representing BSCI

Vanessa Baumes (vanessa.baumes@bsciintl.org) Auditing Project Manager (as of October 1st 2011) Kris Molle (kris.molle@bsci-intl.org) Members Relation Officer

116

Group Exercise Read Out of Achilles Textile Audit Plan


60 minutes

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

Introduction of Advanced Course

Social Accountability International SA8000 Basic Auditor Course - Version May 2012

117

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