Capr Zaa600030816
Capr Zaa600030816
Capr Zaa600030816
1
Sedex Audit Reference:
Sedex Audit Reference:
SMETA
SMETACorrective Action
Corrective ActionPlan
PlanReport
Report (CAPR)
(CAPR) Version 6.1
ZAA600030816 Version 6.1
Audit Content:
(1) A SMETA audit was conducted which included some or all of Labour Standards, Health &
Safety, Environment and Business Ethics. The SMETA Best Practice Version 6.1 (March 2019)
was applied. The scope of workers included all types at the site e.g. direct employees,
agency workers, workers employed by service providers and workers provided by other
contractors. Any deviations from the SMETA Methodology are stated (with reasons for
deviation) in the SMETA Declaration.
(2) The audit scope was against the following reference documents
2-Pillar SMETA Audit
• ETI Base Code
• SMETA Additions
• Universal rights covering UNGP
• Management systems and code implementation,
• Responsible Recruitment
• Entitlement to Work & Immigration,
• Sub-Contracting and Home working,
4-Pillar SMETA
• 2-Pillar requirements plus
• Additional Pillar assessment of Environment
• Additional Pillar assessment of Business Ethics
• The Customer’s Supplier Code (Appendix 1)
(3) Where appropriate non-compliances were raised against the ETI code / SMETA Additions
& local law and recorded as non-compliances on both the audit report, CAPR and on
Sedex.
(4) Any Non-Compliance against customer code shall not be uploaded to Sedex. However,
in the CAPR these ‘Variances in compliance between ETI code / SMETA Additions/ local
law and customer code’ shall be noted in the observations section of the CAPR.
Guidance
The Corrective Action Plan Report summarises the site audit findings and a corrective, and preventative
action plan that both the auditor and the site manager believe is reasonable to ensure conformity with the
ETI Base Code, Local Laws and additional audited requirements. After the initial audit, the form is used to re-
record actions taken and to categorise the status of the non-compliances.
N.B. observations and good practice examples should be pointed out at the closing meeting as well as
discussing non-compliances and corrective actions.
To ensure that good practice examples are highlighted to the supplier and to give a more ‘balanced’ audit
a section to record these has been provided on the CAPR document (see following pages) which will
remain with the supplier. They will be further confirmed on receipt of the audit report.
Root cause (see column 4)
Root cause refers to the specific procedure or lack of procedure which caused the issue to arise. Before a
corrective action can sustainably rectify the situation, it is important to find out the real cause of the non-
compliance and whether a system change is necessary to ensure the issue will not arise again in the future.
See SMETA BPG Chapter 7 ‘Audit Execution’ for more explanation of “root cause’’.
Next Steps:
1. The site shall request, via Sedex, that the audit body upload the audit report, non-compliances,
observations and good examples. If you have not already received instructions on how to do this
then please visit the web site www.sedexglobal.com.
2. Sites shall action its non-compliances and document its progress via Sedex.
3. Once the site has effectively progressed through its actions then it shall request via Sedex that the
audit body verify its actions. Please visit www.sedexglobal.com web site for information on how to
do this.
4. The audit body shall verify corrective actions taken by the site by either a "Desk-Top” review process
via Sedex or by Follow-up Audit (see point 5).
5. Some non-compliances that cannot be closed off by “Desk-Top” review may need to be closed off
via a “1 Day Follow Up Audit” charged at normal fee rates. If this is the case, then the site will be
notified after its submission of documentary evidence relating to that non-compliance. Any follow-
up audit must take place within twelve months of the initial audit and the information from the initial
audit must be available for sign off of corrective action.
6. For changes to wages and hours to be correctly verified it will normally require a follow up site visit.
Auditors will generally require to see a minimum of two months wages and hours records, showing
new rates in order to confirm changes (note some clients may ask for a longer period, if in doubt
please check with the client).
Audit Details
Sedex Company ZC409972362 Sedex Site Reference: ZS409993019
Reference: (only available on Sedex System)
(only available on Sedex System)
Audit Conducted By
Affiliate Audit Purchaser Retailer
Company
Brand owner NGO Trade Union
Audit Parameters
Time in and time out Day 1 Day 2
In 09:00 In 08:00
Out 17:30 Out 12:00
Audit type: PERIODIC
Was the audit announced? ANNOUNCED
Was the Sedex SAQ available for review? Yes
Any conflicting information SAQ/Pre-Audit Info to No
Audit findings?
Summary of Findings
Issue Area of Number of issues Findings
Non–Conformity
(please click on the issue title to go direct to the Local
ETI NC Obs GE
appropriate audit results by clause) Law
Issue Description
§1 In accordance with Article 41 of the Labor Law of the PRC, after consultation
with the trade union and employees, the employer may extend working hours
due to its production or business needs, but the extended working hours shall
not generally exceed one hour a day; in special circumstances that require an
extension of working hours, the extended working hours shall not exceed 3
hours a day and 36 hours a month on condition that the health of employees is
guaranteed.
§2 In accordance with Article 14 of the Regulation For Chemical Usage Safety in
Work Place: (1) In case of transferring or loading the chemicals purchased into
a new container, it is required to mark clearly the descriptions of these
chemicals on the newly adopted container. As to those hazardous chemicals
that have been transferred or loaded into a new container, it is necessary to
stick a safety precautions mark on the new container. (2) The original safety
precautions mark upon those containers that contain hazardous chemicals
shall not be replaced before these containers have been cleansed.
§3 In accordance with Warning Sign in the Guidelines for Safety Signs and Usage
GB 2894-2008, article 4.2.3, warning sign, form 2, 2-7, electric shock warning
sign set up scope and location: electricity devices and circuit where electric
shock may happen.
Non-Compliance Evidence
Non-Compliance
Status OPEN
Reference ZAF600208965
Clause 6 - Working hours are not excessive
Issue Title 480 - Overtime is not used responsibly i.e. extent,
frequency and level of hours worked by individual
workers and / or whole workforce are excessive
Subcategory Overtime
New or carried New Carried Over
over?
Raised by audit ZAA421514088
Root cause Training System
Costs Lack of workers
Other
Root cause - N/A
Other
Local law issue In accordance with Article 41 of the Labor Law of the
PRC, after consultation with the trade union and
employees, the employer may extend working hours
due to its production or business needs, but the
extended working hours shall not generally exceed
one hour a day; in special circumstances that require
an extension of working hours, the extended
working hours shall not exceed 3 hours a day and 36 IMG20231025143636.jpg
hours a month on condition that the health of
employees is guaranteed.
ETI code 6.1 - Working hours must comply with national laws,
collective agreements, and the provisions of 6.2 to
6.6 below, whichever affords the greater protection
for workers. Sub–clauses 6.2 to 6.6 are based on
international labour standards.
Explanation to Based on attendance records of 10 samples from 01
the non October 2020 to audit day review, it was found that
compliance during this period, all sample workers’ monthly
overtime exceeded 36 hours in most months. Three
sampled months September 2021(current paid
month), July 2021 (random) and December 2020
(random month) were randomly selected. It was
found that all sample workers’ monthly overtime
was 72 hours in September 2021. All sample
workers’ monthly overtime was 84 hours in July 2021
and all sample workers’ monthly overtime was 78
hours in December 2020. 根据2020年10月1日到审核
当天的10个样本的考勤记录,发现这段时间全部抽样员
工大部分月份月加班超过36小时。抽样的三个月
:2021年9月(当前支付工资月份),2021年7月(随机
月)和2020年12(随机月)月中,显示抽样全部员工中
在2021年9月月加班为72小时。全部员工中在2021年7月
月加班为84小时,在2020年12月,全部员工的月加班为
Non-Compliance Evidence
Non-Compliance
Status CLOSED
Reference ZAF600208966
Clause 0B - Management systems and code implementation
Issue Title 29 - No / inadequate management awareness of the
social and ethical standards required / ETI base code
Subcategory Site's Awareness of Code/Legal Requirements
New or carried New Carried Over
over?
Raised by audit ZAA421514088
Resolved by ZAA600030816
audit
Root cause Training System
Costs Lack of workers
Other
Root cause - N/A
Other
ETI code 0.B.3 - Suppliers are expected to communicate this
Code to all employees.
Explanation to Part of workers were not aware of the ETI code.
the non During worker interview, 3 out of 10 workers
compliance interviewed were not aware of the ETI code. Periodic IMG20231025141251.jpg
audit conducted on 25-26/10/2023: Closed Per
training records review and interview workers were
all aware of the ETI base code. 根据培训记录查看及员
工访谈,所有员工已清楚ETI基本准则。
Follow up Follow up audit Desktop audit
method
Timescale Immediate 30 days 60 days
90 days 120 days 180 days
365 days Other
Actions It is recommended that all workers are made aware
of the content of the ETI code. 建议企业增强员工对
ETI 准则的理解。
Additional It is recommended that all workers are made aware
comments of the content of the ETI code.
建议企业增强员工对ETI 准则的理解。
Periodic audit conducted on 25-26/10/2023: Closed
Per training records review and interview, workers
were all aware of the ETI base code.
根据培训记录查看及员工访谈,所有员工已清楚ETI基本
准则。
Non-Compliance Evidence
Non-Compliance
Status CLOSED
Reference ZAF600225136
Clause 3 - Working conditions are safe and hygienic
Issue Title 233 - Hazardous chemicals are stored unlabelled or
labelling is incorrect
Subcategory Chemicals
New or carried New Carried Over
over?
Resolved by ZAA600030816
audit
Root cause Training System
Costs Lack of workers
Other
Root cause -
Other
Local law issue In accordance with Article 14 of the Regulation For
Chemical Usage Safety in Work Place: (1) In case of
transferring or loading the chemicals purchased into
a new container, it is required to mark clearly the
descriptions of these chemicals on the newly
adopted container. As to those hazardous chemicals
that have been transferred or loaded into a new
container, it is necessary to stick a safety precautions IMG20231025103510.jpg
mark on the new container. (2) The original safety
precautions mark upon those containers that
contain hazardous chemicals shall not be replaced
before these containers have been cleansed.
ETI code 3.1 - A safe and hygienic working environment shall
be provided, bearing in mind the prevailing
knowledge of the industry and of any specific
hazards. Adequate steps shall be taken 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.
Explanation to It was noted that chemicals (e.g. lubricating oil) used
the non in workshop was not labelled with their contents and
compliance hazard warnings. 车间使用的化学品(如润滑油)没有
张贴标示及危险警告标识。
Follow up Follow up audit Desktop audit
method
Timescale Immediate 30 days 60 days
90 days 120 days 180 days
365 days Other
Non-Compliance Evidence
Non-Compliance
Status CLOSED
Reference ZAF600225137
Clause 3 - Working conditions are safe and hygienic
Issue Title 227 - Unmarked / incorrect labels / signage /
instructions for electrics
Subcategory Electrical risk
New or carried New Carried Over
over?
Resolved by ZAA600030816
audit
Root cause Training System
Costs Lack of workers
Other
Root cause -
Other
Local law issue In accordance with Warning Sign in the Guidelines
for Safety Signs and Usage GB 2894-2008, article
4.2.3, warning sign, form 2, 2-7, electric shock
warning sign set up scope and location: electricity
devices and circuit where electric shock may happen.
ETI code 3.1 - A safe and hygienic working environment shall
be provided, bearing in mind the prevailing IMG20231025110043.jpg
knowledge of the industry and of any specific
hazards. Adequate steps shall be taken 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.
Explanation to It was noted that no warning sign was marked on
the non the switch boxes at kitchen. 厨房的电箱没有张贴警告
compliance 标志。
Follow up Follow up audit Desktop audit
method
Timescale Immediate 30 days 60 days
90 days 120 days 180 days
365 days Other
Actions It is recommended that the factory should provide
proper electrical training to workers, conduct
regular electrical safety inspection, ensure the
covers of power switches are completed and posted
warning sign. 建议工厂给相关工人提供电气安全培训
,进行定期电气安全检查,确保所有电源开关外壳完整
无损及张贴警告标志。
SMETA Declaration
I declare that the audit underpinning the following report was conducted in accordance with SMETA Best
Practice Guidance and SMETA Measurement Criteria.
(1) Where appropriate non-compliances were raised against the ETI code / SMETA Additions & local
law and recorded as non-compliances on both the audit report, CAPR and on Sedex.
(2) Any Non-Compliance against customer code alone shall not be uploaded to Sedex. However, in
the CAPR these ‘Variances in compliance between ETI code / SMETA Additions/ local law and
customer code’ shall be noted in the observations section of the CAPR.
Auditor Team
Lead Auditor: Flora Wang APSCA Number: 21700615
Additional
Auditors:
Date of 2023-10-26
declaration:
Note: The focus of this ethical audit is on the ETI Base Code and local law. The additional elements will not
be audited in such depth or scope, but the audit process will still highlight any specific issues.
Site Representation
Full Name: Mr. Yi Yi
Title: Quality Manager
Date of 2023-10-26
declaration:
Comments:
Any exceptions to this must be recorded here (e.g. different sample size):
Sampled wage records from the past 5 months were provided for review (5 months only since the operation for digital thermometer just
started last Sep 2020).
The audit took 2.0 man-days (9AM-6PM per day). Audit time was extended until 8PM due to the extent of documentation; this was agreed
upon with the factory representatives
Nil
If a non-compliance is to be rectified by a corrective action which will also prevent the non-
compliance re-occurring, it is necessary to consider whether a system change is required.
Understanding the root cause of the non-compliance is essential if a site is to prevent the issue re-
occurring.
The root cause refers to the specific activity/ procedure or lack of activity /procedure which
caused the non-compliance to arise. Before a corrective action can rectify the situation, it is
important to find out the real cause of the non-compliance and whether a system change is
necessary to ensure the issue will not arise again in the future.
Since this is a new addition, it is not a mandatory requirement to complete this column at this time.
We hope to encourage auditors and sites to think about Root Causes and where they are able to
agree, this column may be used to describe their discussion.
Example 1
Where excessive hours have been noted the real reason for these needs to be understood, whether due to
production planning, bottle necks in the operation, insufficient training of operators, delays in receiving
trims, etc.
Example 2
A non-compliance may be found where workers are not using PPE that has been provided to them. This
could be the result of insufficient training for workers to understand the need for its use; a lack of follow-up
by supervisors aligned to a proper set of factory rules or the fact that workers feel their productivity (and thus
potential earnings) is affected by use of items such as metal gloves.
Example 3
A site uses fines to control unacceptable behaviour of workers.
International standards (and often local laws) may require that workers should not be fined for disciplinary
reasons.
It may be difficult to stop fines immediately as the site rules may have been in place for some time, but to
prevent the non-compliance re- occurring it will be necessary to make a system change.
The symptom is fines, but the root cause is a management system which may break the law. To prevent the
problem re-occurring it will be necessary to make a system change for example the site could consider a
system which rewards for good behaviour
Only by understanding the underlying cause can effective corrective actions be taken to ensure
continuous compliance.
The site is encouraged to complete this section so as to indicate their understanding of the issues raised and
the actions to be taken.
Your feedback on your experience of the SMETA audit you have observed is extremely
valuable. It will help to make improvements to future versions.
You can leave feedback by following the appropriate link to our questionnaire: