ScreenCraft International

Brouchers

Certificate.

Code of Conduct

Version 6.1 Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 2 Audit Details Sedex Company Reference: (only available on Sedex System) ZC131586493 Sedex Site Reference: (only available on Sedex System) ZS408250492 Business name (Company name): Screen Craft international Site name: SCREEN CRAFT INTERNATIONAL Site address: 6.5 KM ,Raiwind Road,Adjacent to Pak Turk,School Lahore 54000 PK Country: PK Site contact and job title: Iftikhar UL Hassan / Admin Compliance Officer SMETA Audit Pillars: Labour Standards Health and Safety (plus Environment 2-Pillar) Environment 4-pillar Business Ethics Date of Audit: 2023-01-08 Audit Company Name: Eurofins South Asia Audit Conducted By Affiliate Audit Company Purchaser Retailer Brand owner NGO Trade Union Multi-stakeholder Combined Audit (select all that apply) SedexAuditReference: SMETACorrectiveAction Plan Report (CAPR) Version6.1 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. Audit company: Report reference: Date: 3 Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 3 SMETA Declaration I declare that the audit underpinning the following report was conducted in accordance with SMETA Best Practice Guidance and SMETA Measurement Criteria. 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. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 4 (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: Ali Nizami APSCA Number: 21701647 Additional Auditors: Date of declaration: 2023-01-23 Site Representation Full Name: Iftikhar UL Hassan Title: Admin Compliance Officer Date of declaration: 2023-01-23 Comments: Summary of Findings Local Law Issues Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 5 Issue (please click on the issue title to go direct to the appropriate audit results by clause) Area of Non–Conformity Number of issues Findings ETI Local Law NC Obs GE 0A - Universal rights covering UNGP 0 0 0 0B - Management systems and code implementation 0 1 0 Obs - ZAF600016800 1 - Freely chosen employment 0 0 0 2 - Freedom of association and right to collective bargaining are respected 0 0 0 3 - Working conditions are safe and hygienic 3.1 3.1 3.1 3.1 3.1 3.1 §1 §2 §3 6 0 0 NC - ZAF600016801 NC - ZAF600016802 NC - ZAF600016803 NC - ZAF600016804 NC - ZAF600016805 NC - ZAF600016806 4 - Child labour shall not be used 0 0 0 5 - Living wages are paid 0 0 0 6 - Working hours are not excessive 0 0 0 7 - No discrimination is practiced 0 0 0 8 - Regular employment is provided 0 0 0 8A - Subcontracting and homeworking 0 0 0 9 - No harsh or inhumane treatment is allowed 0 0 0 10A - Entitlement to work and immigration 0 0 0 10B2 - Environment 2–pillar 0 0 0 10B4 - Environment 4–pillar 0 0 0 10C - Business ethics 4-pillar 0 0 0 Issue Description §1 Factory act 1934 Section 26 fencing of machinery Sub section 1 §2 Punjab Factory Rules 1978 Appendix II §3 PUNJAB HAZARDOUS SUBSTANCES RULES, 2018 c) General Safety Precautions: (1) A licensee shall ensure that the following safety precautions are conveyed to persons who deal with generation, collection, consignment, transportation, treatment, disposal, storage and handling of Hazardous Substances Site Details Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 6 Site Details Company Name Screen Craft international Site Name SCREEN CRAFT INTERNATIONAL GPS location (if available) GPS Address: 6.5 Km, Raiwind Road, Near Pak Turk School Lahore Coordinates: 25.0072982,67.0954149 Applicable business and other legally required licence numbers and documents, for example, business license number, liability insurance, any other required government inspections Labor Certificate : DLW/LHR/W/22219 Products/Activities at site, for example, garment manufacture, electricals, toys, grower, cutting, sewing, packing etc Product: Knitted garments. Activities: Cutting, sewing, checking, finishing & Packing Site description: (Include size, location, and age of site. Also, include structure and number of buildings) Screen Craft is located at 6.5 Km, Raiwind Road, Near Pak Turk School Lahore. Factory land area is 1 acres where built area is 96000 square feet. Facotry has Ground plus 1 floor. Age of the building is 18 years. Factory construction take place in 2007. Structure and number of buildings Building Name: Production and office building Floor Description Remark Ground floor Security, time office, embiodery , fabric store, cutting, sewing, checking, packing. None First floor Cutting, sewing, finishing, packing None Visible structural integrity issues (large cracks) observed? Yes No Please give details: No cracks observed during the site tour. Does the site have a structural engineer evaluation? Yes No Please give details: Stability certificate is issued by structure engineer. Site function Agent Factory Processing/Manufacturer Finished Product Supplier Grower Homeworker Labour Provider Pack house Primary Producer Service Provider Sub-contractor Months of peak season Select a month to Select a month Process overview Cutting, sewing, checking, finishing and packing (Printing and embroidery on customer demand). 4 production lines in the facility. Main equipment used for production is: sewing machine, cutting machines, embroidery machines and packing machines. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 7 What form of worker representation is there on site? Union Worker Commitee Other None Please give details: Worker council committee is available in the factory in order to solve day to day worker issues. Is there any night production work at the site? Yes No Are there any on site provided worker accommodation buildings Yes No Please give details: Are there any off site provided worker accommodation buildings Yes No Please give details: Were all site provided accommodation buildings included in this audit Yes No Please give details: No accommodation provided by the facility. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 8 Audit Parameters Time in and time out Day 1 In 10:00 Out 18:57 Audit type: Full initial Was the audit announced? SEMI_ANNOUNCED Was the Sedex SAQ available for review? No Any conflicting information SAQ/Pre-Audit Info to Audit findings? Yes SAQ is not provided prior to the audit. Who signed and agreed CAPR Iftikhar UL Hassan / Admin Compliance Officer Is further information available No Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 9 Audit attendance Management Worker Representatives Senior management Worker Committee representatives Union representatives A: Present at the opening meeting? Yes Yes No B: Present at the audit? Yes Yes No C: Present at the closing meeting? Yes Yes No Reason for absence at the opening meeting No union is foamed by workers in the facility. However workers are not restricted to form workers union. Reason for absence during the audit No union is foamed by workers in the facility. However workers are not restricted to form workers union. Reason for absence at the closing meeting No union is formed by workers in the facility. However workers are not restricted to form workers union. Worker Analysis The term "migrant worker" refers to a person who is engaged or has been engaged in a remunerated activity in a country of which they are not a national or permanent resident or has purposely migrated on a temporary basis to another in-country region to seek and engage in a remunerated activity. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 10 Worker Analysis Local Permanent Temporary Agency Migrant* Permanent Temporary Agency Home workers Total Worker numbers – male 80 0 0 0 0 0 0 80 Worker numbers – female 0 0 0 0 0 0 0 0 Total 80 0 0 0 0 0 0 80 Number of Workers interviewed – male 10 0 0 0 0 0 0 10 Number of Workers interviewed – female 0 0 0 0 0 0 0 0 Total – interviewed sample size 10 0 0 0 0 0 0 10 Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 11 Nationalities Structure Nationality of Management Pakistani Please list the nationalities of all workers, with the three most common nationalities listed first. Nationaility 1: Pakistani approx %: 100% Was this list completed during peak season? Yes No Please give details: No peak season working in the factory. Worker remuneration Workers on piece rate: 0% Paid hourly: 0% Salaried: 100% Payment cycle Paid daily: 0% Paid weekly: 0% Paid monthly: 100% Other: 0% Details for other: None Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 12 Worker Interview Summary Were workers aware of the audit? Yes No Were workers aware of the code? Yes No Number of group interviews: 1 group of 4 workers Number of individual interviews: Male: 6 Female: 0 All groups of workers are included in the scope of this audit such as; Direct employees, Casual and agency workers, Workers employed by service providers such as security and catering staff as well as workers supplied by other contractors. Yes No Please give details: Interviews were done in private and the confidentiality of the interview process was communicated to the workers? Yes No In general, what was the attitude of the workers towards their workplace? Favorable Non-favourable Indifferent What was the most common worker complaint? No major complain raised by workers. What did the workers like the most about working at this site? On time salary Any additional comment(s) regarding interviews: None Attitude of workers to hours worked: Positive Is there any worker survey information available? Yes No Please give details: Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 13 Attitude of workers: Overall the attitude of the employees, the management of the company were very positive and during interviews the workers confirmed that the management had a very positive behaviour towards them, and they could access the management whenever required with their concerns whether work related or personal. During Interviews the workers also confirmed that the attitude of the supervisors was also very positive and they were treated positively by their supervisors. Workers have been selected by the auditors at random from different work process covering different age groups. The interview was conducted in a private place without the presence of any representative from the management. No negative comments as such were received from the workers regarding the management and overall the workers were found very satisfied with the management of the company. Attitude of worker’s committee/union reps: The Joint Work Committee exist in the company. Workers know their representatives. No negative comments were received from JWC. They knows their responsibilities. Overall the interview was conduct in relax manner and workers representative found satisfied with management behaviour Attitude of managers: The management was supportive to the audit process. Access to workplace, documents and people was fully provided. Interviews were conducted in a private space provided. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 14 0A - Universal Rights covering UNGP [Summary of Findings] 0A: Compliance Requirements 0.A.1 Businesses should have a policy, endorsed at the highest level, covering human rights impacts and issues, and ensure it is communicated to all appropriate parties, including its own suppliers. 0.A.2 Businesses should have a designated person responsible for implementing standards concerning Human rights 0.A.3 Businesses shall identify their stakeholders and salient issues. 0.A.4 Businesses shall measure their direct, indirect, and potential impacts on stakeholders (rights holders) human rights. 0.A.5 Where businesses have an adverse impact on human rights within any of their stakeholders, they shall address these issues and enable effective remediation. 0.A.6 Businesses shall have a transparent system in place for confidentially reporting, and dealing with human rights impacts without fear of reprisals towards the reporter. Note for auditors and readers. This is not a full Human Rights Assessment, but instead a check on the business’s implementation of processes to meet their Universal rights covering UNGP responsibilities. Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems. Current Systems: Organization established Human Rights Policy in Business Ethics Policy which is in compliant to: The universal Declaration of Human Rights (1947) The international Covenant on Civil and Political Rights (1966) The International Convention on Economic, Social and Cultural Rights (1966) The International Labour Organization Declaration on Fundamental Rights at work (1998) Mr. Ali Hassan (Manager Compliance & HR) was responsible to implement Human Rights Policy Policy is communicated to all appropriate parties, including its own suppliers. Site has identified stakeholders and salient issues in the SMETA Manual and has established a monitoring mechanism to measure direct, indirect, and potential impacts on stakeholders’ human rights. No issue related to any adverse impact on human rights within stakeholders of Hameed Packages has been reported so far. Site has a transparent system in place for confidentially reporting and dealing with human rights impacts without fear of reprisal towards the reporter. Toll free ethics hotline available and communicated effectively. Evidence examined: Human rights policy “Human Rights”. Official notification of Director for implementing standards concerning Human rights. SMETA Manual, Training and communication records (employees, vendors, suppliers). Any other comments: Nil Policy statement that expresses commitment to respect human rights? Yes No Please give details: Human Rights” endorsed by CEO provides commitment to respect human rights Are the policies included in workers’ manuals? Yes No Please give details: All these policies include in workers handbook. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 15 Does the business have a designated person responsible for implementing standards concerning Human Rights? Yes No Please give details: Mr. Ali Hassan (Manager Compliance & HR) Does the business have a transparent system in place for confidentially reporting, and dealing with human rights impacts without fear of reprisals towards the reporter? Yes No Please give details: Transparent system exists for confidentially reporting. Complain & Drop Box is available and communicated effectively. Does the grievance mechanism meet UNGP expectations? (Legitimate, Accessible, Predictable, Equitable, Transparent, Rights-compatible, a source of continuous learning and based on stakeholder engagement) Yes No Does the business demonstrate effective data privacy procedures for workers’ information, which is implemented? Yes No Please give details: Data privacy mechanism is established in code of business ethics and conduct and implemented Measuring Workplace Impact Annual worker turnover(Number of workers leaving in last 12 months as a % of average total number of workers on site over the year (annual worker turnover)) Last year 0% This year 0% Current % quarterly (90 days) turnover(Number of workers leaving from the first of the 90 day period through to the last day of the 90 day period / [(number of employees on the 1st day of 90 day period + number of employees on the last day of the 90 day period) / 2]) 0% Annual % absenteeism(Number of days lost through job absence in the year / [(number of employees on 1st day of the year + number employees on the last day of the year) / 2] * number available workdays in the year) Last year 2% This year 3% Quarterly (90 days) % absenteeism(Number of days lost through job absence in the period / [(Number of employees on 1st of the period + Number of employees on the last day of the period / 2] * Number of available workdays in the month) 2% Are accidents recorded? Yes No Please give details: Accidental / Injury Register. However, no accidents happened in the latest 12 months. Annual Number of work related accidents and injuries per 100 workers((Number of work related accidents and injuries * 100) / Number of total workers) Last year 0% This year 0% Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 16 Quarterly (90 days) number of work related accidents and injuries per 100 workers((Number of work related accidents and injuries * 100) / Number of total workers) 0% Lost day work cases per 100 workers([(Number of lost days due to work accidents and work related injuries * 100) / Number of total workers) Last year 0% This year 0% % of workers that work on average more than 48 standard hours / week in the last 6 / 12 months 6 month 0% 12 month 0% % of workers that work on average more than 60 total hours / week in the last 6 / 12 months 6 month 0% 12 month 0% Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 17 0B - Management Systems and code Implementation [Summary of Findings] 0B: Compliance Requirements 0.B.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code. 0.B.2 Suppliers shall appoint a senior member of management who shall be responsible for compliance with the Code. 0.B.3 Suppliers are expected to communicate this Code to all employees. 0.B.4 Suppliers are expected to be operating legally in premises with the correct business licenses and permissions and to have systems to ensure that all relevant land rights have been complied with. 0.B.5 Suppliers should communicate this code to their own suppliers and, where reasonably practicable, extend the principles of this Ethical Code through their supply chain. Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems. Current Systems: The company is found committed towards implementation of this code. They have given the full access to conduct the audit and provided all documents as requested. The company has appointed Mr. Muhammad Faisal Rasheed (Deputy Manager Compliance & HR) who is responsible to develop and implement the code requirements. ETI code is communicated to workers through induction trainings. Risk assessment was found done for procedures. Evidence examined: Company has established policy and signed by CEO. Business Ethics Training record dated on 16th March 2022, total employees attend the training. Property ownership records Any other comments: Nil Management Systems In the last 12 months, has the site been subject to any fines/prosecutions for non–compliance to any regulations? Yes No Please give details: No evidence of any fines observed for non–compliance to any regulations. Do policies and/or procedures exist that reduce the risk of forced labour, child labour, discrimination, harassment & abuse? Yes No Please give details: During the audit, it is observed that policies are made on child labour, discrimination, forced labour harassment & abuse. If Yes, is there evidence (an indication) of effective implementation? Please give details. It is verified that these policies and code are communicated to through displayed Policies. Training was conducted on 29th March 2022. Have managers and workers received training in the standards for forced labour, child labour, discrimination, harassment & abuse? Yes No Please give details: Company has conducted training about ETI code dated on 2nd March 2022 to all workers. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 18 If Yes, is there evidence (an indication) that training has been effective e.g. training records etc.? Please give details Yes No Please give details: Training effectiveness found available for each training Does the site have any internationally recognised system certifications e.g. ISO 9000, 14000, OHSAS 18000, SA8000 (or other social audits)? Yes No Please give details: No certification has been obtained so far. Is there a Human Resources manager/department? Yes No Mr. Jamal Ud din (HR & Manager compliance) Is there a senior person /manager responsible for implementation of the code? Yes No Please give details: Mr. Muhammad Faisal Rasheed (Deputy Compliance manager) Is there a policy to ensure all worker information is confidential? Yes No Please give details: Confidentiality Policy is available. Is there an effective procedure to ensure confidential information is kept confidential? Yes No Please give details: Factory does have a procedure for confidentiallty of data in the facility. Procedure no SC/SCM/SOP/DC/01 Are risk assessments conducted to evaluate policy and procedure effectiveness? Yes No Please give details: Risk assessment of policy & procedure has done conducted. Does the facility have a process to address issues found when conducting risk assessments, including implementation of controls to reduce identified risks? Yes No Please give details: Risk assessment is available for policy and procedures. Does the facility have a policy/code which require labour standards of its own suppliers? Yes No Please give details: Company does not sheared its code of conduct to its suppliers. Land Rights Does the site have all required land rights licenses and permissions (see SMETA Measurement Criteria)? Yes No Please give details: Factory provided business license to prove the land using is legal, and no relevant negative information based on interview and wed search. Does the site have systems in place to conduct legal due diligence to recognize and apply national laws and practices relating to land title? Yes No Please give details: Company has legal advisor who ensures legal due diligence to recognize and apply national laws and practices relating to land title. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 19 Does the site have a written policy and procedures specific to land rights? Yes No Please give details: Legal Advisor is completed all documents regarding land rights. Is there evidence that facility/site compensated the owner/lessor for the land prior to the facility being built or expanded? Yes No Please give details: No such evidence observed. Does the facility demonstrate that alternatives to a specific land acquisition were considered to avoid or minimize adverse impacts? Yes No Please give details: Land use reforms mechanism established in code of ethics of company and in land acquisitions requirements are met in accordance with local legal requirements. Is there any evidence of illegal appropriation of land for facility building or expansion of footprint? Yes No Please give details: No such deviation observed. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 20 Observation Evidence [Back to findings summary] Observation Reference ZAF600016800 Clause 0B - Management Systems and code Implementation Issue Title 37 - The ethical Code (i.e. ETI Base Code for SMETA audits) is not communicated to the site's own suppliers Subcategory Site's Systems to Manage Supplier Compliance New or carried over? New Carried Over Root cause Training System Costs Lack of workers Other Root cause - Other Explanation to the observation It was noted during management interview, that management has not sheared ETI Code of conduct with his own suppliers in order to maintain ethical supply chain. Actions It is recommended to the factory that, Management should have to shear ETI Code of conduct with his own suppliers in order to maintain ethical supply chain. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 21 1 - Freely chosen Employment [Summary of Findings] 1: Compliance Requirements 1.1 There is no forced, bonded or involuntary prison labour. 1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice. Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems. Current Systems: Policy is established in manual (SEDEX-01 Issue dated: 10.10.2015). This local law applicable to this requirement is Bonded Labour System (Abolition) Act 1992, Act III of 1992 [Gazette of Pakistan, Extraordinary, Part I, 17th March, 1992], Clause (2) of Article 11 which states “No person shall make any advance under, or in pursuance of, the bonded Labour system or compel any person to render any bonded Labour or the form of forced labour. During the interviews of management and workers and through records verifications it was noted that during the past years no complaints and or violations were reported by any employee / worker against this requirement. From employee interviews it was also evident that they were working voluntarily and freely. During the facility tour, it was noted that workers were working under no pressure and they were very relaxed. The workers were also found allowed to go out of the working areas and even outside the company premises during working hours, if necessary. They do not ask to deposit any original documents or security only photocopies are maintained, During management and employee interview, it was noted that the company does not require any worker to deposit any original identification papers. HR Policy Manual covers Organizational Structure, Recruitment & selection, compensation & benefits, Leave & work schedule, Performance management, employee affairs, & grievance & redressed system. Employee separation. Evidence examined: Personal file and worker interview Procedure for Employment Any other comments: Nil Is there any evidence of retention of original documents, e.g. passports/ID’ (If yes, please give details and category of workers affected) Yes No Please give details: Is there any evidence of a loan scheme in operation (If yes, please give details and category of workers affected) Yes No Please give details: Is there any evidence of retention of wages / deposits (If yes, please give details and category of workers affected) Yes No Please give details: Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 22 Are there any restrictions on workers’ freedom to terminate employment? Yes No Please give details: Workers are free to terminate their employment at any time. If any part of the business is UK based or registered there & has a turnover over £36m, is there a published a ‘modern day slavery statement? Yes No Not Applicable Please give details: No part of the business is done in UK. Is there evidence of any restrictions on workers’ freedoms to leave the site at the end of the work day? Yes No Please give details: No such restrictions observed. Does the site understand the risks of forced / trafficked / bonded labour in its supply chain Yes No Not Applicable Please give details: Site understands the risk of forced labour and bonded labour. Further company has also established policies on it. Is the site taking any steps taking to reduce the risk of forced / trafficked labour? Yes No Please give details: Facility has policy not to employ forced / trafficked labor. There is no forced or trafficked labour in the facility. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 23 2 - Freedom of Association and Right to Collective Bargaining are Respected [Summary of Findings] 2: Compliance Requirements 2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. 2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities. 2.3 Workers’ representatives are not discriminated against and have access to carry out their representative functions in the workplace. 2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates, and does not hinder, the development of parallel means for independent and free association and bargaining. Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems. Current Systems: They have policy on Freedom of Association and right to collective bargaining in manual. The organization has worker council. Workers can complaint or suggest through complaint and suggestion box also. Total 10 members found in the worker welfare council in which all are male. Evidence examined: Review of records and worker’s interviews. Policy on Freedom of Association and right to collective bargaining. Elections Records dated: January 27th 2022 Biannually Minutes of Meetings Records: Dated: 16th -September-2022 Any other comments: Nil What form of worker representation/union is there on site? (Please add the name of the union or committee in the textbox) Union Worker Commitee Other None Other details: Work Council committee Is it a legal requirement to have a union? Yes No Is it a legal requirement to have a worker’s committee? Yes No Is there any other form of effective worker/management communication channel? (Other than union/worker committee e.g. H&S, sexual harassment) Yes No Please give details: Company has open door policy and workers can approach to management directly. In addition, complains are communicated through complain box. Is there evidence of free elections? Yes No Does the supplier provide adequate facilities to allow the Union or committee to conduct related business? Yes No Please give details: Meeting room is available in order to council union members meetings. Name of union and union representative, if applicable: No union in the facility. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 24 Is there evidence of free elections? Yes No Not Applicable If there is no union, is there a parallel means of consultation with workers e.g. worker committees? Yes, Facility having workers committee. Is there evidence of free elections? Yes No Not Applicable Are all workers aware of who their representatives are? Yes No Please give details: yes, workers are well aware of that. Were worker representatives freely elected? Yes No Date of last election: 2022-01-27 Do workers know what topics can be raised with their representatives? Yes No Were worker representatives/union representatives interviewed? Yes No If Yes, please state how many: 2.0 Please describe any evidence that union/worker’s committee is effective? Specify date of last meeting; topics covered; how minutes were communicated etc. Meeting minutes were found available. Agenda and minutes distribution record available. Last meeting date was 16-Dec-2022 Following points are covered in meeting: Legal minimum wage increase; Worker health & safety condition etc. Are any workers covered by Collective Bargaining Agreement (CBA)? Yes No Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 25 3 - Working Conditions are Safe and Hygienic [Summary of Findings] 3: Compliance Requirements 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. 3.2 Workers shall receive regular and recorded Health & Safety training, and such training shall be repeated for new or reassigned workers. 3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. 3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers. 3.5 The company observing the code shall assign responsibility for Health & Safety to a senior management representative. Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems. Current Systems: HSSE Policy Covering Health & Safety. Security & Environment (GTM/SCM/01) is established. Management procedure for Emergency Preparedness & Response is documented and established and approved by Director HSSE dated: 17.01.2018 Mr. Jamal Ud din (HR & Manager compliance) has been assigned for implementation of HSE. Last evacuation drill was conducted by 9th September 2022 Evacuation time was found 1.25 minutes. They have documented HSE policy and communicated on employees. PPE training was conducted on 9th September 2022 to all employees. Emergency evacuation map was found available/displayed in whole premises. Evidence examined: HSSE Policy Covering Health & Safety. Security & Safe Environment is established. Management procedure for Emergency Preparedness & Response is documented and established and approved by owner of the company. Any other comments: Nil Does the facility have general and occupational Health & Safety policies and procedures that are fit for purpose and are these communicated to workers? Yes No Please give details: Company has health & Safety policy and is communicated to workers, verified in worker interviews Are the policies included in workers’ manuals? Yes No Please give details: policies and procedure are included in workers’ manual Are there any structural additions without required permits/inspections (e.g. floors added)? Yes No Please give details: No any structural additions without required permits. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 26 Are visitors to the site informed on H&S and provided with personal protective equipment? Yes No Please give details: Safety briefing given to visitors and provided PPEs. Is a medical room or medical facility provided for workers?(This section is to list evidence to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate)) Yes No Please give details: No medical room in the factory and no legal requirement for it. However, sufficient first aid kits were found available in each section. Is there a doctor or nurse on site or there is easy access to first aider/ trained medical aid? Yes No Please give details: Sufficient first aiders are available in each section. Where the facility provides worker transport – is it fit for purpose, safe, maintained and operated by competent persons e.g. buses and other vehicles? Yes No Please give details: No transport was provided for workers by the facility. Is secure personal storage space provided for workers in their living space and is fit for purpose? Yes No Please give details: Accommodation was not provided to workers. Are H&S Risk assessments are conducted (including evaluating the arrangements for workers doing overtime e.g. driving after a long shift) and are there controls to reduce identified risk? Yes No Please give details: risk of overtime also calculated in risk assessment. Is the site meeting its legal obligations on environmental requirements including required permits for use and disposal of natural resources? Yes No Please give details: Facility is meeting its legal obligations on environmental requirements no natural resource being used for production purpose. Is the site meeting its customer requirements on environmental standards, including the use of banned chemicals? Yes No Please give details: Requirements found compliant. Further no such chemical found on site which is banned. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 27 Non-Compliance Evidence [Back to findings summary] Non-Compliance Reference ZAF600016801 Clause 3 - Working Conditions are Safe and Hygienic Issue Title 224 - Isolated occurrence of incorrect / damaged insulation in electricals including burnt / damaged wiring and plugs Subcategory Electrical risk New or carried over? New Carried Over Root cause Training System Costs Lack of workers Other Root cause - Other 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 the non compliance It was noted during factory visit that one lose wire is found with lose connection in production hall. Follow up method Follow up audit Desktop audit Timescale Immediate 30 days 60 days 90 days 120 days 180 days 365 days Other Actions It is recommended that facility shall install proper plug or secure the lose wire in production hall. lose and unsecure wire connection.jpg Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 28 Non-Compliance Evidence [Back to findings summary] Non-Compliance Reference ZAF600016802 Clause 3 - Working Conditions are Safe and Hygienic Issue Title 264 - Machines lack appropriate safety guards (e.g. eye or needle guards on sewing machines, belt / hand guards on other machines) Subcategory Machinery New or carried over? New Carried Over Root cause Training System Costs Lack of workers Other Root cause - Other Local law issue Factory act 1934 Section 26 fencing of machinery Sub section 1 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 the non compliance It was noted during factory visit that 8 out of 26 sewing machines were found without pulley covers. Follow up method Follow up audit Desktop audit Timescale Immediate 30 days 60 days 90 days 120 days 180 days 365 days Other Actions It is recommended that facility shall install pulley covers on all sewing machines. Pulley covers.jpg Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 29 Non-Compliance Evidence [Back to findings summary] Non-Compliance Reference ZAF600016803 Clause 3 - Working Conditions are Safe and Hygienic Issue Title 289 - First aid box available but contents are missing / contents out of date or otherwise inadequate Subcategory First Aid / Accidents New or carried over? New Carried Over Root cause Training System Costs Lack of workers Other Root cause - Other Local law issue Punjab Factory Rules 1978 Appendix II 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 the non compliance It was noted during factory walk through that 2 first aid boxes were found with insufient supplies. Follow up method Follow up audit Desktop audit Timescale Immediate 30 days 60 days 90 days 120 days 180 days 365 days Other Actions It is recommended that facility shall make sure to maintain complete first aid supplies in frist aid boxes according to legal requirement. First aid kit in complete.jpg Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 30 Non-Compliance Evidence [Back to findings summary] Non-Compliance Reference ZAF600016804 Clause 3 - Working Conditions are Safe and Hygienic Issue Title 188 - Fire extinguishers incorrectly installed, e.g. placed at an inappropriate height / on floor Subcategory Fire Safety - Fire Fighting Equipment New or carried over? New Carried Over Root cause Training System Costs Lack of workers Other Root cause - Other 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 the non compliance It was noted during factory visit that one fire cylinder is not properly installed / mounted on wall in near main gate. Follow up method Follow up audit Desktop audit Timescale Immediate 30 days 60 days 90 days 120 days 180 days 365 days Other Actions It is recommended that facility shall mount all fire extinguishers on wall on appropriate height near main gate. Fire extinguisher not mounted.jpg Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 31 Non-Compliance Evidence [Back to findings summary] Non-Compliance Reference ZAF600016805 Clause 3 - Working Conditions are Safe and Hygienic Issue Title 240 - No / inadequate safety measures / anti-explosion measures for chemicals (e.g. no anti-leaking system / secondary container / unbunded) Subcategory Chemicals New or carried over? New Carried Over Root cause Training System Costs Lack of workers Other Root cause - Other Local law issue PUNJAB HAZARDOUS SUBSTANCES RULES, 2018 c) General Safety Precautions: (1) A licensee shall ensure that the following safety precautions are conveyed to persons who deal with generation, collection, consignment, transportation, treatment, disposal, storage and handling of Hazardous Substances 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 the non compliance It was noted during factory visit that paint drums on floor without secondary containment to avoid spillage in printing section. Follow up method Follow up audit Desktop audit Timescale Immediate 30 days 60 days 90 days 120 days 180 days 365 days Other Actions It is recommended that facility shall store paint drums under secondary containment in printing section Paint bucket - Drums not stored under secondary containment..jpg Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 32 Non-Compliance Evidence [Back to findings summary] Non-Compliance Reference ZAF600016806 Clause 3 - Working Conditions are Safe and Hygienic Issue Title 207 - Isolated occurrence of blocked fire exits Subcategory Fire Safety - Fire exits New or carried over? New Carried Over Root cause Training System Costs Lack of workers Other Root cause - Other 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 the non compliance It was noted during factory visit that pathway in cutting section was found blocked by cut fabric / waste fabric bags on ground floor. Follow up method Follow up audit Desktop audit Timescale Immediate 30 days 60 days 90 days 120 days 180 days 365 days Other Actions It is recommended that factory management shall ensure that all the pathways shall be clear from obstractles all the time. Pathway blocked in cutting section.jpg Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 33 4 - Child Labour Shall Not Be Used [Summary of Findings] 4: Compliance Requirements 4.1 There shall be no new recruitment of child labour. 4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child. 4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions. 4.4 These policies and procedures shall conform to the provisions of the relevant ILO Standards. Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems. Current Systems: They have companywide policy for different matters including child labour that they will not hire any child labour. ID card are must to get employment in the organization Personal files found maintained with respect of age proof evidence like national identity card, appointment letter, etc. During the course of audit, no child found and the company has set the 18 years old. In this regard, the personal files found completed with respect of identity card. Evidence examined: Child Labour Policy, Interviews, personal files Any other comments: Nil Legal age of employment: 18 Age of youngest worker found: 20 Are there children present on the work floor but not working at the time of audit? Yes No Percentage of under 18’s at this site (of total workers) 0% Are workers under 18 subject to hazardous work assignments? Yes No Please give details: No worker found under 18 year. Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 34 5 - Living Wages are Paid [Summary of Findings] 5: Compliance Requirements 5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income. 5.2 All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid. 5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded. Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems. Current Systems: It was noted from review of wage records and interaction with employees and management that: 1. All eligible employees are covered gratuity. 2. No fines / illegal deductions are made from the wages of the employees as disciplinary measures. 3. All employees are paid on or before 7th of every month. 4. Employees are provided with pay slip. 5. As per available records, all employees are paid above and equal the legal minimum wages. As per law, the minimum wages are for unskilled employee is 25000 PKR per month and workers are compensated according to worker skill and job nature which is higher than minimum wage. 6. Facility maintains Leave records which is required by applicable law. 7. It was noted during review of that remuneration is paid to workers in accordance with law. 8. Employees are paid with annual bonus at with complete current salary (the 13rd months’ salary). Evidence examined: •10 employees were interviewed and the same numbers of records were reviewed for the month January 2022, May 2022 and December 2022 •Latest legal minimum wages notification issued by state government •List of National and Festival Holidays. •Interaction with management and Employees. •Social benefit receipt record (EOBI, Group life insurance & Social Security). Any other comments: Nil Summary Information Criteria Local Law Actual at the Site Is this part of a Collective Bargaining Agreement? Standard/Contracted work hours: (Maximum legal and actual required working hours excluding overtime, please state if possible per day, week, and month) Legal Maximum Per Day: 8.0 Per Week: 48.0 Per Month: 208.0 Actual Per Day: 8.0 Per Week: 48.0 Per Month: 208.0 NO Overtime hours: (Maximum legal and actual overtime hours, please state if possible per day, week, and month) Legal Maximum Per Day: 2.0 Per Week: 12.0 Per Month: 48.0 Actual Per Day: 0.0 Per Week: 0.0 Per Month: 0.0 NO Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 35 Wage for standard/contracted hours: (Minimum legal and actual minimum wage at site, please state if possible per hr, day, week, and month) Legal Maximum Per Day: 961.0 Per Week: null Per Month: 25000.0 Actual Per Day: 961.0 Per Week: null Per Month: 25000.0 NO Overtime wage: (Minimum legal and actual minimum overtime wage at site, please state if possible per hr, day, week, and month) Legal Maximum Per Day: 480.0 Per Week: null Per Month: null Actual Per Day: 480.0 Per Week: null Per Month: null NO Wages Analysis: Were accurate records shown at the first request? Yes No Sample Size Checked (State number of worker records checked and from which weeks/months – should be current, peak, and random/low. Please see SMETA Best Practice Guidance and Measurement Criteria) 10 samples from December 2022 (latest paid month) 10 samples from May 2022 (random month) 10 samples from January 2022 (random month) Are there different legal minimum wage grades? If Yes, please specify all. Yes No All workers are compensated according to goverement approved grades. If there are different legal minimum grades, are all workers graded and paid correctly? Yes No Not Applicable Please give details: For the lowest paid production workers, are wages paid for standard/contracted hours (excluding overtime) below or above the legal minimum? Below legal min Meet Above Lowest actual wages found: Note: full time employees and please state hour / week / month etc. full time employees and please state hour / week / month etc. Minimum in the province is 25000 PKR per month. However company is paying minimum salary to their employee / worker is 26500/- (office boys & peon). Please indicate the breakdown of workforce per earnings 0% of workforce earning under minimum wage 0% of workforce earning minimum wage 100% of workforce earning above minimum wage Bonus Scheme found: Please specify details: Bonus Scheme found:Bonus Scheme found:Bonus Scheme found: Company provides bonus higher than legal requirement to their employees (more than 1 legal required bonus). Which is based on company’s financial performance. Note: type of employee (e.g. full time, temp, etc.) and please state which units e.g. /hour /week /month etc. Note: type of employee (e.g. full time, temp, etc.) and please state which units e.g. /hour /week /month etc. What deductions are required by law e.g. social insurance? Please state all types: EOBI (Employee part) and provident fund. Have these deductions been made? Yes No Please list all deductions that have been made. EOBI (Employee part) and provident fund. Please list all deductions that have not been made. Approved Leaves Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 36 Were appropriate records available to verify hours of work and wages? Yes No Were any inconsistencies found? (if yes describe nature) Yes No Do records reflect all time worked? (For instance, are workers asked to attend meetings before or after work but not paid for their time) Yes No Please give details: All the records are found consistent with each other during review. Is there a defined living wage: This is not normally minimum legal wage. If answered yes, please state amount and source of info: Please see SMETA Best Practice Guidance and Measurement Criteria. Yes No Please give details: If yes, what was the calculation method used. ISEAL/Anker Benchmarks Asia Floor Wage Figures provided by Unions Living Wage Foundation UK Fair Wear Wage Ladder Fairtrade Foundation Other – please give details: Are there periodic reviews of wages? If Yes give details (include whether there is consideration to basic needs of workers plus discretionary income). Yes No Please give details: Annual review on wages. Are workers paid in a timely manner in line with local law? Yes No Is there evidence that equal rates are being paid for equal work: Yes No Please give details: All workers are compensated according to their job How are workers paid: Cash Cheque Bank Transfer Other Audit company: Report reference: Date: Eurofins South Asia ZAA600001780 2023-01-08 Sedex Audit Reference: Sedex Members Ethical Trade Audit Report ZAA600001780 Version 6.1 37 6 - Working Hours are not Excessive [Summary of Findings] 6: Compliance Requirements 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. 6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week. 6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay. 6.4 The total hours worked in any 7-day period shall not exceed 60 hours, except where covered by clause 6.5 below. 6.5 Working hours may exceed 60 hours in any 7-day period only in exceptional circumstances where all of the following are met: 6.6 Workers shall be provided with at least one day off in every 7-day period or, where allowed by national law, 2 days off in every 14-day period. Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems. Current Systems: Based from the in/out time records, interaction with the employees and management, 1. There is no compulsion on overtime work. It is purely voluntary. 2. The employees work for 6 days a week in General Shift. The normal working hours are as follows: General Shift: 9:00 am to 6:00pm. Lunch/Dinner Break: 60 minutes staggered Weekly off: Sunday 3. Employees’ wages are calculated on monthly basis and paid on or before 07th of each month through Cash & bank transfers. 4. Facility has maintained electronic time records for all employees since the beginning of the employment. Evidence examined: •Review of In/out time records from December 2022(latest paid month), May 2022(random month) and January 2022 (random month) •Working Hours policy Any other comments: Nil Working hours' analysis Systems & Processes What timekeeping systems are used? Face id scanning system is installed. Is sample size same as in wages section? Yes No Please give details: Are standard/contracted working hours defined in all contracts/employment agreements? (If no, please give details including % and which type of workers do NOT have standard hours defined in contracts/employment agreements.) Yes No Audit company: Report refere

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