EICC Validated Audit Process (VAP) VAP Operations Manual

Transcription

1 EICC Validated Audit Prcess (VAP) VAP Operatins Manual Revisin 5.1 January 2016 Infrmatin and cmmunicatin technlgy cmpanies wrking thrugh the Electrnics Industry Citizenship Calitin (EICC) are wrking t imprve sustainability and scial respnsibility within the glbal supply chain. These cmpanies recgnize a mutual respnsibility t ensure wrking cnditins in the Infrmatin and Cmmunicatin Technlgy (ICT) industry are safe, wrkers are treated with respect and dignity, and that manufacturing practices are envirnmentally respnsible. The Validated Audit Prcess (VAP) is a cllabrative apprach t auditing t reduce the burden n supply chain cmpanies frm multiple requests fr scial audits. The VAP meets the need fr a high quality, cnsistent and cst-effective standard industry assessment fr labr, ethics, health, safety and envirnmental practices based n the EICC cde f cnduct, laws, and regulatins. Fr mre infrmatin abut the VAP, please cntact: APMEiccaudits@sumerra.cm EICC Address: Suite 330, 1737 King Street, Alexandria VA 22314, USA EICC Website: Electrnic Industry Citizenship Calitin. All Rights Reserved. N part f these materials may be reprduced r transmitted in any frm r by any means, electrnic r mechanical, including but nt limited t phtcpy, recrding r any ther infrmatin strage r retrieval system knwn nw r in the future, withut the express written permissin f the Electrnic Industry Citizenship Calitin, Incrprated. The unauthrized reprductin r distributin f this cpyrighted wrk is illegal and may result in civil r criminal penalties under the U.S. Cpyright Act and applicable cpyright laws. EICC VAP Operatins Manual v502 1

2 9. Auditee Preparatin A successful audit depends n careful preparatin by bth the auditrs and the auditee. In advance f the audit, the auditee shuld wrk t prepare its lcatin and management team and staff fr the audit. Ding s will increase audit efficiencies and will make the audit easier fr bth the auditrs and auditee. The gal f the audit prgram is t wrk in partnership with suppliers t fster crprate respnsibility (CR) perfrmance imprvement and build CR capability within the supply base. The audit prvides EICC member cmpanies and ther custmers with an evaluatin f a supplier's labr, ethics, ccupatinal health and safety, and envirnmental practices relative t the EICC Cde f Cnduct. The audit als identifies CR practices and/r suppliers that may require imprvement in rder t be in cmpliance with the EICC Cde f Cnduct. Self-Assessment Audit Crrective Actin Plan and Preventive Actin Clsure Audit Cntinuus Imprvement 9.1 The EICC Validated Audit Prcess (VAP) Overview The EICC audit will generally be a multi-day event with multiple auditrs. The exact number f audit days and number f auditrs depends n the factrs listed in the Audit Team chapter. The specific audit duratin and number f auditrs is determined jintly between the VAP Audit Prgram Manager (APM) and audit firm at the time the audit is scheduled. The EICC audit includes bservatins frm physical inspectins; reviews f prgrams, prcedures, and plicies; and gathering infrmatin frm management and wrkers. Facility walkthrughs and gathering infrmatin frm wrkers and management are intended t prvide insight int CR plicies, practices, and implementatin f prcedures, awareness f rles and respnsibilities, and management invlvement. Dcumentatin and recrds review prvides infrmatin n hw well CR management systems are defined, implemented and sustained, and f their perfrmance. An bserver may accmpany the auditrs. See the chapter n Observer Guidance and Feedback fr details. 9.2 EICC Validated Audit Prcess Criteria The EICC audit criteria are based n the EICC Cde f Cnduct and lcal legal requirements. These criteria are the basic CR perfrmance expectatins fr suppliers. EICC VAP Operatins Manual v502 2

3 The criteria cver five main areas: Labr Health & Safety Envirnmental Ethics Management Systems fr Labr, Health & Safety, Envirnmental, and Ethics 9.3 Audit Overview The audit includes the fllwing elements: Auditr preparatin (auditrs review infrmatin prvided by auditee and cnduct a pre-audit meeting with the auditee) Opening meeting Perimeter survey Facility evaluatin Facility tur and inspectin Dcumentatin reviews Infrmatin gathering frm management and wrker interviews and discussins Daily wrap-up meetings Clsing meeting Draft reprt Validated Audit Reprt (VAR), the final audit reprt The clsure audit fcuses exclusively n nncnfrmances and is shrter in duratin. Auditees that want t request help with their Crrective Actin Plans (CAPs) may fllw the prcess in the chapter fr Crrective Actin Preparatin fr Auditees. 9.4 Auditee Preparatin Requirements The auditee's advance preparatin duties include: Cnfirm the audit dates and audit duratin with the audit firm. Establish, tgether with the Lead Auditr, the n-site audit agenda. Prvide infrmatin n travel lgistics: preferred htels and airprts, travel restrictins and any special cnsideratins. Participate in pre-audit dcumentatin review. Review infrmatin abut the EICC s Cde f Cnduct and interpretatin guidance ffered in this Operatins Manual. Cmplete the audit scping dcument r the EICC Self-Assessment Questinnaire (SAQ). EICC VAP Operatins Manual v502 3

4 Prvide all f the requested manuals, recrds and dcumentatin. Make them available and up-tdate n the day f the audit. Ensure that relevant infrmatin is available fr the auditrs when they arrive: Names, phne numbers and lcatins f the audited facility's key peple Maps f the site and surrunding area Ensure that auditrs have access t the facilities (i.e., drmitries, canteens, manufacturing, assembly and chemical strage areas). Ensure staff members are available that have a thrugh knwledge f the facility s Labr, Health & Safety, Envirnmental and Ethics plicies, prcedures, wrk instructins and recrds. Ensure staff members are ready and able t pull sample wrking hur and wage data and ppulate the wrking hurs template. Make appintments with individuals whm the Lead Auditr has requested fr gathering infrmatin frm wrkers/staff sessins. Appint staff t interface with and accmpany the auditrs. Invite apprpriate staff members t the pening and clsing meetings and daily wrap-ups. Brief management and staff n the audit prcess s they can effectively participate. Prvide the auditrs with meeting rm(s), preferably with access t a telephne/internet line, printer and cpy machine. The APM is available fr additinal guidance and t answer questins if required. 9.4 Auditee Prcess The audit will fllw the prcess as utlined belw Audit Start When arriving n site, the auditrs will present identificatin prir t the start f the n-site audit prcess. The auditr(s) will bring with them all audit tls and equipment necessary fr the audit. The auditee will ensure all dcuments that were requested in advance by the auditr are available and apprpriate staff members are available. NOTE: Auditr(s) will arrange their wn transprtatin and accmmdatin fr the audit Opening Meeting All audits begin with an pening meeting. The purpse f the meeting is fr the auditrs t meet with the auditee s management and ther persnnel invlved in the audit. The pening meeting will fllw standard EICC audit prcedures and templates including: Purpse and bjectives f audit Audit schedule Audit scpe Audit apprach EICC VAP Operatins Manual v502 4

5 Discussin f facility turs, interviews, recrd reviews, taking field ntes Emphasize the fact that nt every recrd r peratin will necessarily be reviewed in detail and that the auditrs may nly lk at a representative sample f items t determine cnfrmance Schedule the daily wrap-ups and clsing meeting Reprt preparatin and QA prcess Auditee management respnse prcess Audit prcess flw chart making certain that the Auditee understands the timeline The Lead Auditr will prvide answers any questins the auditee may have. The Lead Auditr shuld use the PwerPint presentatin template, EICC Audit Opening Meeting Template. The slide set can be mdified as needed. The auditee shuld present a summary f business and peratinal issues and ther infrmatin that helps the auditrs understand: CR prgram rganizatin Assignment f respnsibilities CR issues, gals and perfrmance The business climate fr the rganizatin A summary review f facility peratins Identificatin f imprtant site activities ccurring during the week Majr changes since the last audit A review f the pre-audit dcumentatin including the SAQ and any previus audit reprts Identificatin f key interview candidates and availability (including relevant rganizatin charts) Identificatin f the auditr wrk rm Phne & internet prtcl and supprt Identificatin f the site wrk hurs Visitr safety and security prtcls Discussin f the site escrt prtcl fr visitrs Other infrmatin f ptential interest t the auditrs and attendees The pening meeting with auditee management shuld be cnducted as efficiently as pssible Audit scpe The auditrs will inspect: Prductin areas Cmmn areas Office areas Facilities areas (equipment rms, wastewater treatment, maintenance shps, etc.) Material, chemical and waste strage and prcessing areas Warehuse/distributin/strage rm(s); shipping and receiving EICC VAP Operatins Manual v502 5

6 Canteens and kitchens Drmitries, hstels and any ff site husing f wrkers/migrant wrkers (if cmpany r labr agent wns/rents accmmdatin fr wrkers) Surrunding land (within brder f factry prperty) Security rm(s) Wrker and Management Interviews Wrker Interviews Prper interviewing is an imprtant element f the audit prcess. Auditrs shuld fcus n btaining respnses that enable accurate evaluatin f past and current perating practices. Interviews shuld be dne in a manner that is sensitive t interviewee apprehensin and nervusness. Thrughut the audit, the auditrs will interact with wrkers t gather infrmatin in bth frmal and infrmal situatins. Frmal interactin means that the auditrs select and interview certain individuals; these wrkers will cme frm different areas f the facility, different shifts r psitins and have different respnsibilities. Infrmal interactins ccur as the auditrs have brief interactins with individuals at their place f wrk r in ther areas f the factry during the curse f the audit. Wrker interviews are a particularly sensitive tpic. Auditrs shuld always ask auditee management t ensure that wrker interviews can be cnducted privately, withut the presence f auditee managers r ther staff. Wrker input is cnfidential. The auditee must agree at a senir level t encurage wrkers t be pen and hnest during interviews and they must actively prtect any interviewed wrker frm retaliatin (i.e., n reductin in pay r ther penalties) fr any infrmatin that leads t a nncnfrmance finding. The number f wrkers selected fr a frmal gathering r infrmatin sessin will depend n facility size. Interviews may last 20 minutes r mre, and will be cnducted in tw ways: individually r in grup settings. In rder t prvide statistically valid results, the number f wrker interviews cnducted and the number f wrker recrds reviewed depends n the number f wrkers at the facility. Interviewees will be drawn frm a range f wrkers including permanent, temprary, subcntract labr, security, cleaners, fd preparatin and ther staff. The pl f wrkers t be interviewed shuld vary, including new and experienced wrkers, thse in mre and less skilled psitins, wrkers frm varius departments and shifts, and wrkers f bth genders. When apprpriate, the interviewees shuld include wrker representatives. The number f interviews cnducted shuld equal apprximately the square rt f the ttal number f wrkers (direct and indirect emplyed peple excluding management staff) (e.g. 55 interviews fr a factry with 3000 wrkers). Where this is nt pssible, a clear explanatin fr a lwer number f interviews shuld be given in the reprt. NOTE: If half r mre f the required interviews are cmpleted and all feedback is cnsistent with infrmatin prvided by management and dcuments reviewed, then it is nt necessary t perfrm additinal interviews. Wrker interviews are private meetings between the auditr and the interviewees. Auditee management and bservers cannt be present during interviews in rder t ensure wrker privacy and cnfidentiality, nr can the interviewees be punished in any way fr the cmments made during an interview. EICC VAP Operatins Manual v502 6

7 The APM shuld be immediately infrmed if site management is unwilling t allw interviews, r if the auditrs feel that wrkers talking penly with auditrs will cmprmise the wrkers. The APM will assess the situatin, including cntacting the auditee, in rder t determine if the audit shuld cntinue. The fllwing infrmatin is t be dcumented: Gender breakdwn f interviews (e.g. 36 female, 32 male and 12 juveniles) The shift n which wrkers are engaged (if applicable) Any issues with privacy and cnfidentiality f interviews Whether wrkers attended interviews freely Wrkers were nt cerced Age range f interviews undertaken Number f individual and grup interviews undertaken Ttal number f interviews undertaken Whether interviews were undertaken by the auditr r prfessinal interviewer Management Interviews Gathering infrmatin frm managers prvides the auditrs with an understanding f hw the auditee s CR prgrams were develped and are implemented. Auditrs shuld verify statements made by site staff thrugh a review f dcuments, recrds, physical bservatins and wrker interviews. This verificatin step is used rutinely in auditing, and auditrs shuld ensure that thse wh are interviewed are aware that it is nt meant t be a challenge t the veracity f their statements. Typically, the auditrs interact with: Site manager(s) Prductin manager(s) Maintenance staff Envirnmental manager(s) Health & Safety manager(s) Quality manager(s) Internal Audit manager(s) Human Resurces manager(s) Onsite services staff such as canteen, drmitry supervisrs, security staff Finance manager/payrll manager(s) Prcurement manager/supply chain manager(s) Warehuse and chemical stre manager(s) Onsite medical staff (as apprpriate) Legal Other persnnel (as apprpriate) EICC VAP Operatins Manual v502 7

8 9.4.5 Facility Walk thrugh The purpse f the facility walkthrugh is fr the auditrs t bserve physical cnditins and current practices in all areas f the facility. The auditr shuld be free t review all physical areas f the facility and shuld set the pace and directin f the tur. At the start f the audit, a perimeter survey may be cnducted. Prtins f this survey may take place prir t the pening meeting. The bjective f this survey is t identify a variety f data pints that help prvide cntext t the auditrs f the auditee s peratin and t help the auditrs prepare questins fr further investigatin. This survey may cnsist f: Lking at transprtatin infrastructure Emergency services such as fire department r utside security services Identifying ptential lcal cmmunity impacts Identifying ptential lcal envirnmental impacts During the tur, the auditr typically inspects and bserves: Wrk envirnment (space, temperature, lighting, etc.) Ergnmics and wrk statins Manufacturing and prcessing peratins Fire and emergency equipment Machine prtectin and maintenance Emergency prcedures Persnal prtective equipment First aid equipment and medical center/clinic Air emissins and emissin cntrl systems Hazardus materials strage and handling Hazardus waste generatin and strage Waste (hazardus and nn-hazardus) management Fuel, chemical and il strage, transprt and use Tilets and sanitatin Canteen and kitchen hygiene and safety, when applicable Drmitry facilities including hygiene and safety Wastewater treatment, discharge and sludge dispsal Recreatinal facilities Unreasnable restrictin n wrkers freedm f mvement r rights Quality, prductin and time recrds EICC VAP Operatins Manual v502 8

9 Psting f relevant cdes and any wrker infrmatin relating t their rights Wrkers ntice bards and infrmatin relating t Unin r wrkers cmmittee meetings Any recrds r dcuments displayed that might shw a discrepancy between peratinal activities and the prtectin f human rights With cnsent frm the facility management, digital phtgraphs might be taken t further supprt the data btained. In sme cases, fr safety, security r cmmercial cnfidentiality reasns, the site management may prevent visitrs frm walking unaccmpanied thrugh prtins the site. In such cases, auditrs shuld fllw the auditee plicies, unless the management is willing t ffer an exceptin. It is the respnsibility f the auditee t infrm the auditrs f the safety rules and requirements (such persnal prtective equipment PPE in specific facility areas) and prvide the auditrs with necessary PPE where required. Phts allw the auditrs t quickly dcument certain situatins. Auditrs shuld btain permissin t take phts in the facility. Alternatively, the auditee can take phts as requested by the auditrs and prvide them by the end f each day t the audit team. If the management des nt give such permissin and will nt take requested phts (either as a whle, r is certain areas), auditrs will dcument this in the reprt. Phts are nt intended t cntain prduct, prduct infrmatin r ther prprietary infrmatin. The auditrs shall disrupt the prductin flw as minimally as pssible during the facility walk thrugh Dcument Reviews: As part f the audit, the auditrs will review relevant recrds. Examples include, but are nt limited t (fr mre infrmatin, see Critical Dcuments chart): Wrking hur recrds, payrll, wages, deductins and benefits EHS management system dcumentatin Permits Waste Recrds Written plicies, prgrams, prcedures Training recrds The number f recrds t be reviewed, and what is t be reviewed, will be prvided by the auditrs during the audit. It is imprtant fr the auditrs t spend sme time reviewing the site's cmpliance recrds (e.g. permits, plans, prcedures, recrds) befre interviewing the staff r inspecting the perating facilities. This is because many f the cmpliance requirements are fund in these recrds. The auditrs will review the recrds fr the applicable requirements and verify cmpliance thrugh interviews and inspectins. The auditrs shuld be thrugh in the review f recrds, hwever, this des nt mean that every recrd must be evaluated. The auditr is free t use statistical r ther representative sampling in the review prcess. Where the auditr des nt review every recrd and there is a nncnfrmance finding, the auditr must reflect the sampling methd in the statement f finding. The dcuments and recrds must be available n-site fr auditrs t review, and must cver at least the previus 12 mnths. EICC VAP Operatins Manual v502 9

10 A minimum f three mnths f pay and time recrds (peak, valley and average mnth) will be reviewed fr each wrker fr the 12-mnth perid prir t the audit. In the case f a clsure audit, three mnths f pay and time recrds will be reviewed fr each wrker frm the perid f crrective actin implementatin till date f audit (nt exceeding ne year). The dcuments that auditrs will review must be available at the start f the nsite audit prcess. If the dcuments are nt available 4 hurs int the audit, the audit may be determined as Denied Access r the dcuments may nt be reviewed by the auditr and will be classified as nt present, which may negatively impact the audit scre and results. As part f the dcumentatin review, the auditrs may need t recrd sme infrmatin in rder t cmplete their evaluatin. The auditrs will nt include any cnfidential infrmatin, such as detailed prduct infrmatin, detailed prcess steps, r persnal identifiers in the audit reprt. In additin, the APM screens all Validated Audit Reprts (VAR) t ensure that any ptentially cnfidential infrmatin is remved prir t releasing the reprts t the auditee and the authrized recipients. Nte: The number f recrds per mnth reviewed must always equal at least the square rt f the ttal number f in-scpe wrkers at the site, even if auditrs have interviewed less than that number. Nte: A clsure audit cannt take place unless there are at least three mnths f implementatin data (unless the clsure audit is related t a Pririty Nncnfrmance). A clsure audit is als nt permitted t take place AFTER the initial audit cycle has expired (2 years frm the clsing meeting f the initial audit). Any facility that tries t schedule a clsure audit 18 mnths r mre frm the prir initial audit will be asked t schedule a new initial audit Daily Wrap-up Meeting The auditrs will meet at the end f each audit day with the auditee s management t discuss the day s findings, prvide the pprtunity fr the auditee t present additinal evidence and discuss issues where additinal infrmatin may be needed t cmplete the evaluatin. The auditrs will recap and agree upn the agenda fr the remaining nsite audit with the auditee management and clarify any further needs t ensure the audit is perfrmed as effectively and efficiently as pssible. This is needed t prevent surprises at the clsing meeting and t give auditee management the pprtunity t prvide evidence r infrmatin that the auditr may have verlked. Daily wrap-up meetings are apprximately 30 minutes r less. During the meeting, the auditr shuld: Discuss any Pririty findings, including need fr immediate crrectin r cntainment f nes that cnstitute imminent danger t life. Infrm auditee management that a frmal cmmunicatin f Pririty items will be made t the APM, wh will in turn ntify the auditee s EICC custmers. Make the auditee aware f any issue where the auditrs need additinal infrmatin in rder t make a determinatin f cnfrmance. Encurage the auditee t present/prepare additinal evidence as well as alternative appraches t cmpliance/cnfrmance with the audit criteria and legal requirements. EICC VAP Operatins Manual v502 10

11 Discuss preliminary findings, prviding the pprtunity fr the auditee t prvide additinal infrmatin in the case f a disputed finding. There may be evidence that culd ptentially amend r reverse a finding Clsing Meeting The clsing meeting is held at the end f the last day f the audit. The same grup f auditee persnnel that participated in the pening meeting, as well as any thers wh wuld benefit frm hearing frm the audit team, shuld attend the clsing meeting. All Majr and Pririty audit findings must be presented during the clsing meeting, ensuring that the auditee fully understands thse issues. In instances where the auditrs need t cnduct further studies (e.g. review relevant legislatin) t establish if an issue bserved is indeed a finding, the facts f the pending issues must be discussed with the site management. The auditee is als given the pprtunity t ask questins and prvide additinal evidence r clarificatin. If additinal infrmatin r evidence is required, it must be prvided at this stage. The Audit Finding Acknwledgement (AFA) statement, which is a preliminary recrd f any Pririty r Majr audit findings as well as any ther findings if the auditrs have had time t detail them, is signed at the end f the Clsing Meeting and ed t the APM within 48 hurs f the clsing meeting. The clsing meeting will be cnducted thrugh a frmal presentatin. The auditr can use summary slides created frm the EICC Clsing Meeting Template. If the situatin requires a Clsing Meeting presentatin, the Auditr shuld use the EICC Clsing Meeting Template. If the meeting is nt cnducted r is cut shrt, auditees shuld please ntify the APM. The audit team will als describe the next stage f the audit prcess i.e. the frmal audit reprt cntaining all findings, and the requirement fr the auditee t address the findings with a written imprvement plan that must be prvided t their apprved custmers upn request. Fr Pririty Nncnfrmances, during the clsing meeting: Cmmunicate t auditee management that immediate cntainment actins are mandatry Immediate cntainment actins shuld be cmpleted by the end f the audit Auditr will list the status f the immediate cntainment actins as auditr nte in the cnclusin f the applicable questin in the audit reprt. NOTE: Cntainment des nt apply fr wrking hurs and scial insurance pririty issues. The clsing meeting is als used t thank facility management fr allwing the auditrs t tur the facilities and fr their cperatin during the Audit. The Audit Finding Acknwledgement statement is signed at the end f the clsing meeting and ed t the APM within 48 hurs f the meeting. EICC VAP Operatins Manual v502 11