Ratool Apparels Ltd. Bangladesh WRAP FCR AR 13638

WRAP CERTIFICATION PROGRAM
Facility Certification Recommendation

Monitor Report No. 13638 To: WRAP Certification Board We have conducted an independent compliance assessment of the facility listed below. As per WRAP Certification Program requirements, we find that practices consistent with the WRAP Production Principles have been in place for a period of not less than ninety (90) days prior to the inspection below. Our independent assessment was made in conformance with the criteria of the WRAP Facility Self-Assessment Handbook and the WRAP Monitors Manual, and done in keeping with the WRAP Policies for Recognition of Monitoring Partners. On May 30, 2013 (date of final inspection) ALGI Bangladesh, performed the (monitoring firm) Factorys WRAP ID No. 14539
WRAP compliance evaluation visit on the facility: Ratool Apparels Ltd.-Bangladesh (Name and country of facility) and hereby recommends it for certification under the WRAP Certification Program. Rasel Parves Name of Independent Lead Monitor May 30, 2013 Date
_____________________________________ Authorized Signature for Independent Monitoring Firm
Angelo Valdevitt Name of Authorizing Official
Date of Initial Compliance Visit: May 30, 2013 Date(s) of Corrective Action Plan Visit(s), (if relevant): __________________________
PHOTOS General Information
Factory Building
Factory Gate
Cutting Section
Sewing Section
WRAP Audit Report ALGI version April 2013
Finishing Section
Packing section
Boiler Room
Generator Room
Fire Fighting Equipments
First Aid Box
Evacuation Plan
Accessories Store
Finished Goods Store
Fire Hose Rill
Fire Alarm
Dining Hall
Medical Room
Child Care Room
WRAP COC Posted
Fire Alarm Bell
Non Compliances
Nil
Best Practices
Nil
Facility Audit Report

Audit Details 14539 13638 Recommendation CAP First-time certification Re-certification CAP follow up Unannounced 1st audit May 30, 2013 Follow up 1 Follow up 2 Follow up 3 Yes No If No, please state the reason(s) why: Yes No If No, why not? ALGI Bangladesh,A-6,11, Gausul Azam Avenue,
WRAP Registration #: Monitor REPORT #: Report Type: Audit Type: Audit Date(s): Was the audit unannounced? Was the Facility Self-Assessment Packet reviewed by the Lead auditor before the audit? Monitoring firm name and address: Auditor Name(s) and role(s):
Sec-14, Uttara, Dhaka-1230

Lead auditor Rasel Paves Audit team members Amirul Islam A.T.M. Anisuzzaman Technical experts N/A Trainee auditors* N/A Others N/A * Trainee auditors are only allowed to observe WRAP audits; they are not allowed to take any active part in the audit. Only WRAP accredited auditors time will count towards the man-day requirements for the audit. Rasel Parves Rashedul Karim June 09, 2013 Day 1 in 09:30 am Day 2 in Day 3 in Day 4 in Day 1 out 05:30 pm Day 2 out Day 3 out Day 4 out Three auditors for one day. Yes No N/A If No, why not? Ratool Apparels Ltd. Bangladesh Mohammed Mostofa-Managing Director Mohammed Mostofa-Managing Director Choyadana, Joydebpur, Gazipur, Bangladesh
Report written by: Report reviewed by: Report issue date: Time in and out of the facility: Total number of man-days for this audit: If a follow up audit, was a factory tour conducted? Facility Name: Country: Facility Main Contact and Title: Who signed and agreed CAP? (Name and title): Full Address of Site covered in this audit: (both English and Local language) Registered Business name and address (in English, and, if needed, local language): Applicable business and other legally required licence numbers: Facility Phone #: Site E-Mail: Products / Activities at Site e.g. garment manufacture, electrical, toys, service, other (please state): Audit results reviewed with facility management?
Ratool Apparels Ltd. Choyadana, Joydebpur, Gazipur, Bangladesh Are these the same as the facility name and address covered in this audit? Yes No If No, please explain: Factory Licence: 15457/Gazipur +88-0682-9293087 mostafa@ratoolapparels.com Garments Manufacturer- Knit Item Yes No If No, please explain:
Policy and Procedures Table

Was the facility in compliance with the requirement to have: Written Policies? 1 2 3 4 5 6 7 8 9 10 11 12 Compliance with Laws and Workplace Regulations Prohibition of Forced Labor Prohibition of Child Labor Prohibition of Harassment or Abuse Compensation and Benefits Hours of Work Prohibition of Discrimination Health and Safety Freedom of Association and Collective Bargaining Environment Customs Compliance Security Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No No No No No No No No No No No Written Procedures? Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes Yes No No No No No No No No No No No No
Policy and procedures
Non-Compliance Table
Area of Non-Conformity Issue (Only check box when there is a non-conformity) WRAP Principles 1 2 3 4 5 6 7 8 9 10 11 12 Compliance with Laws and Workplace Regulations Prohibition of Forced Labor Prohibition of Child Labor Prohibition of Harassment or Abuse Compensation and Benefits Hours of Work Prohibition of Discrimination Health and Safety Freedom of Association and Collective Bargaining Environment Customs Compliance Security Local or National Law
Historic Non-Compliance Table

Area of Non-Conformity Issue (Only check box when there is a non-conformity) WRAP Principles 1 2 3 4 5 6 7 8 9 10 11 12 Compliance with Laws and Workplace Regulations Prohibition of Forced Labor Prohibition of Child Labor Prohibition of Harassment or Abuse Compensation and Benefits Hours of Work Prohibition of Discrimination Health and Safety Freedom of Association and Collective Bargaining Environment Customs Compliance Security Local or National Law
Audit Overview
Site Description: (Include size, location, age, structure, number of buildings) The facility is located at Choyadana, Joydebpur, Gazipur, Bangladesh. The facility comprises of 1 building and 1 shed. Facility description is given below. Building # 1 (7 storied) Ground floor is occupied by child care, doctor room, bonded warehouse, finished goods store and boiler room. First floor is occupied by finishing section. Second floor is occupied by sewing section. Third floor is occupied by sewing section. Fourth floor is occupied by sewing section. Fifth floor is occupied by cutting section. Sixth floor is occupied by workers dining and prayer room. Shed # 1: is occupied by generator room. The facility is of concrete structure with a total built up area of about 3600 sq ft where production areas are about 30,200 sq ft and ware house areas are about 2,500 sq ft. The facility was established in the year 2011. Total number of workers in the factory during the audit was 512 and total production space allocated by the factory for workers was 8456 cubic meter (30200*10=302,000 cubic feet*.028=8456 cubic meter). So space per worker was found 16.51 cubic meters where law requirement is 9.5 cubic meter and was found not overcrowded. Total number of emergency staircase of the factory was two for the building (50 inch both) adequate width. From physical observation, it can assume that worker can evacuate by using those staircase within very short time in case of emergency. Total employees of the
factory was found trained on emergency evacuation and health and safety and total 250 fire fighter was found trained in the factory as per their documents. No other factory is located in the same premise.
Process Overview: (Include products being produced, main operations, number of production lines, chemicals either for production, cleaning or fuel used, main equipment used) Products being produced: All types of knit items. Main operation: Cutting, Sewing, Finishing & Packing. Production lines: 8 sewing lines. Production capacity: 250,000 pieces per month. Chemicals used: Lubricating oil, machine oil, detergent and spot lifter, Main equipment (with numbers): Plain machine: 76, Over lock machine: 76, Flat lock machine: 36, Rib cutter: 2, Hole stitch machine: 5, Button stitch machine: 2, Bartech machine: 1, Fit of the arm: 2, Back tab machine: 2, Kansai: 1, Cutting machine: 3, Fusing machine: 2, etc. Product produced for: Wal-Mart
Worker analysis
Permanent Worker numbers (male) Worker numbers (female) Total number of workers at the facility 103 409 512 Temporary 0 0 Migrant workers (domestic or foreign) 0 0 Agency 0 0 Home workers 0 0
Other personnel
Management 3rd party service providers 0 Security personnel 7 Agency cleaners 0 Agency canteen staff 0 Others (please state) Cleaner 11
30
Worker interviews conducted

Permanent Number of individual interviews Number of groups interviewed 15 15(3*5) Temporary 0 0 Migrant workers (domestic or foreign) 0 0 Agency 0 0 Home workers 0 0
Site information
Were appropriate records available to verify hours of worker and wage compliance? Month(s) of peak season (if applicable): What is the level of lowest wages paid? What is the % of piece rate workers (if Yes No Describe nature of any inconsistencies found: Poor record keeping No records Multiple records Saturday to Thursday Above legal minimum
Same round the Normal Work Days: year e.g. Mon Sat Below legal minimum At legal minimum 0
applicable)? Are the correct overtime premiums paid? Is there any night production work at the facility? What is the % of workers living in facility provided accommodation (if applicable)? Age of youngest worker found: Are workers under 18 subject to hazardous work assignments? What form of worker representation is there on site? Is internal system monitoring conducted by the facility on a regular basis? Yes Yes 0 No No
19 Yes No
Union (name) Worker Committee Other (specify) Yes No Internal audit conducted on April 02, 2013 and MRM on April 03, 2013 (conducted once in one month)
PRINCIPLE 1
COMPLIANCE WITH LAWS AND WORKPLACE REGULATIONS
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY The facility obtains current information on local and national laws and regulations concerning WRAP principles through: training program and posters posted on production floors in notice boards and in front of main entries. Responsible Person for communicating changes of laws and regulations and incorporating in the business practices: Position: Managing Director Name: Mohammed Mostafa Responsible since: November 01, 2011
1.1 Does the facility obtain current information on local and national laws and regulations concerning each of the Principles and incorporate this information in its business practices?
1.1a Does the facility have written policies and procedures for current information on national and local laws and regulations on each of the following WRAP Principles? Compliance with Laws and Workplace Regulations Prohibition of Forced Labor Prohibition of Child Labor Prohibition of Harassment or Abuse Compensation and Benefits Hours of Work Prohibition of Discrimination Health and Safety Freedom of Association & Collective Bargaining Environment Customs Compliance Security
WRAP Policy & Procedure Manual No-01 Issue No-01 Rev 00
WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01
10
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY Issue No-01 Rev 00
1.2 Does the facility have a qualified person responsible for informing the facility of changes to laws and regulations, or access to current publications on national and local labor laws? 1.3 Does the facility update its practices to incorporate revision to existing laws and regulations in a timely fashion? 1.4 Does the facility undertake internal monitoring of its management system (internal audits) to satisfy itself that the written procedures and processes are meeting the requirements of local law and WRAP Principles? 1.5 During the previous two years, has the facility had any notices of noncompliance levied against it (including any legal proceedings or outstanding allegations concerning the facilitys operations)? 1.6Is there a program to train relevant individuals regarding any new laws or revisions to existing laws and regulations? 1.6a Are the materials used for this purpose appropriate? 1.7. Document exceptions to local and national laws, rules, and regulations other than N/A those specifically documented elsewhere in this report. 1.8 Does the facility have a written operating policy manual that include the following: a. The national and local laws and regulations pertaining to the Principles? b. c. The facilitys policies and procedures pertaining to the Principles? Routine updates for revisions to existing laws and regulations?
Name: Mohammed Mostafa Position: Managing Director Responsible since: November 01, 2011
Last revision Minimum wage gazette for garments sector published on October 2010 effective from November 2010
Internal audits have been conducted once on April 02, 2013 and the result showed it meets the local law requirement and WRAP Principles.
N/A (no non compliance levied during past two years.)
Training planner document. Last training April 15, 2013 Subject/s of training: Minimum Wage Gazette published on October 2010, effective from November 2010 Training material used - Hand book given to employees and WRAP principles translated
WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00
WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00 WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00
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AUDIT QUESTIONS
YES
NO
NA
COMMENTARY
Subcontracting
1.9. Does the facility sub-contract any of its production operations? 1.10 Does the facility sub-contract any other operations? 1.11 How has the facility informed the subcontractor of their obligations under the local labor law and WRAP Principle requirements? 1.12 Does the facility keep evidence of how any sub-contractor has been made aware of these requirements? 1.13 Does the facility keep receipt of subcontractor acknowledgement of these requirements? 1.14 Does the facility regularly review its list of sub-contractors to make sure it is up to date? The facility did not use any subcontractor as they have all the process in their factory premises. All the processes are running in the factory premises. They do not have any subcontracting process. The facility did not have any subcontracting process. The facility did not have any subcontracting process.
The facility did not have any subcontracting process.
The facility did not have any subcontracting process.
Best practices observed:

None
1. COMPLIANCE WITH LAWS AND WORKPLACE REGULATIONS
Facilities will comply with laws and regulations in all locations where they conduct business.
Non-compliances raised against this Principle

Nil
Historic Non-compliances raised against this Principle

Nil
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PRINCIPLE 2 FORCED LABOR

AUDIT QUESTIONS 2.1 Are all employees working at the facility voluntarily? 2.2Are there any indications that people's movements are being restricted? 2.3Are there exaggerated security measures or logistics being employed in the facility? 2.4Were there any overt signs of fear or exaggerated obedience displayed by employees during the facility inspection? 2.5Do security personnel act in a non-threatening manner? 2.6 Are security guards posted for normal security reasons, in a proportionately logical number? 2.7 Are the doors and gates of the facility locked only for normal business and housing security reasons in compliance with applicable local and national fire codes? 2.8 Does the facility prohibit all relevant individuals, including any person under the facility's direction (such as security guards), from coercing employees in any way, or unnecessarily limiting employees' freedom of movements? Is employee freedom of movement unimpeded upon their shift's conclusion? 2.9 Does the facility require all hiring documents (e.g. an employment application or contract) to: 1) include a statement affirming that applicants are seeking employment voluntarily and are not under threat of any penalty, 2) be signed by each applicant, and 3) be maintained in the employees personnel file? 2.10 Does the facility obtain proof that anyone seeking employment is legally entitled to work in the country of manufacture in accordance with national immigration laws? YES NO NA COMMENTARY Interviews, document review and visual walkthrough of the facility did not reveal any form of indentured, bonded, or forced labor. Workers are free to leave the factory during the breaks. Walk through and worker interviews did not reveal excessive security arrangements or procedures being used. No signs of fear seen among workers during walkthrough or interviews. Attitude of security guards was judged to be professional and courteous. Walk through of the facility did not reveal any excessive security being deployed. Doors and gates remain open during the operational hours, from 8:00 am to 5:00 pm for. Factory runs through Saturday to Thursday and during overtime hours as needed. Policies, workers interviews and walkthrough of facility did not reveal restriction of movement or employees subjected to coercion. As per interviews and auditors observations, the employees are free to leave after the end of their shift.
Facility requires hiring documents, employment application and contracts to be signed by each applicant and maintained in the personnel files. Measure was corroborated with 30 personnel files reviewed. Contracts include a statement that reflects that employment is on a voluntary basis and not under threat of any penalty.
No immigration workers found in this facility.
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AUDIT QUESTIONS 2.11 Does the facility obtain an executed statement from all labor brokers/agents used by the facility stating that the brokers/agents are not supplying labor that is involuntary or forced, and has the right to work in this country? 2.12 Does the facility have a qualified person responsible for communicating, deploying and monitoring the practices of effectively prohibiting involuntary or forced labor? 2.13 Does the facility have a program and materials used to train relevant individuals, including all individuals responsible for the hiring process, on the facilitys policies and procedures prohibiting forced or involuntary labor? 2.14 Are all security service agreements free of any language or terminology that may imply the existence of forced, indentured or involuntary labor conditions? 2.15 Do job descriptions or individual contracts for security employees limit their tasks to normal security matters such as protection of facility property or facility personnel? 2.16 Does the facility issue wages/compensation directly to employees, or in an unambiguous system that clearly shows that the employee controls the destination of his/her wages, and access to his/her wages? 2.17 Does the facility hold identification papers, travel documents or passports of their employees? If it does, please provide commentary on whether it is at the request of their employee and with the employee maintaining complete access. 2.18 Is any prison labor used in this facility? If so, please explain & provide information about local & national law, and industry standard(s). 2.19 Are all work contracts signed by both parties (employer and employees)? For countries with at-will employment and/or no formal contracts, include a statement to that effect.
YES
NO
NA
COMMENTARY
All hiring is done directly by the HR department.
Name Mohammed Mostafa Responsible since: November 01, 2011
Training document details training to be carried out for the year 2013 Last training on hiring process and prohibiting forced or involuntary labor was done on March 03, 2013 Security guards job responsibility clearly defines their responsibilities and does not include any language referring to force, indentured or involuntary labor enforcement. The job descriptions for security employees limit their tasks to normal security matters and protection of the companys property.
All wages are paid directly to employees by cash. This was verified during worker interviews and through pay stubs.
As per workers interviews, facility requires copy of documents rather than original documents. Information verified during worker interviews (30) and review of personnel files (30).
Document review, management and employee testimony confirmed that no prison labor is used by the facility.
All work contracts are signed by both employer and employees. Workers receive a copy.
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None
2. FORCED LABOR
Facilities will not use involuntary, forced or trafficked labor.

Nil

Nil
15
PRINCIPLE 3 CHILD LABOR

AUDIT QUESTIONS 3.1 Does the facility obtain proof of age documentation from all potential workers and review the documentation for authenticity prior to hiring? 3.2 How does the facility manage the hiring practice documenting the age of potential employees with official country specific documents (e.g., birth certificates, identification cards, school records and/or immigration papers, medical records)? 3.3Does the facility obtain and retain proof of age for each employee and maintain information in the employee personnel file regarding how long the employee has been working at the facility? 3.4 Does the facility assesses the authenticity of age documentation and makes comparisons with sample documents? Apply extra diligence in territories where child labor is common. 3.5 Does the facility ascertain the employees stated age through the interview process? Verify that the physical appearance of employees selected is consistent with their age and employment history as documented in their personnel file. 3.6 Does facility document the existence of an employment interview (e.g. a checklist indicating that the required questions were asked of the applicant)? 3.7 Does the facility require a completed and signed employment application or contract that includes the date of birth (inclusive of the employee signature, employee identification number and signature date)? 3.8Has the facility formally designated a qualified person with responsibility for communicating, deploying and monitoring child labor practices as they relate to the above requirements? YES NO NA COMMENTARY
Facility requires Government ID card from job applicants and checks the authenticity before hiring.
Age proof documents reviewed: Birth Certificate, School Certificate and Dental Certificate provided by authorised doctor.
30 individual files reviewed which contain Birth Certificate, School Certificate and Dental Certificate as age proof document. Service record in Personnel file. Work contracts contain information reflecting the date of hire.
Authenticity is verified by comparing with similar sample documents and verifiers work experience.
Verification for young looking employees is used during recruitment and compared with age proof documents
Interview checklist and Verification for young looking employees is used during recruitment and compared with age proof documents.
Appointment letter and Service record contains these information including date of birth. 30 contracts reviewed in personnel files contain this information including date of birth.
Name: Farjana Sultana Position : Officer (HR & Compliance) Responsible since: October 01, 2012
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AUDIT QUESTIONS 3.9 Does the facility verify that the responsible person ensures that employees assigned tasks are appropriate for their age, where applicable? 3.10 Review the facilitys communications made to all relevant facility employees regarding child labor policies and procedures. Do the communications address each of the following requirements? 3.10a. Obtain proof of age documentation from all potential workers prior to hiring.
YES
NO
NA
COMMENTARY
No child or young looking employee was found in the factory premises.
HR department informs the requirements when prospective employee contacts facility for employment or when called for interview.
3.10b. Critically examine the authenticity of age documentation.
Comparison of the age proof documents against sample documents. Alternate methods (like Dental check up) to verify age. Interview checklist : Verification for young looking employees is used during recruitment Alternate methods (like Dental check up) to verify age. Interview checklist : Verification for young looking employees is used during recruitment 30 Personnel files contained copy of age proof document. Verification for young looking employees used for young looking workers. Training planner which details training to be carried out for the 2013 includes Child Labour. Last training conducted on: April 02, 2013
3.10c. Question the authenticity of age documentation not conforming to facility practices. 3.10d. Age documentation retained in employee personnel files. 3.10e. Interviews with all prospective employees. 3.11 Do the programs and materials used to train relevant individuals on the child labor practices, including all individuals responsible for the hiring process, cover requirements to obtain age documentation, review age documentation for authenticity, and interview all prospective employees? 3.12 Do all employees in the facility appear to be above the minimum age? If a reasonable suspicion exists that there are age-borderline employees, be extremely cautious and attentive to assessing this compliance. If you suspect the age of any individual(s) you view working in the facility, you MUST seek to include them in the review process for age authentication, including employee interview.
Young looking workers are selected for interview during the walk through the facility. No violations noticed.
17

None
3. CHILD LABOR
Facilities will not hire any employee under the age of 14 or under the minimum age established by law for employment, whichever is greater, or any employee whose employment would interfere with compulsory schooling.

Nil

Nil
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PRINCIPLE 4 HARASSMENT OR ABUSE
AUDIT QUESTIONS 4.1 Has the facility adopted a written policy on the prohibition of harassment, abuse and corporal punishment? 4.2 Are the definition(s) of the non-compliant behavior(s) and management policy (es) towards them consistent with the intent to prohibit all forms of this behaviour? 4.3 Does the policy include reasonable punitive repercussions for non-conformance and repeated non-conformance? Note: The policy must apply to the behaviour of all employees with special emphasis placed upon supervisory personnel. 4.4 Has the facilitys management signed statements affirming their understanding of the facilitys anti-harassment and abuse policies? Note: If the facility has not required signed statements in the past, evidence of statements signed on a prospective basis, i.e., from a certain date forward, is acceptable.
YES
NO
NA
COMMENTARY
Policy No 04 of the Manual It was verified through document review. Policy displayed in production floors and in front of the main entries. The definition of a noncompliant behaviour is available in the company procedure document on standing orders and intents to prohibit all forms of misbehaviour. Policy and procedure addresses this requirement and includes punitive repercussions if not complied with. This document has been signed by all workers, supervisors and managers as a token of understanding of this policy.
Affirmation statement signed by staff, supervisor and managers. Each line supervisor and every employee in managerial level receive a copy of the procedures. Signed statements confirm receipt of the information. The facility has a policy displayed in production floor prohibiting all forms of harassment, abuse and corporal punishment. Training carried out periodically on the subject Last training dated April 18, 2013
4.5 Does the facility effectively prohibit all forms of harassment, abuse and corporal punishment through written policies and procedures? 4.6 Does the facility communicate the policy on the prohibition of harassment and abuse to workers and third party services (e.g., security guards, kitchen services) that will have significant contact with facility employees?
Policy displayed on the production floor and in front of the main entrance. of the facility in English and local language.
4.7 Does the facility encourage employees to report instances of harassment or abuse, without fear of retribution, through effective communication of facility policies and a timely resolution of matters reported?
Suggestion boxes are placed near the rest rooms. The suggestion boxes are opened every week by the Administrative Manager and a representative of the grievance committee. The grievance committee meet once in three months to discuss such issues. Last meeting held on April 18, 2013
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AUDIT QUESTIONS 4.8 Does the facility have an effective and mandatory program to train relevant individuals, including all individuals responsible for the supervision of workers, on the facilitys policies and procedures prohibiting all forms of harassment, abuse and corporal punishment? 4.9 Are all the materials used for this purpose appropriate for this training? 4.10 While inspecting the plant, were any signs noted of physical abuse (including but not limited to shared physical characteristics evident in many workers), such as: a. bruising? b. obvious physical injuries (casts, or other corrective wraps, an exaggerated repetition of the same medical condition)? c. isolated employees? d. overt sights of corporal or psychological punishment?
YES
NO
NA
COMMENTARY
Training planner document details training planned for the year 2013 Date of last training: April 18, 2013
WRAP documentation, displayed copies of standing order.
Walk through did not reveal any such case. Verified injury log and medical records did not reveal such cases. None identified. No signs seen during walkthrough and during interviews

None
4. HARASSMENT OR ABUSE
Facilities will provide a work environment free of supervisory or coworker harassment or abuse, and free of corporal punishment in any form.

Nil

Nil
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PRINCIPLE 5 COMPENSATION AND BENEFITS

YES NO NA COMMENTARY Audit team reviewed payroll records and Electronic time records for last three months, and sampled 30 individual cases for April 2013, March 2013 and February 2013. The facility obtained current issues of Government Laws and Regulations. The local minimum wage standard is BDT 3000/month and is displayed in each workshop. Pay roll record and pay slip verified. All employees are compensated at least the minimum wage as required by local requirement, for this purpose the minimum wage is BDT 3000 per month. Minimum wages as per Government Gazette for garments worker published on October 2010 and effective from November 2010 Audit team verified that the facility utilizes and maintains an organized record-keeping system for recording and computing proper compensation including overtime. Facility uses electronic attendance system to record employees working hours. Audit team verified that facility has a computerized system to produce and retain payroll records.
AUDIT QUESTIONS
5.1 Does the facility have practices to ensure employees are compensated consistent with their terms of employment and in accordance with local laws and regulations?
5.2 Does the lowest record of payment by the facility meet (or exceed) the legal minimum compensation? 5.3 Does the facility post legal minimum wage rates, benefit policies, and additional payment information in the native language(s) of the facility workers?
5.4 Does the facility utilize and maintain an organized system of recordkeeping?
5.5 Does the facility produce and retain payroll records to support compensation, including overtime? 5.5a In case the facility pays its employees through wire transfers, do they produce and retain proof of bank statements showing all the transactions in a verifiable way? Note: The name of the employee, salary amount, and the date of the transaction must appear on the bank slip showing the transaction, as well as the recipients bank name and account.
The salaries to workers are paid in cash at the facility.
5.6 Does the facility provide all employees with a pay record or stub that lists the components of the wages paid?
Pay stubs list employee name, hourly rate wage, regular hours, overtime hours, overtime compensation, holiday compensation, full attendance allowance, gross wage, lawful deductions, net wage and signature. All employees are provided with pay stubs a day prior to the disbursement of wages.
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AUDIT QUESTIONS 5.7 Are all legally mandated withholdings - e.g., taxes, social security, etc. - remitted to the government? 5.8 Are there any piece rate workers in the facility? If so, review a sampling of the documentation for piece rate workers as compared to wage rate workers to ensure compliance with this Principle.
YES
NO
NA
COMMENTARY All employees are covered under Employees Insurance.
No piece rate workers in this factory
5.9 Has the facility formally designated a qualified person with responsibility for communicating, deploying and monitoring the payroll and benefit system and ensuring that the wage rates and compensation calculations are adequately communicated to all workers in the facility? 5.10 Does the facility have a written and coherent policy on piece rate compensation and does the piece rate compensation at least satisfy the minimum compensation prescribed by law? 5.11 Are employees provided with adequate communication of their legally mandated minimum compensation rights? Do they sign off on material counts or random independent recounts for piece rate systems? 5.12Does the policy communication include all of the following: - a detailed description of the employees compensation and benefits at the time of employment? - both a written and verbal explanations of wage calculations provided at the time of employment? - a requirement that changes relating to compensation rates or methods of wage calculations will be communicated timely and effectively?
Name: Mohammed Mostafa Job position : Managing Director Responsible since: November 01, 2011
No piece rate workers in this factory.
Employee hand book provided to all employees. Factorys Act Abstracts are displayed. Worker training includes compensation Last training conducted on February 28, 2013
Employee hand book provided to all employees. Government Abstracts are displayed and training is provided. Last training: February 28, 2013
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Wages analysis:
Sample size Wage periods checked Legal minimum wage for standard time Actual minimum wage paid at this facility Lowest wage paid in sample Highest wage paid in sample What deductions are required by law? Have all of these been made? Have they been forwarded to the appropriate authority? Legal overtime premium for weekdays: Legal overtime premium for rest days Legal overtime premium for holidays 30 April 2013 March 2013 BDT 3000 BDT 3000 BDT 5500 BDT 5500 Unauthorised absent deduction Yes No Yes No 200% of regular working hour 200% of regular working hour 200% of regular working hour February 2013
Social insurance coverage Types of Social Insurances Work-Injury Medical Pension Unemployment Maternity Housing Others (please specify) Coverage (No. of employees & %age of total)
All All None None For whom applicable None None

None
5. COMPENSATION AND BENEFITS
Facilities will pay at least the minimum total compensation required by local law, including all mandated wages, allowances & benefits.

Nil

Nil
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PRINCIPLE 6 HOURS OF WORK

YES NO NA COMMENTARY
AUDIT QUESTIONS 6.1 Has the facility formally designated a qualified person with responsibility for communicating, deploying and monitoring that no employee works more hours per day and per week than the legal limits? 6.2 Does the facility have a program and relevant materials to train all individuals, including all individual responsible for production coordination and scheduling, to ensure that employees work no more than the legal maximum, including overtime ceilings? 6.3 Are all employees are made aware, at the time of hiring, of facility policies and procedures, specifically the legal limitations on the maximum hours of work per day, week and month, both regular and overtime, and the maximum number of consecutive days they can legally be required to work? 6.4 Does the facility retain time records that reflect the day and date employees worked, the number of hours worked each day, and the employees acknowledgements of the same? 6.5 Does the facility have a written, rational and well communicated policy defining "urgent business needs"? Note: The definition of 'urgent business needs cannot be vague or open ended. It must be limited to delays/interruptions in production caused by natural calamities, non-repetitive production deadlines or unforeseen circumstances beyond the employers control. A coherent and consistent rationale must be evident in the definition and infrequent deployment of 'urgent business needs'. 6.6 Are notifications of maximum regular and overtime hour policies visibly posted in the native language(s) of the facility's workers and management personnel?
Name: Md. Azizul Hoq Job position: Safety Officer Responsible since: October 01, 2012
The facility has statutory displays communicating legal requirements on working hours and overtime. The employment document provides information on working hours. Regular working hours are displayed in the facility. This is also part of the training program. Last training conducted on April 03, 2013
Methods of awareness provision: Induction training Employee hand book. Statutory displays.
Facility maintains an electronic time record system for recording all hours worked. Definition of urgent business needs: For delays caused by national calamities such as, cyclone, fire, draught or delays caused by political reasons such as hartal, strikes, etc. and for nonrepetitive production deadlines of unforeseen circumstances beyond our control, the facility may engage workers in overtime work and this overtime work shall be voluntary. This overtime hours shall not exceed legal limits. Number of days urgent business needs occurred during the past year NIL Government Abstracts of legal requirements posted in main entrance of facility in the native language of workers and management personnel
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AUDIT QUESTIONS 6.7 Are all new workers, at the time of hiring, required to be made aware of the facility's policies on required hours of labor?
YES
NO
NA
COMMENTARY Orientation training and employee handbook which includes working and overtime hours policies is given to new workers at the time of hiring.
Hours of Work Analysis

Review Periods # samples reviewed Weekly average hours including overtime for this period (the calculation
should be based on all your samples in each review period)
Weekly max hours for this period

(including OT hours per week)
Frequency of occurrence of max hours (including OT hours per week)
April 2013 March 2013 February 2013
30 30 30
57.6 58.6 58.6
60 60 60
2 3 3
Legal standard work week for this country/industry Contracted standard work-week this facility (hrs) Actual standard work-week averaged over sample (hrs) Actual weekly overtime hours (averaged over entire sample) Range of weekly overtime hours over all workers sampled (quote highest and lowest) Lowest regular weekly hours worked in sample Highest regular weekly hours worked in sample Legally permitted overtime hours Any local waivers for this site?
48 48 48 10.26
Review period1 Review period2 Review period3 H __12__ L ___0_ H __12__ L _0___ H _12___ L __0__
40 60 12 None

None
Hours worked each day, and days worked each week, shall not exceed the limitations of the countrys law. Facilities will provide at least one day off in every seven-day period, except as required to meet urgent business needs Non-compliances raised against this Principle
Nil
6. HOURS OF WORK

Nil
25
PRINCIPLE 7 DISCRIMINATION
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY
7.1 Does the facility have a written policy that explicitly prohibits discrimination? 7.2 Does the facility have procedures and practices to ensure compliance and remediation with the facility policy? 7.3 Does the facility have their written policy visibly posted in the language(s) of the employees and management personnel? 7.4 Has the facility formally designated a qualified person with responsibility for communicating, deploying, and monitoring the non-discrimination policy? 7.5 Does the facility have an effective program and materials used to train relevant individuals, including all individuals responsible for the supervision of workers and for the hiring process, on their discrimination policy and practices? 7.6 Are the facilitys policy, practices and procedures on discriminatory behaviour effectively communicated to all employees? 7.7 Does the facility effectively communicate in writing the requirements of this Principle to third parties (industrial parks, export processing zones, free trade zones, etc.) that may recruit and screen applicants its behalf? 7.8 Has the facility had any discrimination charges filed against it by employees, regulatory agencies or any outside agency during the past two years? If so, please provide details. 7.9 Does the facility explicitly prohibit mandatory pregnancy testing as a condition of employment or continued employment?
Policy No. 07 In the WRAP Manual
Policy displayed in every workshop. Affirmative statements are signed by employees understanding the consequences of violation of this policy. This is also part of the training program. Last training: April 05, 2013 Policy displayed in the shop floor in English and Bengali language.
Name: Mr. Mia Manik Job position: Safety Office Responsible since: October 01, 2012
Training Planner WRAP Awareness Training Last training conducted on April 05, 2013
WRAP Policies displayed in production area and WRAP Awareness Training is conducted. Last training conducted on April 05, 2013
All hiring is done directly through the Human Resources Department. No third party is involved in hiring procedures.
Audit team did not uncover any discriminatory charges against facility by employees, regulatory agencies or any outside agency during the past two years. As per interviews, hiring practices reviews and management interviews, facility explicitly prohibits mandatory pregnancy testing as a condition of employment or continued employment.
26
AUDIT QUESTIONS 7.10 Are workers with the same job and seniority paid the same rate, irrespective of gender, age, or other characteristics? 7.11 Do all employees sign statements (statements may be included in an employment application or contract), written in the native language(s) of the employees, affirming their receipt and understanding of the facilitys antidiscrimination practices?
YES
NO
NA
COMMENTARY Auditor reviewed payroll records and observed that all employees performing the same task and with the same seniority are equally compensated. Workers confirmed the same. Induction training and Employee Hand Book given at the time of appointment Signed Affirmation Statement by staff, supervisors and managers.

None
7. DISCRIMINATION
Facilities will employ, pay, promote, and terminate workers on the basis of their ability to do the job, rather than on the basis of personal characteristics or beliefs.

Nil

Nil
27
PRINCIPLE 8 HEALTH & SAFETY

YES NO NA COMMENTARY Facility holds valid Fire License, Boiler license, boiler operator and electrician certificate. Trade License- 1456 Factory License- 15457/Gazipur Fire license Dhaka/22974/2011, Valid up to June 30, 2013 Boiler License-Ba: B:-3528, valid up to January 01, 2014 IRC- Ba-0223441 ERC-010826 Bonded Warehouse- 1449/2012
AUDIT QUESTIONS
8.1 Are all local and national government health and safety certificates/permits, insurance policies and any relevant correspondence or documents from government officials in order? Please identify and report any irregularities.
8.2 Does the facility comply with all national and local health and safety laws and regulations?
The facility has a written health and safety plan complying with local laws & regulations. Form No 28 Accident and dangerous accident register. Log of injuries and records of employees visits to the doctor were presented for review
8.3 Does the facility properly track health and safety incidents?
8.4 Has the facility formally designated a qualified person with responsibility for communicating, deploying and monitoring all compliant health & safety policies and practices? 8.5 Does the facility have a program and materials to train relevant individuals, including all individuals responsible for the supervision of workers, on all of the relevant occupational safety and health issues? 8.6 Does a physical inspection of the facility verify that the workplace is operated and maintained in a safe and healthy manner? 8.6a (If applicable) Is the facilitys canteen/cafeteria operated and maintained in a safe and healthy manner? 8.6b (If applicable) Is the facilitys creche/childcare area operated and maintained in a safe and healthy manner?
Name : Farzana Sultana (Officer HR & Compliance) Responsible since: October 01, 2012
Training Planner details training planned for the year. Last training carried out on: April 03, 2013
Physical inspection of workplace is conducted by the facility management periodically.
Canteen was located on the top floor of the building with valid fire inspection report.
Child-care area been identified in the facility with safe and healthy manner.
28
AUDIT QUESTIONS 8.7 Are exits unlocked during times when the facility is occupied to allow free, unobstructed exit from the facility? 8.8 (If applicable) Are exits unlocked during times when the dormitories are occupied to allow free, unobstructed exit from the dormitories? 8.9 During the facility visit, were any aisles and/or exits blocked or restricting easy access to emergency exits? 8.10 (If applicable) During the dormitory visit, were any aisles and/or exits blocked or restricting easy access to emergency exits? 8.11 Does the facility have a written safety program, including a fire safety plan? 8.12 (If applicable) Does the dormitory have a written safety program, including a fire safety plan? 8.13 Does the facility maintain first aid supplies as recommended by a local medical provider or required by law? 8.14 Are first aid supplies available and accessible to all areas of the facility? 8.15 Is employee training conducted for first aid and safety? 8.16 Are the first aid responders/emergency safety personnel properly identified and trained? 8.17 Is there clean drinking water that is easily accessible at the facility? 8.18 (If applicable) Is there clean drinking water that is easily accessible in the dormitories? 8.19 Is water provided at no cost to employees? 8.20 Does a visual inspection verify that there is a safe work environment, which includes: proper lighting and ventilation, sanitary toilet areas, structurally sound and clean building facilities?
YES
NO
NA
COMMENTARY
Minimum two exits in all covered areas. Exits are clearly marked and unobstructed.
No dormitories
Aisles unobstructed and provide easy passage to exits.
NA ( No dormitory facility)
Evacuation Plan displayed at prominent locations
NA (No dormitory facility)
First aid kit is provided in every workshop as prescribed by Factory Rules 1979. At least one first aid kit in each workshop. There are 30 first aid kits in the facility. Last training carried out on April 03, 2013 First Aid Responders 12 Fire fighters - 250 There are 12 first aid responders certified by Company doctor. Water test certificate by ICDDRB Dated: May 20, 2012 N/A It was verified through worker interview that water is provided at no cost to employees. Safe work environment Toilets - Male 10 and Female 25
29
AUDIT QUESTIONS 8.21 (If applicable) Does a visual inspection verify that there is a safe dormitory environment, which includes: proper lighting and ventilation, sanitary toilet areas, structurally sound and clean dormitory facilities? 8.22 Does the facility maintain a safety committee comprised of workers and management, which holds regular meetings and keeps minutes of proceedings? 8.23 Are the following safety documents maintained by the facility? a. Health and safety reports b. Heavy machinery inspection (boilers, compressors, etc.)
YES
NO
NA
COMMENTARY
N/A
It was verified that facility maintains a safety committee comprises of 16 workers and 8 management representatives, which holds meetings quarterly and keeps minutes of proceedings.
Form No 28 Accident and dangerous accident register. Boiler License-Ba: B:-3528, valid up to January 01, 2014 Machine maintenance card Generator maintenance card Fire extinguisher maintenance card Boiler maintenance card
c. Maintenance reports
d. Fire extinguisher records, noting date of inspection and expiration
Fire extinguishers are inspected monthly and inspection records are maintained by the facility. It was verified that facility conducts semi-annual emergency evacuation drills for fire emergencies. Last three occurred on May 25, 2013, April 02, 2013, March 10, 2013, Time taken: 3.40 minutes Workforce present: 500 Number of injured workers: 0 Fire alarm rang by: Md. Mia Manik Last person to evacuate: Md. Mia Manik Reason: To observe everyone is evacuated safely. Form 28 Accident and dangerous accident register. The facility has a clinic on site with a qualified doctor. Medical logs with details: name of person, nature of ailment/injury and medicine issued.
e. Emergency drill records, noting date and detailed results
f. Work injury reports g. Clinic logs, noting date and reason for visit 8.24 Have any government agencies inspected the facility for compliance with safety and health regulations during the past two years? If yes, verify that findings are available and reexamine any specific findings issued.
No government agencies inspected the facility during past two years.
30
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY
8.30 Does the facility have a chemical safety program? 8.26 Does the facility properly store hazardous/toxic materials?
The chemical usage is restricted to oils for operating machines and spot cleaning. The facility stores its oils in a separate store with spill containment. Spot cleaning cans are stored adequately. It was verified that employees using glue and diesel oil are trained on chemical safety. Mr. Tariqul Islamstore keeper is authorized to enter the chemical section for providing the chemicals to different departments. Last training was done on February 03, 2013 Material Safety Data Sheets (MSDS) for glue and diesel oil are available in the production workshop. Emergency preparedness plan is established to handle nature disasters such as earthquake and typhoon, fire emergencies, work injury etc.
8.27 Are employees trained on chemical safety, if required?
8.28 Does the facility maintain documentation for chemical labelling, chemical usage warnings, and proper handling instructions? 8.29 Does the facility have written emergency procedures to handle natural disasters, fire emergencies, and industrial accidents? 8.30 (If applicable) Does the facility have written emergency procedures to handle natural disasters, fire emergencies, and industrial accidents for dormitories?
NA
8.31 Have selected employees been trained on the proper use of fire extinguishers?
Fire fighters 250 members (Male: 160; Female: 90) Last training was provided on February 03, 2013 Training conducted by Fire Service and Civil Defence Department. Evacuation plan displayed in prominent locations. In Bengali (language) It was verified that facility conducts semi-annual emergency evacuation drills for fire emergencies. Last one occurred on May 25, 2013. It was verified that there is an adequate number of properly located unimpeded emergency exits (at least 2 per production area). It was verified that there are visible, appropriate, and accessible fire extinguishers. Number of fire extinguishers: 77 Number of fire hydrants: 00 Number of sand buckets: 14
8.32 Does the facility have an emergency evacuation plan in the native language(s) posted in view of the facility's workers? 8.33 Does the facility conduct semi-annual (at least) emergency evacuation drills? 8.34 Does a facility tour verify that there are an adequate number and location of unimpeded emergency exits? 8.30 Does a facility tour verify that fire extinguishers are visible, appropriate in number and easily accessible?
31
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY Number of hose reels: 07 Number of smoke detectors: 87 Number of fire alarm: 8 Number of fire alarm triggers: 16 Overhead sprinklers: 0 It was verified that facility conducts risk assessments of each work process including cutting, sewing, finishing, etc to determine if any protective equipment is required. Worker interview corroborates the availability of PPE at no cost. Occupational health checks were arranged annually for workers exposed to chemicals in printing department.
8.36 Does the facility conduct hazard assessments to determine if any personal protective equipment is required? 8.37 If personal protective equipment is required, is it provided to affected employees at no cost? 8.38 Verify if regular occupational health check is arranged for hazardous job duties. 8.39 What is the overall general appearance of this facility and (if applicable) dormitories: Excellent Good Fair Unacceptable 8.40 Is the overall general appearance of the maintenance shop acceptable and not in a condition that can cause serious injury or harm? 8.41 Is there a policy to maintain safe and orderly work conditions? 8.42 Are the toilets and washrooms in the facility, and (if applicable) the dormitories, in sanitary in serviceable condition? Facility Dorm
Facility was in clean and tidy condition.
Adequate lighting, orderly and tidy.
Related policies were included in the factory rules and posted onsite. Adequate toilets in serviceable condition as per legal requirements 25 Ladies toilets and 10 gents toilet. Waste disposal policy: Policy No. 08 The medical waste is disposed by local Solid Waste Disposal Unit. Domestic garbage is disposed by City Corporation Authority. Biological waste disposal: N/A as they have only cutting, sewing and finishing process. Number of trash cans inside the facility: 00 Number of trash cans outside the facility: 00
8.43 Is trash properly disposed of both inside and outside the facility?
32
AUDIT QUESTIONS 8.44 (If applicable) Is trash properly disposed of both inside and outside the dormitory facilities? 8.45 Does the facility addresses the following occupational safety and health needs in the minimum conditions and regulations of local law, if required, or in healthful operating conditions? heat stress paint spray/spot cleaning booths welding safety respirator safety blood borne pathogen program hearing (noise control program) indoor air quality cotton dust ventilation sanitary waste disposal
YES
NO
NA NA .
COMMENTARY
Adequate ventilation and fans provided Operators provided with gloves, face mask and goggles. No welding done Dust masks provided Work Instructions to first aid responders Ear plugs provided. Well ventilated and exhausted Well ventilated and exhausted Disposal by M/S. Almas Traders

None
8. HEALTH & SAFETY
Facilities will provide a safe and healthy work environment. Where residential housing is provided for workers, facilities will provide safe and healthy housing.
Non-compliances raised against this Principle In accordance with Bangladesh Labour Law 2006, Chapter- 6, Section 62 In every establishment the doors affording exit from any room shall not be locked or fastened so that they can be easily and immediately opened from inside while any person is within the room and all such doors, unless they are of the sliding type, shall be constructed to open outwards or where the door is between two rooms, and all such doors, unless they are of the sliding type, shall be constructed to open outwards or where the door is between two rooms, in the direction of the nearest exit from the building and no such door shall be locked or obstructed while work is being carried on in the room.
33
It was noted during plant tour that in dining area is partially blocked by seating chair in 7th floor. Comments- Above nonconformity is corrected on audit date. Historic Non-compliances raised against this Principle
Nil
34
PRINCIPLE 9 FREEDOM OF ASSOCIATION & COLLECTIVE BARGAINING
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY
9.1 Does the facility have written policies and procedures that recognize and respect the right of employees to exercise their lawful rights of free association? 9.2 Has the facility designated a qualified person with responsibility for communicating, deploying and monitoring the freedom of association practices as prescribed by labour law? 9.3 Does the facility have a union, association or collective representation of employees? Note: The monitor is required to indicate whether there exists or not an informal or formal association of employees. If a lawful association of employees exists, the monitor is required to include a representative of such association in the interview process. 9.4 If a union or collective association which represents the employees exists, does the facility consults with the workers representatives on any issues that are a requirement by law such as factory disclosures, mass lay-offs, restructuring of the business etc.? 9.5 If the workers do have an organized group that addresses workplace issues, does this workers group operates free from coercion or illegal restrictions to its operations? 9.6 If a lawful association of employees exists, is there any bargaining agreement or labormanagement negotiation on workplace issues? 9.7 Is there are formal communication procedures between worker representatives and management? 9.8 Does the facility enter into discussions with the workers representatives in an open manner and within the terms of local law? 9.9 Are the minutes of facility / worker representative meetings documented and available to the workers?
It was verified through review of Policy No. 09
Name: Parvin Akter Job position: Vice President -WA Responsible since: May 02, 2013
The facility is not unionized. The facility has a Workers Committee which comprises of 14 workers. The members are fairly elected each year. Parvin Akter is heading the committee. Meetings are conducted monthly and recorded. Last meeting conducted on January 05, 2013
Facility would consult Parvin Akter who is the representative of workers committee, if needed.
Workers committee address work place issues. Free of coercion or restrictions. Worker interview did not reveal any non compliance.
No legal union and no CBA
Regular meeting would be arranged for communication between both. Facility management would participate in the meeting and follow up the issues raised by workers. Meeting minutes can be provided for review.
35
AUDIT QUESTIONS 9.10 Are workers representatives elected on a free and confidential basis by the workers? If not, what is the election process? 9.11 Does the facility discriminate against employees who form or participate in lawful associations?
YES
NO
NA
COMMENTARY
Worker representatives were elected on a voluntary and free basis. No adverse comments during worker interview Interviews by audit team did not reveal any information that would indicate actions by facility to discriminate against employees who are union members. Workers free to join any association worker interviews. Interviews by audit team did not reveal any information that would indicate actions by facility to discriminate against employees who choose not to join any association.
9.12 Does the facility discriminate against those who choose not to join any association?
9.13 Does the facility communicate its policies and practices pertaining to this Principle to all facility employees and third parties (e.g., free zone office services, employment agencies) that may perform recruitment or screening of applicants? Facility Employees Third Parties
The facility recruits directly through HR department.

None
9. FREEDOM OF ASSOCIATION & COLLECTIVE BARGAINING
Facilities will recognize and respect the right of employees to exercise their lawful rights of free association and collective bargaining.

Nil

Nil
36
PRINCIPLE 10 ENVIRONMENT
AUDIT QUESTIONS 10.1 Does the facility have an environmental management system relevant to its industry? 10.2 Has the facility formally designated a qualified person with responsibility for communicating, deploying, and monitoring the environment practices elaborated upon in the environmental management system? 10.3 Does the facility have a program and materials to train relevant individuals on each practice of the environmental management system? 10.4 Does the facility assess its ability to prevent and control harmful releases of industrial waste into the environment as a part of the environmental management system? 10.5 Does the facility maintain a detailed plan for handling accidental release or discharge of environmentally dangerous materials?
YES
NO
NA
COMMENTARY
The facility has an Environment Policy No. 10
Name Mr. Mia Manik Job position: Safety Officer Responsible since: October 01, 2012
Training Planner Last training on April 03, 2013 Facility test air and noise from Adroit Environment Consultants Ltd. Air test date: June 07, 2012 Noise test date: June 07, 2012 Hazardous material used is restricted to oils (diesel oil, lubricant oil) and spot lifting. Spot cleaning can and oils are stored separately with proper spill containment and Waste disposal policy. Facility maintains forms to record emission events (no cases occurred as of the date of the audit) Waste disposal policy: Policy No. 10 The medical waste is disposed by local Solid Waste Disposal Unit. Domestic garbage is disposed by City Corporation Authority
10.6 Does the facility maintain records of emission events?
10.7 Does the facility environmental management system address where and how solid, chemical, sanitary and wastewater substances are disposed of? 10.8 Does a review of all local government environmental inspection reports, certificates/permits, notices of deficiencies, and corrective action notices or plans held by the facility, as well as any correspondence from government officials, reveal any irregularities? If so, please comment on how the facility has addressed them. 10.9 Does the facility adequately communicate to all facility employees the relevant local and
No irregularities recorded.
Through training conducted monthly Last training on April 05, 2013
37
AUDIT QUESTIONS national laws and regulations as well as pertinent facility procedures concerning the environment Principle?
YES
NO
NA
COMMENTARY

None
Facilities will comply with environmental rules, regulations and standards applicable to their operations, and will observe environmentally conscious practices in all locations where they operate. Non-compliances raised against this Principle
10. ENVIRONMENT
Nil

Nil
38
PRINCIPLE 11 CUSTOMS COMPLIANCE
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY Export Policy The Customs Act of 1969
11.1 Does the facility keep copies of all applicable customs laws and regulations?
Mr. Zakir Hossain, Commercial Manager, is designated to update and keep copies of all applicable customs laws and regulations. Responsible since: October 01, 2012
11.2 Do the facilitys policies and procedures on customs compliance cover the following requirements? 11.2a Facility complies with all applicable customs laws and maintains practices to comply with customs laws regarding illegal transshipment of products (in the event possible illegal transshipment activity, appropriate host government agency will be notified).
Customs Policy SC/ 11
11.2bMonitors its productions on a per style basis.
Facility maintains an organized system of production documentation by separating each purchase order and monitors its productions on a per style basis. Documents reviewed: Purchase Order, Contract sheet, Planning sheet, Packing Instruction and Production Records. It was verified by audit team through randomly selected sets of records for 03 different products. Following documents were reviewed: Bill of Lading/Airway Bill Certificate of Origin GSP Form A - Europe Single Country /multiple country Declaration US Packing List Inspection reports in process and final 10+2 Importer Security Filing Worksheet US Inspection reports- in process, final inspection and inward inspection for subcontracted processes. The facility machine inventory is kept and update annually by Mr. Zakir Hossain-Commercial Manager. Last update was conducted in February 03, 2013.
11.2cTraces country of origin using records such as production, shipping, verification reports, quality control reports, and individual piecework sheets, for all inputs.
11.2dVerifies production on an on-going basis on-site and at sub-contracting facilities.
11.2e Maintains a facility machine inventory and updates it annually.
39
AUDIT QUESTIONS 11.2fEnsures that the proper category designation is determined for all goods destined for the US market. 11.2gIf the goods are subject to US quotas ensures that the country of origin for quota purposes is correct through methods such as seeking guidance from importer of record, submitting category and/or country of origin ruling requests to the US Customs service, having a trained category and country of origin specialist on staff.
YES
NO
NA
COMMENTARY
Category and HS code are mentioned on the invoices. The HS Code is 61.05.100000
Not subject to US Quotas
11.3 Does the facility maintain an organized system of production documentation? Are the following records maintained? 11.3aRecords of the country of origin for all goods produced in the facility.
Facility maintains an organized system of production documentation, by separating each purchase order with its proper packing list, bill of lading, shipping, importing records, style number, etc. Following documents were reviewed: Certificate of origin Single Country /multiple country Declaration US GSP Form A
11.3bA production profile of any subcontracting facility (the facility requests documents from the subcontractors when questions regarding goods produced at those facilities arise). 11.3cProduction/purchase orders (with information such as conditions of production, payment, and finished product specifications). 11.3dRaw material invoices (indicating country/origin/manufacturing facility). 11.3eShipping/receiving documents (outgoing and incoming records of components/ inputs sent to or received from another facility). 11.3fEmployee work records accurate records of employee work hours that can be linked to the production of specific products. 11.3gQuality control records (which may include facility name and address, purchase order number, style number, date of the quality check, buyer, name, stamp or signature of inspector, comments on production).
No subcontracting process.
Purchase orders contain the details as required.
Incoming material receipts contain the detail of the facility from where the material is being purchased. All incoming/outgoing materials are accompanied by a delivery notes which contains details of the materials and is recorded in inward / outward register maintained at the security office Production records and time card can be linked.
Final Inspection report available for every shipment and contains all the details.
40
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY Following documents were reviewed: Invoice Packing List Certificate of Origin GSP Form A - Europe Single Country /multiple country Declaration - US Bill Of Lading/Airway Bill Inspection Report 10+2 Importer Security Filing Worksheet effect
11.3hExport documents (including, where applicable, copies of the quota and visa, if the facility is the quota provider, packing list, manifest, bill of lading/airway bill from truck, ship, plane or train indicating the export date, exporting entity, destination, shipping lines, importing entity, and any charges incurred).
11.3i Outward processing production (if applicable, copies of the outward processing program designated by the domestic government, copies of compliance review reports, documentation demonstrating the flow of goods from one facility to another). 11.3jNumber of Units produced marked with a traceable mark. 11.3kMachine inventory records, updated at least once a year. 11.3l Documented US quota requirements for the host country. 11.3m Documented confirmation of the correct category and country of origin for goods through verification of correct country of origin such as binding rulings from the US Customs Service, confirmation with purchasing company, knowledgeable/trained staff, etc. 11.3n Documentation on how the qualified person with responsibility for this Principle communicates deploys and monitors the facilitys customs compliance policies. 11.4 Do the facilitys production records include verification of sub-contractor performance? If applicable, what records are used? Date and location of the verification Product(s) verified Purchasing company Style number
The outgoing and incoming materials are accompanied by Delivery Challan as per the requirements of the local law.
15,000 Machine inventory records were kept and updated at least once a year. Not subject to US Quotas
Category and HS code are mentioned on the invoices. The HS Code is 61.05.100000
Custom Compliance Policy No. 11 in the Manual
No subcontracted operators within the facility
41
AUDIT QUESTIONS Phase of production Reference indicator for employee(s) performing operation Name/stamp or signature of verifying official
YES
NO
NA
COMMENTARY
11.5 Does the facility have a designated person responsible for this Principle? 11.6 Does the responsible person ensure that origin determining documents are maintained for at least the period of record retention required by law? 11.7 Does the responsible person ensure that all subcontracting facilities complete a production profile, and keeps such profiles on file? 11.8 Does the facility verify production at subcontracting facilities when necessary through the review of requested documentation or personal visits (recording such instances of production verification and keeping on file)? 11.9 Does the responsible person stay current with possible illegal transshipment activity in the host country through communication with appropriate bodies such as the host government, quota council or issuing agency, trade association, contact with U.S. Customs, corporate importing office etc., and be responsible for maintaining files on any known trans shippers or transshipment activities determined to be in the host country or with a country from which facility sources?
Name Mr.Zakir Hossain Job position: Commercial Manager Responsible since: October 01, 2012
Control of records 03 years retention period
No subcontracting process in the facility.
Supplier Evaluation Incoming inspection reports.
10+2 Importer Security Filing Worksheet effect for US & Canada.
42

None
Facilities will comply with applicable customs laws, and in particular, will establish and maintain programs to comply with customs laws regarding illegal transshipment of finished products. Non-compliances raised against this Principle
11. CUSTOMS COMPLIANCE
Nil

Nil
43
PRINCIPLE 12 SECURITY
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY Facility maintains two levels of security. One at the warehouse department, inspecting all goods shipped out and assuring the area is secure from non essential personnel and the other at the main entrance gate, where other team of security guards screens the cargo documentation and permit to depart the facility. Security Policy No. 12 and Security Instructions Name: Mr. Anamul Haque Position: Security In Charge Responsible since: November 01, 2012
12.1 Does the facility have practices to guard against the introduction of contraband (e.g. drugs, explosives, biohazards, and/or other contraband)? Any non-manifested cargo will be referred to as contraband
12.2 Does the facility have a responsible person in charge of security?
Container Inspection
12.3 Does the facility have documented procedures in place to verify the physical integrity of the container structure prior to loading? 12.3.1 Does the procedure include the reliability of the locking mechanisms of the doors? 12.3.2 Does the facility conduct a seven-point inspection process for all containers and keep records of all inspections: If the answer to any of these points is no, please state the alternative method used. Front wall Left side Right side Floor Ceiling/Roof Inside/outside doors Outside/Undercarriage 7 point inspection carried out by the security before loading and after loading. Physical integrity procedure of container structure: No.12 Exit doors and windows are properly locked during non working hours.
Trailer Inspection
44
AUDIT QUESTIONS 12.4 Does the facility have procedures in place to verify the physical integrity of the trailer structure prior to loading, including the reliability of the locking mechanisms of the doors? 12.4.1 Is the facility following five-point inspection process is recommended for all trailers? Fifth wheel area - check natural compartment/skid plate Exterior - front/sides Rear - bumper/doors Front wall Left side
YES
NO
NA
COMMENTARY
Physical integrity procedure of trailer structure: No.12
5 point inspection carried out by the security for all trailers
Container and Trailer Seals 12.5 Does the factory affix a high security seal to all loaded trailers and containers bound for the U.S.? Seals that meets PAS ISO 17712 were been used. The consignment is loaded on the vehicle in the presence of the security and packing in charge. The vehicle is locked and is sealed. The consignment is sent to the container terminal and handed over to the freight forwarders. The stuffing of the container is carried out by the customs officials. Seals are kept by security department, specified persons are assigned for affixing, replacing, recording, tracking and verifying seals on containers.
12.5.1 Do the seals meet or exceed the current PAS ISO 17712 standards for high security seals?
12.5.2Does the facility have documented procedures stipulating how seals are to be controlled and affixed to loaded containers and trailers? 12.5.3 Does the facility have documented procedures for recognizing and reporting compromised seals and/or containers/trailers to US Customs and Border Protection or the appropriate local authority? 12.5.4 Does the facility have designated employees for the distribution of seals for integrity purposes?
Any abnormal case will be reported to US Customs and Border Protection in time.
A designated person from warehouse department Name: Mr. Tariqul Islam (Warehouse In-charge)
45
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY
Container and Trailer Storage The facility has a procedure for preventing unauthorised access to empty and/or full containers. Only the employees with work permit can enter these areas and warning signs of No Entry were posted
12.6 Is the security of containers and trailers located within the facility maintained? Are they in a secure area to prevent unauthorized access and/or manipulation?
12.6.1 Does the facility have documented procedures in place for reporting and neutralizing unauthorized entry into containers/trailers or container/trailer storage areas?
Reporting procedure has been stated clearly in the documented polices.
Physical Access Controls 12.7 Does the facility have a physical access control procedure? Employees 12.7.1Does the facilities have an employee identification system in place for positive identification and access control purposes? 12.7.2 Does the facility ensure that employees are only given access to those areas needed for the performance of their duties? 12.7.3 Does the facility control the issuance and removal of employee, visitor and vendor identification badges? Does the facility have documented procedures for the issuance, removal and changing of access devices (e.g. keys, key cards, etc.)? Visitors 12.7.4 Do visitors present photo identification for documentation purposes upon arrival? All visitors should be escorted and should visibly display temporary identification. Every employee has a unique ID card for entering the facility. Packing area was only allowed for packing workers. A record of issuing and receiving ID badges for employee, visitor and vendor were kept by security guard at factory gate. Keys, key cards and codes were kept by related departments supervisor only. Important exits were controlled by security guards patrolling.
Normally visitors identification card would be required for review before entering the facility.
Deliveries (including mail) 12.7.5 Is vendor ID and/or photo identification required to be presented for documentation purposes upon arrival by all vendors? Arriving packages and mail should be periodically screened before being disseminated.
Normally vendors identification card would be required for review before entering the facility.
46
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY
Challenging and Removing Unauthorized Persons 12.7.6 Does the facility have documented procedures in place to identify, challenge and address unauthorized/unidentified persons? Personnel Security 12.8 Does the facility have documented procedures in place to screen prospective employees and to periodically check current employees? Security Policy No. 12
Security Policy No. 12
Pre-Employment Verification 12.8.1 Does the facility verify application information, such as employment history and references, prior to employment? Reference check would be conducted for each employee before employment.
Background Checks / Investigations
It was verified that facility performs background

12.8.2 Does the facility conduct background checks and investigations for prospective employees? 12.8.3 Once employed, are periodic checks and reinvestigations performed based on cause, and/or the sensitivity of the employees position? checks on security dock personnel before employment is permanent. Police verification carried out by local Police station demonstrates that no criminal records for all related employees. Annually basis
Personnel Termination Procedures 12.8.4 Does the facility have procedures in place to remove identification, facility, and system access for terminated employees? All mentioned items would be terminated at once when worker left.
Documentation Processing 12.9 Are documented procedures in place to ensure that all information used in the clearing of merchandise/cargo, is legible, complete, accurate, and protected against the exchange, loss or introduction of erroneous information? Documentation control must include safeguarding computer access and information.
Security procedure No.12
Manifesting Procedures 12.9.1Are documented procedures in place to help ensure the integrity of cargo and that information received from business partners is reported accurately and in a timely manner?
Security procedure No. 12
47
AUDIT QUESTIONS
YES
NO
NA
COMMENTARY
Shipping and Receiving Facility maintains two levels of security. One at the warehouse department, inspecting all goods shipped out and assuring the area is secure from non essential personnel and the other at the main entrance gate, where other team of security guards screens the cargo documentation and permit to depart the facility. Security Policy No. 12 and Security Instructions All cargos would be carefully checked and verified. Warehouse staff responsible for shipment and security guard both would check the departing cargo. Drivers would receive all information that would be used for checking the cargo before cargo received or released. Security Procedure No. 12 Cargo Discrepancies 12.9.7 Are all shortages, overages, and other significant discrepancies or anomalies resolved and/or investigated appropriately? 12.9.8 Are customs and/or other appropriate law enforcement agencies notified if anomalies, illegal or suspicious activities are detected, as appropriate? Fencing 12.10.1 Is there perimeter fencing enclosing the areas around cargo handling and storage facilities? 12.10.2 Is interior fencing within a cargo handling area used to segregate domestic, international, high value, and hazardous cargo? Perimeters fencing higher than 2m were installed. Controlled before dispatch and buyer kept informed.
12.9.2 Is cargo that is being shipped reconciled against information on the cargo manifest?
12.9.3 Is all cargo accurately described, and the weights, labels, marks and piece count indicated and verified? 12.9.4 Does the facility verify departing cargo against purchase or delivery orders? 12.9.5 Are drivers delivering or receiving cargo positively identified before cargo is received or released? 12.9.6 Are documented procedures in place to track the timely movement of incoming and outgoing goods?
Customs would be informed at once when any illegal or suspicious activities been detected.
No domestic cargo
Gates and Gate Houses
12.10.3 Are gates through which vehicles and/or personnel enter or exit manned and/or monitored?
All gates were equipped with security guard.
48
AUDIT QUESTIONS
YES
NO Parking
NA
COMMENTARY
12.10.4 Are private passenger vehicles prohibited from parking in or adjacent to cargo handling and storage areas? Building Structure 12.10.5 Are buildings constructed of materials that resist unlawful entry? 12.10.6 Is the integrity of structures maintained by periodic inspection and repair?
Private passenger vehicles were not allowed to entering facility.
The facility building is constructed of brick wall and the main gate is manned 24x7. Daily basis
Locking Devices and Key Controls 12.10.7 Are all external and internal windows, gates and fences secured with locking devices? Management or security personnel must control the issuance of all locks and keys. Lighting 12.10.8 Is there adequate lighting provided inside and outside the facility including the following areas: entrances and exits, cargo handling and storage areas, fence lines and parking areas? The facility has installed halogen lights over the main gate and in the parking area. The perimeter wall is equipped with fog lights. All the exits are equipped with individual battery operated emergency lights.
Exit doors and windows are properly locked during non working hours.
Alarms Systems and Video Surveillance Cameras 12.10.9 Are alarm systems and video surveillance cameras utilized to monitor premises and prevent unauthorized access to cargo handling and storage areas? All high risk areas like cargo handling, gates, storage area were equipped with Security guard.
Password Protection 12.11Does the facility has automated systems for individually assigned accounts that require a periodic change of passwords? 12.11.1Does the facility have documented IT security policies and procedures and standards in place and provide them to employees in the form of training? Accountability 12.11.2 Does the facility have a system in place to identify the abuse of IT including improper All computers were monitored by central controller; any abnormal would be reported to management at once. Individuals computer passwords would be changed on monthly basis.
IT security procedure No. 12
49
AUDIT QUESTIONS access, tampering or altering of business data?
YES
NO
NA
COMMENTARY
Security Training and Threat Awareness 12.12 Does the facility have a threat awareness program in place and established and maintained by security personnel to recognize and foster awareness of the threat posed by terrorists and contraband smugglers at each point in the supply chain? 12.12.1 Does the facility makes employees aware of the procedures the company has in place to address a security situation and how to report it? 12.12.2 Does the facility give additional training to employees in the shipping and receiving areas, as well as those receiving and opening mail? 12.12.3 Does the facility undertake additionally, specific training to assist employees in maintaining cargo integrity, recognizing internal conspiracies, and protecting access controls? 12.12.4 Do these programs offer incentives for active employee participation?
Threat awareness training would be provided to all employees twice per year.
Related procedure would be emphasized at each awareness training and also posted onsite.
Last training carried out on April 03, 2013
Such training would be delivered by department supervisor once needed. Incentive policy was included in the security procedure, anyone who reported the suspicious activities would have a special incentive.

None
12. SECURITY
Facilities will maintain facility security procedures to guard against the introduction of non-manifested cargo into outbound shipments (i.e. drugs, explosives biohazards and /or other contraband).

Nil

Nil
50
This report provides a summary of the findings and other applicable information found/gathered during the audit conducted on the dates mentioned only. The audit process requires that information be gathered and considered from records review, worker interviews, management interviews and visual observation. More information is gathered during the audit process than is provided here. The audit process is a sampling exercise only and does not guarantee that the audited facility prior, during or post-audit is in full compliance with WRAP Principles. WRAP Principles should not be used to prevent companies from exceeding these requirements. Companies applying WRAP Principles are expected to comply with national and other applicable law, and where the provisions of law and WRAP Principles address the same subject, to apply that provision which affords the greater protection. The ownership of this report remains with the party who has paid for the audit, unless the report is generated as part of an unannounced audit visit. Release permission must be provided by the owner prior to release to any third parties.
WRAP Audit Report ALGI version April 2013

Ratool Apparels Ltd. Bangladesh WRAP FCR AR 13638

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Ratool Apparels Ltd. Bangladesh WRAP FCR AR 13638

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WRAP CERTIFICATION PROGRAM

Facility Certification Recommendation

_____________________________________ Authorized Signature for Independent Monitoring Firm

Angelo Valdevitt Name of Authorizing Official

PHOTOS General Information

WRAP Audit Report ALGI version April 2013

Fire Fighting Equipments

First Aid Box

Finished Goods Store

Fire Hose Rill

Child Care Room

WRAP COC Posted

Fire Alarm Bell

Facility Audit Report

Sec-14, Uttara, Dhaka-1230

Policy and Procedures Table

Policy and procedures

Historic Non-Compliance Table

Worker interviews conducted

WRAP Policy & Procedure Manual No-01 Issue No-01 Rev 00

COMMENTARY Issue No-01 Rev 00

N/A (no non compliance levied during past two years.)

WRAP Policy & Procedure Manual No. 01 Issue No-01 Rev 00

The facility did not have any subcontracting process.

The facility did not have any subcontracting process.

Best practices observed:

1. COMPLIANCE WITH LAWS AND WORKPLACE REGULATIONS

Non-compliances raised against this Principle

Historic Non-compliances raised against this Principle

PRINCIPLE 2 FORCED LABOR

No immigration workers found in this facility.

All hiring is done directly by the HR department.

Name Mohammed Mostafa Responsible since: November 01, 2011

Best practices observed:

Facilities will not use involuntary, forced or trafficked labor.

Non-compliances raised against this Principle

Historic Non-compliances raised against this Principle

PRINCIPLE 3 CHILD LABOR

No child or young looking employee was found in the factory premises.

3.10b. Critically examine the authenticity of age documentation.

Best practices observed:

Non-compliances raised against this Principle

Historic Non-compliances raised against this Principle

PRINCIPLE 4 HARASSMENT OR ABUSE

WRAP documentation, displayed copies of standing order.

Best practices observed:

Non-compliances raised against this Principle

Historic Non-compliances raised against this Principle

PRINCIPLE 5 COMPENSATION AND BENEFITS

The salaries to workers are paid in cash at the facility.

COMMENTARY All employees are covered under Employees Insurance.

No piece rate workers in this factory

No piece rate workers in this factory.

Best practices observed:

5. COMPENSATION AND BENEFITS

Non-compliances raised against this Principle

Historic Non-compliances raised against this Principle

PRINCIPLE 6 HOURS OF WORK

Hours of Work Analysis

Weekly max hours for this period

Frequency of occurrence of max hours (including OT hours per week)

April 2013 March 2013 February 2013