Guide to the Self-Assessment of SA8000 Social Accountability Management

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Transcription:

Guide to the Self-Assessment of SA8000 Social Accountability Management Systems 61 The guide to self-assessment is a supporting tool in the activities of positioning, planning and start-up of the social accountability management systems. It consists of questions related to each SA8000 standard requirement and includes some blank space for notes and records of objective evidences (subdivided into Strong Points and ). In order to facilitate the self-assessment process, the guide suggests some examples of typologies of objective evidences that may be identified for each standard requirement (column I9). Here you find the suggested method. FIRST STEP - Fill in the self-assessment table according to the following explanations: - for each standard requirement, pay a special attention to the completeness of column C that relates to the self-assessment of compliance of the management system (under this aspect, incomplete self-assessment documentation will not be considered adequate, even if only one item is missing); - in case of non applicability of a standard requirement, fill in box C by reporting the initials N.A. and by motivating the non applicability in the SELF-ASSESSMENT SUMMARY (box I - also in this case, incomplete self assessment documentation will not be considered adequate, even if only one item is missing); - note down concisely, but with care and clarity, the objective evidences highlighted during

the self-assessment process (columns D and E); it is not necessary, although it is recommended, to identify and describe those evidences that can be classified as strong points for each standard requirement in order to obtain the Application Status; on the other hand it is necessary to identify and describe those evidences that can be classified as and relate to the standard requirements the management system has been self-assessed as Not Compliant to (under this aspect, incomplete self-assessment documentation will not be considered adequate, even if only one item is missing); pay attention to column E and indicate only objective evidences and not actions or improvement plans (on instead, the latter has to be described in the SELF-ASSESSMENT SUMMARY - column I). Y, N, N.A. N. REQUIREMENT EVIDENCE 2 FORCED LABOUR Strong Points 2.1 Does the company refrain from engaging in or supporting the use of forced labour? A B C D E 62 SECOND STEP - Fill in the SELF-ASSESSMENT SUMMARY accurately and completely. - In filling in column I, pay particular attention to the completeness, for all those requirements for which the non conformity or the non applicability have been self-assessed in column C (under this aspect, non complete self-assessment documentation will not be considered adequate, even if only one item is missing). - Great care is recommended in filling in column I, as C.I.S.E., in order to acknowledge the SA8000 Applicant status, shall be put in the position to evaluate the adequacy of the improvement actions described (as regards with the SA8000 requirements and the ILO conventions), as well as the real actual existence of the reasons for the non applicability of a standard requirement. - In describing the Actions, specify how much time will be necessary to accomplish each action. Here you find some examples of evidences, which are not meant to be neither compulsory............ F

N.... SELF-ASSESSMENT SUMMARY Action Planned/ State of requirement Motivation of Non Applicability...... NC NA...... G H I TABLE LEGEND: A: Progressive number of the question in the requirement B: Text of the requirement C: To be filled in with one of the following significance: Y = the requirement is compliant N = the requirement is not compliant N.A. = the requirement is not applicable (to motivate in column I) D/E: To be filled in with the objective evidences identified during the self-assessment and conveyed in terms of strong points (D) and areas of improvement (E) F: To be filled in with the description of some examples of objective evidences, which are not meant to be neither compulsory nor exhaustive, in support of the evaluation of compliance with the standard requirements. G: Number of standard requirement H: Indicate if the standard requirement has been considered Not Compliant (NC) or Not Applicable (NA) I: To be filled in with the description of the improvement actions that are planned to address weak points identified or with the motivation of the non-applicability of the requirement. 63 THIRD STEP: send the documentation to: C.I.S.E. Applicant SA8000 Service Corso della Repubblica, 5 47100 Forlì (FC), Italy

N. REQUIREMENT 1.1 Does the company refrain from engaging in or supporting the use of child labour as defined by the standard requirements? Y, N, N/A. 1 1 CHILD LABOUR Strong Points - The copies of the employees identity papers, birth certificates etc, prove that they are younger/ older than the age specified in the definition of child. - The commitment of non-using child labour is stated in the SA8000 policy or in other company records. - There are procedures to ensure reasonably that the company employs no children by mistake. - Records relating to terminations of labour contracts occurred in the latest 6 months confirm that no child has been dismissed in view of the application of the SA8000 standard. - The company supports organisations or programs addressing the problem of children exploitation in workplaces. 64 1

N. REQUIREMENT 1.2 Y, N, N/A. 2 1 CHILD LABOUR Strong Points Policies and procedures for remediation of children found to be working in situations which fit the definition of child labour as provided by the standard requirements: - has the company established them? - documented them? - maintained them? - effectively communicated them to personnel and other interested parties? Has the company provided adequate support to enable such children to attend and remain in school until no longer as child as defined by the standard requirements? - There are documents on policies and procedures for the remediation of children workers, even though there has never been such a case in the company. - The documentation above is written in the languages spoken by the employees. - Employees are aware of the company plans and programs for the remediation of children workers. - There is a communication plan of the company policy and programs for the remediation of children workers. - In case children have been employed, there are records proving the company has paid for books, school uniforms, school fees etc. 65 2

N. REQUIREMENT 1.3 Y, N, N/A. 3 1 CHILD LABOUR Strong Points Policies and procedures for promoting the education for children covered under ILO Recommendation 146 and young workers who are subject to local compulsory education laws or are attending school: - has the company established them? - documented them? - maintained them? - effectively communicated them to personnel and other interested parties? Does the company ensure that none of such children or young worker is employed during school hours? Does the company ensure that combined hours of daily transportation (to and from work and school), school and work time do not exceed 10 hours a day? 66 - School registers or other records confirm that the children employed by the company attend the school regularly. - NGOs or other local groups are involved in/monitor (and this is somehow documented) the programs for the promotion of education that are aimed at ensuring the young workers school attendance. - Employees are aware of the company programs to promote the education and of the cases in which such programs are to be applied. - There are guidelines (or similar) defining the recruitment procedures of young workers. - There are procedures, and are applied, to avoid that children/young workers take more than 10 hours for transportation, school and work. 3

N. REQUIREMENT 1.4 Y, N, N/A. 4 1 CHILD LABOUR Strong Points Does the company refrain from exposing children or young workers to situations in or outside the workplace: - that are hazardous? - that are unsafe? - that are unhealthy? - Children and young workers show they understand safety measures. - There is objective evidence children and young workers are not employed in night shifts (time cards, summary tables of staff presence in the workplace, etc). - The workstations assigned to children and young workers are adequate from the point of view of safety. - Young workers are not assigned jobs that imply the contact with chemical toxic materials. - There are safe means of transport available to take children/young workers home at the end of their working hours. 67 4

N. REQUIREMENT 2.1 Y, N, N/A. 5 2 FORCED LABOUR Strong Points Does the company refrain from engaging in or supporting the use of forced labour? Does the company refrain from requiring new personnel to lodge: - deposits? - identity papers? - Absence of original copies of the employees identity papers at the company. - Employees are not forced to incur debts with the company or its affiliates or, when this is not possible, loans are granted at better conditions than the market ones. - Workers are free to leave at the end of their work shift. - In case security staff is employed, its duties have to be clearly established in its employment contract. - Employees are aware of the regulation concerning the notice of dismissal in order to receive the last wage. - Employees families are allowed to visit their relatives at the factory. 68 5

N. REQUIREMENT 3.1 Y, N, N/A. 6 3 HEALTH & SAFETY Strong Points Does the company provide a safe and healthy working environment, bearing in mind the prevailing knowledge of the industry and of any specific hazards? Has the company taken adequate steps to prevent accidents and injury to health arising out of, associated with or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment? - Passageways are devoid of obstructions; fire exits are not locked, emergency exits are clearly indicated, fire extinguishers are working, available and accessible from all personnel. - Fire extinguishers and emergency exits are adequate to the size and type of company. - Safety switches can easily be reached by workers in case of faulty operation of the equipment. - At the workplace, there is the necessary material for the first aid, as well as personnel trained on purpose, who is adequate to the average number of accidents occurring in the company and to the number of workers employed. - There are plans and procedures for safety and security that are compliant with the applicable law and are adequate to the size and type of company. - Such programs and procedures are known by all the workers and considered effective by them. - There are reports on the accidents occurred and documents highlighting the data processing; such reports do not record recurrent or serious accidents/diseases. - Employees use appropriate individual safety devices, if necessary. - The air temperature and the air quality at the workplace are tested periodically and there are records of such tests. - Protection devices are provided free to workers and are in good condition. - Workers comprehend the need to use protection devices. - Lighting is adequate to carry out the job during all work shifts. - There are records stating the company carries out periodical reviews on safety and health issues. 69 6

N. REQUIREMENT 3.2 3.3 Y, N, N/A. 7 3 HEALTH & SAFETY Strong Points Has the company appointed a senior management representative responsible for the health and safety of all personnel, and accountable for the implementation of the Health and Safety elements of this standard? Has the company ensured that all personnel receive regular and recorded health and safety training? Has the company ensured that such training is repeated for new and reassigned personnel? 70 - There are records confirming the appointment of a senior management representative who is responsible for the health and safety, define his/her role, functions and responsibilities. - The executive staff knows how to describe its responsibilities with regard to SA8000, to the company program of health and safety and to the applicable laws. - There are documents confirming the implementation of the training on health and safety, its timetable and the list of participants. - Employees and their representatives know how to describe the features of the company health and safety programs. - The staff of the first aid service is aware of the types of injuries and accidents that may occur in the company and of the appropriate medical treatment. - Company records and interviews with the workers confirm that the new and reassigned staff is trained properly. - Employees understand the safety symbols at the workplace. 7

N. REQUIREMENT 3.4 3.5 3.6 Y, N, N/A. 8 3 HEALTH & SAFETY Strong Points Has the company established systems to detect, refrain from or respond to potential threats to the health and safety of all personnel? Has the company provided, for use by all personnel: - clean bathrooms? - access to potable water? - sanitary facilities for food storage? Has the company ensured that, if provided for personnel, dormitory facilities are: - clean? - safe? - meet the basic needs of the personnel? - There are procedures, and are applied, to identify potential threats to health and safety in workplaces. - There are procedures, and are applied, to prevent accidents that may be caused by repetitive jobs. - Bathrooms are clean, practical, adequate to the number of workers and easily accessible. - Wage packets confirm that no deduction is made to pay for potable water. - Dormitory facilities are clean and are provided with adequate bathrooms, are properly sized to the number of people they could host and are protected against fire risks. 71 8

N. REQUIREMENT 4 4.1 4.2 4.3 FREEDOM OF ASSOCIATION AND RIGHT TO COLLECTIVE BARGAINING Does the company respect the right of all personnel to form and join trade unions of their choice? Does the company respect the right to bargain collectively? In those situations in which the right of freedom of association and collective bargaining are restricted under law, does the company facilitate parallel means of independent and free association and bargaining for all such personnel? Does the company ensure that representatives of such personnel are not subject to discrimination? Does the company ensure that such representatives have access to their members in the workplace? Y, N, N/A. 9 Strong Points 72 - The right to bargain collectively (or the permission to organise meetings with all personnel, in case such right is restricted under applicable law) is comprised in the company policies and procedures and is known by workers. - There are copies of agreements signed by trade union representatives, workers committee s meeting minutes and copies of collective agreements. - Workers are allowed to exercise their right to collective bargaining, to be provided with the premises (i.e. availability of a meeting room) and the time to meet in a well thought-out way. - Trade unions representatives confirm employers do not interfere with their activities and their access to the production units. - According to company records, trade union representatives have not turned out to receive reduced wages or to be assigned to different jobs. Moreover, they confirm they are able to have the necessary time to meet their fellow-workers. - In case the freedom of association is limited, workers remember when the latest elections of the workers representatives took place, how they were realised, the frequency of meetings, the name of their representatives 9

N. REQUIREMENT 5.1 Y, N, N/A. 10 5 DISCRIMINATION Strong Points Does the company refrain from engaging in or supporting discrimination in: - hiring? - remuneration? - access to training? - promotion? - termination and/or retirement? Based on - race? - caste? - national origin? - religion? - disability? - gender? - sex orientation? - age? - union membership or political affiliation? 73 - There are procedures to prevent all forms of discrimination in workplace including a mechanism to forward complaints that workers know and regard as reliable. - Accounting records confirm that wages are consistent with service, job carried out and professional competence of workers. - Basic criteria have been defined to manage hiring, remuneration, promotion and training; such criteria are not discriminating. - There is a scheme for assigning bonus to workers aiming at refraining from all forms of discrimination. - Relevant records corroborate that, job and position being equal, the same training opportunities are offered to workers. - Independent bodies (NGOs, local associations and trade unions) confirm the company engages in no discrimination practices. - Advertisements for vacancies do not include race, gender or other characteristics that are potentially discriminating. - Records on rejected job applications provide for non-discriminatory motivations. - Company records confirm women workers, job and position in the company being equal, receive salaries, allowances and benefits like men workers. - When considering their service, their acquired competence and the targets they have achieved, women position in the company demonstrate no discrimination is engaged in towards them, as far as their career is concerned. 10

N. REQUIREMENT 5.2 Y, N, N/A. 11 5 DISCRIMINATION Strong Points Does the company refrain from interfering with the rights of personnel to observe tenets or practices, or to meet needs relating to race, caste, national origin, religion, disability, gender, sexual orientation, age, union membership or political affiliation? 5.3 Is the company against allowing behaviours, including gestures, language and physical contact, that are sexually coercitive, threatening, abusive or exploitative? 74 - There are procedures to prevent nuisances, coercion, mobbing etc. in workplace including a mechanism to forward complaints that women know and regard as reliable. - The workforce is made up of members of different ethnic and social groups, following the structure of the local population. - Employees are allowed to observe their religious feasts and celebrate their own religious practices in or outside the workplace. - Company records maintain pregnant women and lactating mothers receive the allowances under the applicable law. - The senior representatives appointed by the management are entitled to prevent all forms of discrimination and to implement corrective actions. 11

N. REQUIREMENT 6.1 Y, N, N/A. 12 6 DISCIPLINARY PRACTICES Strong Points Does the company refrain from engaging in or supporting the use of corporal punishment, mental or physical coercion, and verbal abuse? - Workers do not present signs of physical abuse (scarves, difficulties of deambulation, excoriation etc). - Company records confirm the dismissals occurred in the last six months are not to be ascribed to coercion used by the company. - There is a book (or similar) recording the punishments inflicted to address the violations of the disciplinary internal policy; it also records, and keeps updated, those cases that demand the application of disciplinary measures and the consequent actions taken. - Workers, trade unions and NGOs are aware of the company complaint procedure and are free to forward complaints without suffering from any negative repercussions. 75 12

76 N. REQUIREMENT 7.1 7.2 7.3 Y, N, N/A. 13 7 WORKING HOURS Strong Points Does the company comply with applicable laws and industry standards on working hours, with the specification that, in any case, personnel cannot be requested to work more than 48 hours a week and are provided with at least one day off in every seven-day period? Does the company guarantee that overtime work: - does not exceed 12 hours per employee per week? - is reimbursed at a premium rate? Is overtime work voluntary (other than as permitted in Section 7.3)? Where the company is party to a collective bargaining agreement, is the request of overtime work made in accordance with such agreement? Is such request made to meet short-term business demand? Does such agreement comply with the requirements of Section 7.1? - Payroll confirm the working time does not exceed 48 hours or the maximum under applicable law; they also prove the overtime work does not exceed 12 hours per week and is reimbursed at a premium rate, in accordance with the local/national applicable laws. - There are records describing the conditions that may justify the extension of the normal working hours as a result of extraordinary circumstances; such conditions reasonably prove to be short term and extraordinary economic circumstances. - Company records confirm workers are provided with at least one day off, or more, in every seven-day period, in accordance with the local/national applicable laws. - Workers are not forced to work overtime. - If compared with the number of workers, the total production confirms the personnel comply with a normal working time. - The number of accidents due to the heavy work is not disproportionate neither to the type of industrial activity performed nor with the average number of accidents occurring in the line of business the company belongs to. 13

Y, N, N/A. 14 N. REQUIREMENT 8 REMUNERATION Strong Points 8.1 Does the company ensure that wages paid for a standard working week: - meet legal or industry minimum standards? - is sufficient to meet basic needs of personnel? - provides some discretionary income? 8.2 Does the company ensure that deductions from wages are not made for disciplinary purposes? Does the company ensure that wage and benefit composition is detailed clearly and that the latter is rendered in the most convenient manner for workers? 8.3 Does the company ensure that labour-only contracting arrangements and false apprenticeship schemes are not undertaken in effort to refrain from fulfilling its obligations to personnel under applicable laws pertaining to labour and social security legislation and regulations? - Pay packets confirm remuneration meets the legal or industry minimum standards. - The wages paid by the company are sufficient to meet basic needs and to provide some discretionary income. - Wages are adequate, taking into consideration the fees of local transport to reach the workplace, too. - No extra deductions for disciplinary or discriminatory purposes are pointed out in the pay packets. - Pay packets, or other records at the company, confirm workers are paid regularly and wage composition is described to workers in their own language, in order to ensure their comprehension. - In case workers receive lower wages during their training periods, there are records that define the maximum duration of such periods and ensure the respective wage is not lower that the minimum standard under applicable law. - There are records proving apprenticeship schemes are not used to reduce or cease wages to workers who are regularly employed - Employment contracts confirm wages are not reduced because of, for instance, equipment faulty operations or raw material shortages. - In case there is an increasing tendency of using fixed-term contracts or engaging contracted personnel, this is the result of actual changes in the company requirements and not a way to refrain from paying the due allowances to workers. - There are no forms of employment intermediation. - In case external companies, under co-operative form too, are engaged to provide the organisation applying the SA8000 standard with labour, such workers receive salaries that are comparable to those workers directly employed receive, jobs being equal. Such workers do not depend hierarchically on the employees of the company applying the SA8000 standard. 77 14

78 N. REQUIREMENT 9.1 Y, N, N/A. 15 9 MANAGEMENT SYSTEM Strong Points Policy Has top management defined the company s policy for social accountability and labour conditions to ensure that it: - includes a commitment to conform to all requirements of this standard? - includes a commitment to comply with national and other applicable law, other requirements to which the company subscribes and to respect the international instruments and their interpretation (as listed in this standard)? - includes a commitment to continual improvement? - is effectively documented, implemented, maintained, communicated and is accessible in a comprehensible form to all personnel, including directors, executives, management, supervisors, and staff, whether directly employed or contracted? - is publicly available? - The company s policy is illustrated in the language(s) workers understand; it consists of a commitment to comply with the requirements of the standard and to a continual improvement and is endorsed by the top management. - The policy is conveyed to the workplace and is understood by workers. 15

N. REQUIREMENT 9.2 9.3 9.4 Y, N, N/A. 16 9 MANAGEMENT SYSTEM Strong Points Management Review Does top management review periodically the adequacy, suitability and continuing effectiveness of the company s policy, procedures and performance results vis-àvis the requirements of this standard and other requirements to which the company subscribes? Has top management considered the company s performance and approach by availing of the tool of the SA8000 report in the management review? Have any system amendments and improvements been implemented where appropriate? Company Representatives Has the company appointed a senior management representative who, irrespective of other responsibilities, ensures that the requirements of this standards are met? Has the company provided for non-management personnel to choose a representative from their own group to facilitate communication with senior management on matters related to this standard? 79 - Records on management review are updated and filed; they confirm reviews are performed periodically in accordance with the procedures; the top management takes part to such meetings. - Workers know by whom the role of SA8000 representative of non-management personnel is filled or who makes up the Social Accountability Staff Committee and remember when the relevant elections took place. - There are records confirming the SA8000 representative of non-management personnel was elected following the trade union procedures, when there is a trade union. - There are records substantiating the non-management staff representative is entitled and has the authority to draw the attention of the top management on issues concerning SA8000, so that it may take them into consideration and promote them. - There are records confirming that a senior management representative was appointed and provided with clear responsibilities including the authority to implement corrective or preventive actions, when necessary. - The SA8000 report is drafted according to the indications provided by C.I.S.E. at the web site www.ethicalwork.org/sa8000report. 16

N. REQUIREMENT 9.5 Y, N, N/A. 17 9 MANAGEMENT SYSTEM Strong Points Planning and Implementation Does the company ensure that the requirements of this standard are understood and implemented at all levels of the organisation? Do methods for the comprehension and the implementation include: - the clear definition of rules, responsibilities and authority? - the training of new and/or temporary employees upon hiring? - the periodic training and awareness programs for existing employees? - continuous monitoring of activities and results to demonstrate the effectiveness of systems implemented to meet the company s policy and the requirements of this standard? 80 - There are records confirming new employees are adequately trained on the SA8000 standard. - SA8000 requirements are known and understood at all levels. - There are records that testify clear responsibilities are defined with regards to SA8000, and especially refer to the top management. - There are appropriate records that are regularly updated, in order to highlight the continual compliance with the SA8000 requirements. - There is a system to ensure the continuous monitoring of activities and results, in order to prove the effectiveness of the company policy for SA8000. 17

Y, N, N/A. 18 N. REQUIREMENT 9 MANAGEMENT SYSTEM Strong Points 9.6 9.7 9.8 9.9 Control of Suppliers/Subcontractors and Sub-suppliers Has the company established, and does it maintain, appropriate procedures to evaluate and select suppliers/subcontractors and, where appropriate, sub-suppliers, based on their ability to meet the requirements of this standard? Does the company maintain appropriate records of suppliers/subcontractors and sub-suppliers commitment to social accountability, including, but not limited to, the written commitment of those organisation to: - conform to all requirements of this standard (including this clause)? - participate in the company s monitoring activities as requested? - promptly implement remedial and corrective actions to address any nonconformance identified against the requirements of this standard? - promptly and completely inform the company of any and all relevant business relationship with other suppliers/ subcontractors and sub-suppliers? Does the company maintain reasonable objective evidence that the requirements of this standard are being met by suppliers and subcontractors? Does the company ensure suppliers/ subcontractors or sub-suppliers who are classified as homeworkers, in case it relies on them, a similar level of protection as would be ensured to directly employed personnel under the requirements of this standard? In order to ensure such protection, does the company: - establish legally binding, written purchasing contracts requiring conformance to the requirements of this standard? 81 18

- ensure that the requirements of the written purchasing contract are understood and implemented by homeworkers and all other parties involved in the purchasing contract? - maintain, on the company premises, comprehensive records detailing: - the identities of homeworkers? - the quantities of goods produced/services provided? - and/or hours worked by each homeworker? - implement frequent monitoring activities? 82 - There is an information system that has been set in order to identify the most critical situations among suppliers/sub-suppliers with regard to their compliance with the SA8000 requirements. - There is a structured assessment system to provide for the selection of suppliers on the bases of their conformance to SA8000. - There are records confirming such assessment procedure has been followed to insert the suppliers in the list of the approved suppliers. - There is a procedure that continually evaluates the suppliers to ensure their continual compliance with the SA8000 standard. - Names, addresses and statements signed by all suppliers with reference to their commitment to SA8000 are recorded and filed. - There are records describing the findings of the audits carried out at the suppliers premises; such records can be viewed. - There is written evidence of the suppliers commitment to report the company the names of all suppliers and sub-suppliers with whom they carry on relevant business relationships. - There is, and is recorded, a system to manage those suppliers who do not maintain their compliance with the standard. - There is evidence of improvement in the results achieved in specific cases of suppliers/subcontractors and sub-suppliers with regard to SA8000.

Y, N, N/A. 19 N. REQUIREMENT 9 MANAGEMENT SYSTEM Strong Points 9.10 Concerns and Corrective Actions Does the company investigate, address and respond to the concerns of employees and other interested parties with regard to conformance/nonconformance with the company s policy and to the requirements of this standard? Does the company refrain from disciplining, dismissing or otherwise discriminating against any employee for providing information concerning observance of the standard? 9.11 Has the company implemented remedial and corrective actions and allocated adequate resources that are appropriate to the nature and severity of any nonconformance identified against the company s policy and the requirements of this standard? Has the company established a procedure to manage complaints and appeals in order for the workers to provide with suggestions/ complaints in an anonymous way? Does such procedure include the option for workers and/or other interested parties to appeal directly to the certification body? Has such procedure been brought to knowledge of workers and/or other interested parties? Have the actions taken following to any complaint been brought to knowledge of workers and/or other interested parties? - There is an official procedure, and is implemented, to address and to answer the issues raised by third parties with reference to the company s performance on the standard. - Workers are aware, and there is evidence that they actually use it, of the internal anonymous complaints system (for instance: a suggestion box is accessible in a protected way, there is an intranet mailing system etc..). - Workers and company records (pay rolls, list of dismissed personnel, etc.) confirm no measure has been taken against any employee for providing information concerning observance of the standard. - The company has not taken any retaliation against those employees who have reported concerns or provided information on the observance of the SA8000 standard. 83 19

84 N. REQUIREMENT 9.12 9.13 9.14 Y, N, N/A. 20 9 MANAGEMENT SYSTEM Strong Points Outside Communication Has the company established, and does it maintain, procedures to communicate regularly to all interested parties data and other information regarding performance against the requirements of this document, including the results of management reviews and monitoring activities? Does such procedure include the circulation of SA8000 report to all interested parties? Access for Verification Where required by contract, does the company provide reasonable information and access to interested parties seeking to verify conformance to the requirements of this standard? Where further required by contract, are similar information and access afforded by the company s suppliers and subcontractors through the incorporation of such a requirement in the company s purchasing contracts? Records Does the company maintain appropriate records to demonstrate conformance to the requirements of this standard? - There is a procedure to provide with information documents on policies and observance of the standards requirements by the company; copies of previous similar communications to employees are filed (they are also accessible by other interested parties). - Employees and other interested parties have access to such information documents. - Company documents on policy and targets include the commitment to the SA8000 certification. - The SA8000 report is drafted according to the indications provided by C.I.S.E. at the web site www.ethicalwork.org/sa8000report. - The interested parties have participated to the process of definition of the company social accountability targets. 20

SELF-ASSESSMENT SUMMARY N. State of requirement Action Planned/Motivation of Non Applicability... NC NA... NC NA... NC NA... NC NA... NC NA 85... NC NA... NC NA... NC NA... NC NA Fill in more than one page, if necessary

Acknowledgement of the Applicant Status The organisation seeking the acknowledgement of the Applicant Status applies to a SAI accredited certification auditing body. Such body considers the self-assessment documentation forwarded by the applying facility and details the eventual shortcoming identified in an evaluation report. In the following table adopted by C.I.S.E., the typology of shortcoming is illustrated together with the relevant effects: 86 Typology of shortcoming Incompleteness in filling in the column on the state of compliance of the social accountability system with regard to each requirement Lack of motivation of the requirements defined as Not Applicable (NA) Lack of description of the improvement action for each requirement defined as not compliant Inadequate number of evidences identified (first part of the guide to selfassessment) Inadequacy (with regards to the spirit of the standard and to the ILO conventions) of the content of the improvement actions to the nonconformances highlighted Inadequacy of the motivation provided on the Non Applicability of a requirement Effects Applicant Status recognised only after proper integration of the self assessment documentation by the company Applicant Status recognised only after proper integration of the self-assessment documentation by the company Applicant Status recognised only after proper integration of the self-assessment documentation by the company Applicant Status recognised Applicant Status recognised only after proper integration of the self-assessment documentation by the company Applicant Status recognised only after proper integration of the self-assessment documentation by the company The facility commits to apply for a certification audit within one year from the date of issue of the Applicant certificate. The facility may maintain the Applicant Status for no more than three consecutive years; the Applicant Status Certificate will indicate if it is a second or third renewal. In case of renewal, the organisation will have to pay once again the fee agreed upon. Such recognition allows the facility to define publicly itself as SA8000 Applicant and to give visibility to the certificate, which is notified to SAI by the certification body.

Planning and implementation of the Management System The objective evidences identified during the self-assessment are the main contribution (together with the requirements of the SA8000 standard and other legally binding requirements) to the process of planning of the social accountability system of the facility. Other important contributions are: - the expectations of the various stakeholders; - the economic, social and cultural background; - the features of the line of business and of the supply chain; - the size of the facility; - the state of art; - the location of the productive activities. The following is to be considered as outcome of the planning of a social accountability system: - overall results disclosed by the self-assessment process; - improvement plans outlined against nonconformances highlighted during the self-assessment activity; - validation of system-wide elements whose presence has already been identified during the self-assessment process; - identification of a set of indicators that describe the results produced by the system of social accountability; - identification of the management system and of the review pattern of the above mentioned set of indicators and of the targets defined as objectives; - mechanisms and bilateral relations to encourage in the facility (internal relation system); - arrangement of a proper working environment and adequate working conditions - culture and awareness relating to social accountability in the facility. What follows is generally not to be considered as relevant outcome: - a social accountability system handbook (not compulsory); - recorded procedures of company praxis (not necessarily written); - objective evidence collection system based exclusively on documents. 87 Preliminary Proceeding: Information Dossier In accordance with point 150.1 of the SAI Guidance Document, C.I.S.E. proceeds with the opening of an information dossier on the facility seeking certification. The collection of data and information regards: - the social, economic and political situation of the area or the country where the facility to certify is located (indicators of the quality of life, rate of school attendance, income per capita, cost of the basket of goods, minimum living wage, etc); - features of the country/area culture and customs; - critical issues in the reference geographical area; - concerns and problematic issues in the line of business, with particular attention to health in workplaces; - national applicable law; - collective agreements of the line of business in which the facility operates. The gathering of such information takes place mainly, but not only, by resorting the following tools: - newspapers, reviews and periodicals, books, publications editing by the interested parties; - internet and data bases;

- records of updated national laws; - public registers of companies; - collaborations with local and national interested parties active in the field of human and workers rights: NGOs, trade unions, trade associations. All information so collected is hold in a proper file that is available for consultation and is handed over to the auditing team before the certification audit. First Part of the Certification Audit The first part of the certification audit replaces the typical phase of document analysis : its main aim is to get to know and to evaluate the social accountability system planned by the facility through the investigation on the knowledge of laws and regulations and of the applicable requirements, and to gather all the information (sizes of the company site, logistic arrangements of the staff, availability of dormitory facilities, features of the work places, bathrooms, drinking water, rooms where interviews could take place, likelihood to interview representatives of local interested parties etc.) that is useful to plan and implement the second part of the certification audit. During the first part of the certification audit, the audit team convenes with the company management for a short introductory meeting; this is followed by the audit and by a final meeting, when the results highlighted are illustrated. After pointing out the relevant concerns, the audit team plans the second part of the certification audit and issues an evaluation report. 88 Second Part of the Certification Audit The second part of the certification audit aims at evaluating whether the social accountability system implemented by the facility is compliant with the standard, whether it is actually enforced and whether it is able to ensure its continual improvement. The second part of the certification audit also opens with the meeting of the audit team with the management and the executive staff of the facility to describe the aims and the approach of the audit itself; the meeting is then followed by the conduction of the audit through workers interviews and the collection of objective evidences. The audit closes with the final meeting with the top management to illustrate the conclusions and to highlight eventual major or minor non-compliance. In case of major non-compliance, the certificate will be issued only after its resolution through the implementation of the corrective actions to be verified in a further site verification. All documentation regarding the certification audit is forwarded to the Certification Committee who is in charge to decide on the issue of the certificate. The Certification Committee The Certification Committee (CC) is in charge with the issue, the suspension and the withdrawal of the certificate and is composed by: - technical members, who participate with consultative functions and have no right to vote (C.I.S.E., certification bodies adhering to EWN); - super partes bodies (associations promoting quality governance, public bodies dealing with workers rights and workplace conditions, public administrations, etc.) - bodies representing the industrial sector (employers association)

- bodies representing workers (main trade unions) - bodies representing interested parties (social investment funds, consumers associations, NGOs); - the president of the certification committee (CC), who is elected among the representatives of the super partes bodies. The meetings of the CC are valid if at least one component of each of the four categories is present (industrial sector, representatives of workers, interested parties, super partes bodies) in addition to the President or the Vice president. Each category expresses 10 votes whatever is the number of voters belonging to it; the 10 votes of each category are then subdivided into equal parts among voters of the category itself. The decisions taken are deemed valid if approved with a favourable unanimous vote and confirmed by the list of voters names included in the minutes. In case unanimity is not reached because of technical disagreements, a supplementary investigation is required. In case the disagreement is political, the vote is to be taken by a majority. The functioning of the CC is conceived to ensure an equal representation of all interested parties and to allow the addition of further representations continually. The attendance to the CC is not for value. Surveillance Audits The certificate has a three-year validity, in which the facility undergoes periodical surveillance audits that take place every 6 months as a rule, unless non-conformances or particular situations of concern occur and require, on C.I.S.E. view, the anticipation of the audit. Nevertheless, in case no non-conformances arise during the surveillance audit, and on the basis of its outcomes, C.I.S.E. has the faculty of planning the following surveillance audit after 12 months, instead of 6. Likewise, C.I.S.E. has the faculty to carry out extraordinary audits on the state of the social accountability systems of the facilities in case it deems it convenient (for instance in case of direct or indirect claim forwarded by clients of certified facilities or by other interested parties). The maintenance of the certification requires the certified facilities prove: - the accomplishment of the corrective actions planned to address to the non-conformances by the fixed time limit; - the compliance in time of the social accountability system with the requirements of the SA8000 standard and with C.I.S.E. regulation of certification; - the actions started pursue the continual improvement of the social accountability system. The non-implementation, even partial, of an improvement plan implies the discussion of the proposed suspension of the certificate by the Certification Committee. 89 SA8000 Report In a global economy, companies need to portray their social image more and more, as well as they need to be recognised as socially accountable actors. Their need to communicate the ethical values inspiring the business management arises from this, as well as their need to identify a way to highlight and survey the ethical and social results achieved, and to report them to the community of stakeholders. Various approaches attempt to define social statement tools to enable companies to implement a transparent and extensive communication strategy that is able to foster social legitimacy and the agreement of the parties concerned, as premise of the achievement of the business targets.

Among the social statement tools, the SA8000 report is characterised by proposing a set of clear and relevant indicators of the compliance with each SA8000 requirement of the company management system, whose observance has already been certified by a third party body. The following paragraph draws the attention to the SA8000 purposes and describes the principles of its compilation. Although such principles are important as guide lines and do not have a prescriptive relevance, the SA8000 report is considered by Ethical Work Network as a well-structured tool to address to some SA8000 system requirements such as Management Review (9.2) and Outside Communication (9.12). An exemplifying prototype of the SA8000 report is offered at the web site www.ethicalwork.org/sa8000report. 90 Purposes and Principles of SA8000 Report The SA8000 report intends to: - let all interested parties know about the company policy for social accountability; - favour the knowledge and comprehension of the actual commitments of the company with regard to the SA8000 standard by all stakeholders. The evaluation carried out by the certification body (C.I.S.E.), or by the auditing bodies who are members of Ethical Work Network, on the contents of the SA8000 report ensures that the document provides for a complete, accurate and relevant picture of the company performance; - provide the company management with a useful tool to review the policy for social accountability and to verify the achievement of the business targets; - highlight the continual improvement of the business management through the trend of the indicators used. The compilation of the SA8000 report shall comply with the following principles: - periodicity: the document shall cover a defined reporting period. In order for the business results to be adequately evaluated, the indicators of a period will have to be accompanied by indicators of at least two previous periods. Only in this way they will lay emphasis on the trend of the business management; - relevance and meaningfulness: all quantitative and qualitative pieces of information contributing to prove the compliance with SA8000 requirements have to be included. Special attention needs to be paid to that information whose omission could reasonably affect the evaluation of the users of the report; - completeness and accuracy: the qualitative and quantitative information included in the report are to cover all 9 macro-requirements of the SA8000 standard and are to be selected accurately; - referability: the results achieved have to be reasonably brought back to the actions started so to emphasise the mutual relation approach - performance ; - comparability: trends of indicators are to give emphasis to the positioning of the company with regard to external benchmarks, when available; - comprehensibility: all information provided by the SA8000 report is to be clear and comprehensible, in order to favour the transparency of the policy for social accountability pursued by the company; - Faithful representation: the SA8000 report has to be endorsed either by the legal representative of the company (who takes the responsibility of the information provided, besides the audit carried out by the auditing body) and by the SA8000 representative(s) of non management staff.