WRAP Monitor's Handbook 2016

WRAP Monitor’s Handbook ? 2016 WRAP (Worldwide Responsible Accredited Production) All Rights Reserved.

TABLE OF CONTENTS

1. INTRODUCTION4 1.1WRAP CERTIFICATION PROGRAM 4 1.2WRAP’S 12PRINCIPLES 5 1.3CERTIFICATION PROCESS 9 1.4ACCREDITATION OF MONITORING PARTNERS12

2. AUDIT DOCUMENTS 13

2.1FACILITY SELF-ASSESSMENT QUESTIONNAIRE 13 2.2MAN-DAY,INTERVIEW,AND RECORD REVIEW REQUIREMENTS 14 2.3WRAP PRINCIPLES 14 2.4OPENING AND CLOSING MEETING CHECKLISTS14 2.5DOCUMENTATION CHECKLIST14 2.6INDIVIDUAL EMPLOYEE INTERVIEW GUIDE15 2.7GROUP INTERVIEW GUIDE 15 2.8CLOSING MEETING SUMMARY 15 2.9CORRECTIVE ACTION PLAN 15 2.10DETAILED AUDIT REPORT16

2.11FACILITY CERTIFICATE RECOMMENDATION 16

3. AUDIT PLANNING 17

3.1REVIEW OF FACILITY SELF-ASSESSMENT QUESTIONNAIRE17 3.2TYPES OF AUDITS 17 3.3SEQUENCE OF AUDITS 19

3.4SCHEDULING OF AN AUDIT 19

4. AUDIT EXECUTION 21

4.1OPENING MEETING 21 4.2FACILITY TOUR&INITIAL OBSERVATIONS 22 4.3INTERVIEWS 23 4.4DETAILED TESTING&RECORD REVIEWS 25 4.5PRE-CLOSING MEETING 26 4.6CLOSING MEETING 27 4.7REPORTING OF SERIOUS VIOLATIONS&ZERO TOLERANCE ISSUES 29

5. AUDIT REPORTING 30

5.1COMPLETION OF DETAILED AUDIT REPORT&PHOTO TEMPLATE 30

5.2GENERAL INFORMATION 33

5.3POST REPORT SUBMISSION 34

5.4DOCUMENT CONTROL&AUDIT FILES 34

6. AUDIT FOLLOW – UP PROCEDURE 36

6.1ON-SITE FOLLOW UP AUDIT 36

6.2DESKTOP REVIEW PROTOCOL 38

6.3FOLLOW-UP AUDIT REPORTING(ON-SITE&DESKTOP) 39

6.4POST CERTIFICATION AUDITS(PCA S) 43

7. GENERAL INFORMATION 47

7.1CONFLICT OF INTEREST 47

7.2COUNTRY SPECIFIC ISSUES47

7.3FACILITY RELOCATION OR NAME CHANGE48

7.4DENIAL OF ACCESS 48

7.5SUBCONTRACTING 48

7.6USE OF WRAP LOGO 49

GLOSSARY 50 APPENDICES

I.WRAP POLICIES FOR RECOGNITION OF MONITORING PARTNERS

II.WRAP MAN-DAY,INTERVIEW,AND RECORD REVIEW REQUIREMENTS

III.OPENING MEETING CHECKLIST

IV.INDIVIDUAL INTERVIEW QUESTIONNAIRE

V.GROUP INTERVIEW QUESTIONNAIRE

VI.CLOSING MEETING CHECKLIST

VII.AUDIT FILE REQUIREMENT CHART

https://www.360docs.net/doc/9316495592.html,/LOCATION CHANGE FORM

IX.WRAP ZERO TOLERANCE POLICY

X.WORKING HOURS ACTION PLAN TEMPLATE

1. INTRODUCTION

1.1 WRAP Certification Program

Headquartered in Arlington, Virginia, USA (and with branch offices in Hong Kong and Bangladesh, along with representatives in India, Vietnam, and Thailand), Worldwide Responsible Accredited Production (WRAP) is an independent, objective, non-profit team of global social compliance experts dedicated to promoting safe, lawful, humane and ethical manufacturing around the world through certification and education.

WRAP’s certification program seeks to independently monitor and certify compliance with the 12 WRAP Principles. These Principles are based on the rule of law within each country and include the spirit or language of relevant International Labor Organization (ILO) conventions. Factories that demonstrate proper adoption, deployment, and monitoring of all 12 Principles receive certification ranging from six months to two years. If there is no law available in the country, then local practice or relevant ILO conventions, whichever provides greater protection for the worker, become the standard to which the facility is held.

WRAP maintains a management systems approach toward compliance that requires top management adopt the WRAP Principles in writing, and assign the necessary staff to ensure the required practices are implemented throughout the facility, and that internal audit and risk assessment systems are in place to ensure continuous compliance. Facilities shall undergo a rigorous self-assessment and then

be audited by an independent third-party monitoring company.

Becoming a WRAP certified facility involves much more than simply passing an audit. We take a collaborative approach to social compliance certification where we work with facilities to ensure that they remain in compliance with WRAP’s 12 Principles. This does require, however, that all of our facilities actively engage in the process themselves and see to it that effective management systems are maintained to ensure compliance requirements are met.

This Handbook provides WRAP accredited independent auditors with the information and monitoring tools needed to conduct on-site compliance evaluation visits of facilities participating in the Worldwide Responsible Accredited Production (WRAP) certification program.

It is important to note that all information in this Handbook is subject to change at WRAP’s discretion. Any updates to this Handbook will be sent out to all responsible personnel at all accredited monitoring firms with the expectation of it being disseminated to all WRAP auditors in a timely manner. If you have any questions about our guidelines, please contact us prior to conducting an audit.

1.2 WRAP’s 12 Principles

The WRAP Principles are based on generally accepted international workplace standards, local laws and workplace regulations, and include the spirit or language of relevant conventions of the International Labor Organization (ILO). The Principles encompass human resources management, health and safety, environmental practices, and legal compliance including import/export and customs compliance and security standards.

The WRAP Certification Program’s objective is to independently monitor and certify compliance with these standards, to ensure that sewn products are being produced under lawful, humane and ethical conditions. Participating facilities voluntarily commit to ensuring that their manufacturing practices will meet these standards, and further commit to passing along, on their part, the expectation that their contractors and suppliers likewise comply with these standards.

1. Compliance with Laws and Workplace Regulations

Facilities will comply with laws and regulations in all locations where they conduct business.

All facilities will comply with the legal requirements and standards of their industry under the local and national laws of the jurisdictions in which the facilities are doing business, along with any applicable international laws. This will cover all labor and employment laws of those jurisdictions, as well as laws governing the conduct of business in general, including rules and standards of ethics dealing with corruption and transparency, and any relevant environmental laws.

2. Prohibition of Forced Labor

Facilities will not use involuntary, forced or trafficked labor.

Facilities will maintain employment strictly on a voluntary basis. Facilities will not use any forced, prison, indentured, bonded or trafficked labor. This will include ensuring that any workers they hire will be under labor contracts that fully comply with all relevant legal requirements and do not impose any form of coercion (including imposing substantial fines or loss of residency papers by workers leaving employment or restricting a worker’s ability to voluntarily end his/her employment). In addition, when hiring workers through an employment broker or agency, facilities will ensure that the workers’ passports are not withheld, all written contracts are in the native language of the workers, and recruitment fees are not borne by the workers themselves.

3. Prohibition of 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.

Facilities will ensure they do not engage in any form of child labor, including, but not limited to, the internationally recognized worst forms of child labor. Facilities may not employ any person at an age younger than the law of the jurisdiction allows and in any case not below the age of 14, even if permitted by local law. In addition, facilities will adhere to local legal requirements regarding mandatory schooling. Further, if, where permitted by local law, a facility employs young workers (defined as workers whose age is between the minimum age of employment and 18 years), the facility will also comply with any applicable legal restrictions on the nature and volume of work performed by such young workers, as well as any other requirements imposed by law,

including ensuring that such young workers do not perform any hazardous work (e.g., chemical handling or operating heavy machinery).

4. Prohibition of Harassment or Abuse

Facilities will provide a work environment free of supervisory or co-worker harassment or abuse, and free of corporal punishment in any form.

Facilities will ensure a workplace that is respectful of a worker’s rights and dignity. This includes ensuring that no corporal punishment or physical coercion be used. Facilities will not engage in or tolerate sexual harassment, indecent or threatening gestures, abusive tone or language or any other kind of undesired physical or verbal contact, such as bullying. In particular, facilities will ensure proper training at all levels - including management, supervisors and workers - to secure a workplace free of harassment or abuse.

5. Compensation and Benefits

Facilities will pay at least the minimum total compensation required by local law, including all mandated wages, allowances and benefits.

Facilities will ensure proper compensation for their employees for all the work done, by providing in a timely manner all the wages and benefits that are in compliance with the local and national laws of the jurisdiction in which they are located. This will include any premiums for overtime work or work done during holidays, as well as any other allowances or benefits, including any mandatory social insurance, required by local law.

6. Hours of Work

Hours worked each day, and days worked each week, should not exceed the limitations of the country’s law. Facilities will provide at least one day off in every seven-day period, except as required to meet urgent business needs.

Facilities are required by local law to adhere to any limits set on regular working hours as well as any limits set on overtime work. Long term participation in the WRAP Certification Program is contingent upon meeting the limitations set by local law. WRAP recognizes that this can be a particularly challenging requirement, especially when taking into account local enforcement norms and customs. In light of this reality, WRAP will permit full compliance with local laws on working hours to be achieved incrementally, provided that a given facility meets the following conditions: is fully transparent about its working hours; ensures that those hours are all being worked voluntarily, in conditions that protect worker safety and health; compensates all employees in keeping with WRAP Principle 5; and shows improvement toward meeting the working hours requirements from one audit to the next.

7. Prohibition of 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.

Facilities will ensure that all terms and conditions of employment are based on an individual’s ability to do the job, and not on the basis of any personal characteristics or beliefs. Facilities will ensure that any employment decision - involving hiring, firing, assigning work, paying or promoting - is made without discriminating against the employees on the basis of race, color, national origin, gender, sexual orientation, religion, disability, or other similar factors (pregnancy, political opinion or affiliation, social status, etc.).

8. Health and Safety

Facilities will provide a safe and healthy work environment. Where residential housing is provided for workers, facilities will provide safe and healthy housing.

Facilities will provide a safe, clean, healthy and productive workplace for their employees. Facilities shall prioritize worker health and safety above all else, and proactively address any safety issues that could arise. This will include a wide variety of requirements, such as, ensuring, among other things, the availability of clean drinking water (at no charge to workers), adequate medical resources, fire exits and safety equipment, well-lighted and comfortable workstations, clean restrooms. Further, facilities shall adequately train all their workers on how to perform their jobs safely.

9. Freedom of Association and Collective Bargaining

Facilities will recognize and respect the right of employees to exercise their lawful rights of free association and collective bargaining.

Facilities will respect the freedom of each employee to choose for him- or her-self whether or not to join a workers’ association. Facilities cannot discriminate against workers based on whether or not they choose to associate. Both the facility and the workers shall ensure they conduct themselves in accordance with all relevant laws in this regard. Facilities will ensure an effective mechanism is in place to address any workplace grievances.

10. Environment

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.

Facilities will ensure compliance with all applicable legally mandated environmental standards, and should demonstrate a commitment to protecting the environment by actively monitoring their environmental practices. In particular, facilities will ensure proper waste management, including monitoring the disposal of any waste material - whether solid, liquid or gaseous - to ensure such disposal is done safely and in a manner consistent with all relevant laws.

11. Customs Compliance

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.

Facilities will ensure that all merchandise is accurately marked or labeled in compliance with all applicable laws. In addition, facilities will keep records for all materials and orders, as well as maintain detailed production records.

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).

Facilities will ensure adequate controls are in place to safeguard against introduction of any non-manifested cargo. In this regard, WRAP recognizes the United States Customs and Border Protection (CBP)’s C-TPAT Guidelines for Foreign Manufacturers as a best practice program, and has adopted those guidelines under this Principle.

1.2.1 Notes on New Principle 6: Hours of Work

Beginning January 1st, 2016, WRAP will no longer require that facilities being considered for certification demonstrate compliance with their country’s working hour or overtime laws in every audit. However, since long-term participation in the WRAP Certification Program is contingent upon meeting limitations set by local law, WRAP will permit full compliance to be achieved incrementally, provided that a given facility:

?Is fully transparent about its working hours

?Ensures that those hours are all being worked voluntarily, in conditions that protect worker safety and health

?Compensates all employees in keeping with WRAP Principle 5

?Shows improvement toward meeting the working hours requirements from one audit to the next

Factories that meet these conditions will be eligible for Gold certification even if hours worked exceed local legal limits. Gold certificates earned under such circumstances will not count towards Platinum certification. Silver certificates will no longer be given to facilities with excessive working hours, unless there are other non-compliances that necessitate a Silver designation.

If excessive working hours are identified during an audit, an Observation (not a non-compliance) must be raised on the CAP, and the facility is required to fill out a Working Hours Action Plan (see Appendix X), to be handed out and discussed during the Closing Meeting, and submitted to WRAP by the monitor the same time as the audit report. When excessive working hours are present, a WHAP must be submitted within 2-3 weeks of the audit for the certification process to continue. If the facility is delaying the process, WRAP will allow a report to be uploaded without the WHAP, but the monitoring firm is responsible for collecting the document and uploading it to the WRAP database.

The WHAP is an essential document that analyzes a facility’s production processes, identifies reduction targets, and aims to find root causes. Responsible facility personnel will be held accountable to self-determined metrics, and progress against the plan will be assessed and documented at each successive audit until the factory reaches compliance with the law. Facilities must demonstrate adequate progress toward compliance on each successive audit, as well as full commitment to the plan, in order to remain with the WRAP program.

WHAPs will be accepted on a case-by-case basis. If WRAP is not satisfied with a facility’s progress at their next certification audit, they will not be recertified. If WRAP discovers a facility has provided inaccurate, forged or falsified records, they will be immediately decertified and banned from the WRAP program indefinitely. All facilities, regardless of their WHAP, must demonstrate that all hours worked are being done so voluntarily in a safe environment and that all employees are receiving their legal compensation in accordance with WRAP Principle 5.

1.3 Facility Certification Process

1. Application:

A production facility submits basic information to WRAP and pays a registration fee of US$1195.

2. Self-Assessment:

Facilities complete a self-assessment of their facility to show they have been utilizing socially compliant practices for a minimum of 90 days. Facilities seeking re-certification are expected to have been compliant throughout their preceding certification period. WRAP offers the following resources for facilities to use during their Self-Assessment:

?Facility Self-Assessment Package in English, Spanish, Chinese and Bangla

?Production Facility Handbook in English and Chinese

?Facility Risk Self-Assessment in English, Spanish, Chinese and Bangla

3. Monitoring:

After submitting their self-assessment, the facility selects a WRAP-accredited monitoring organization to audit the facility against WRAP's 12 Principles. The audit must be successfully passed within 6 months of paying the registration fee to avoid having to re-register.

4. Evaluation:

WRAP reviews the monitor's audit report and decides whether or not to certify the facility. If WRAP decides not to issue a certification, the facility will be notified of the corrections to be made and the monitoring firm will conduct an additional inspection. If the facility does not satisfactorily implement the recommendations within the original six-month period, it must pay the registration fee again.

5. Certification:

There are three levels of WRAP certification – Platinum, Gold and Silver. The level granted to a facility is determined by WRAP and depends on the extent to which the audit indicates full compliance and management commitment to the WRAP Principles (see Section 1.2.2).

Notes:

?It is the facility’s responsibility to register on the WRAP website. The monitoring firm shall not have access to the facility’s login information.

?All facilities are subject to a random, unannounced Post Certification Audit during their certification period (see Section 6.5).

?At the end of the original certification period, the facility can apply for re-certification by registering on the WRAP website and submitting a non-refundable certification program

application fee along with their WRAP ID#.

?The facility should start the renewal process before their current certificate expires. WRAP recommends reapplying at least 2 months before the current certificate expires to ensure there

are no gaps between the facility’s certification periods (a requirement for a Platinum certificate).

1.3.1 Certification Review Board

The Review Board is an independent group responsible for the oversight and approval of factories for certification. Comprised of retired industry veterans with sourcing and compliance experience, the group acts as an impartial assessor of the information contained in the audit report. If the Review Board is confident that this information sufficiently meets WRAP requirements, a certificate will be granted. Any questions raised by the Board are addressed by WRAP staff and may be redirected to the monitoring firm or the facility. If the Review Board chooses to deny a facility certification, all relevant parties will be informed and a remediation plan set, if applicable.

1.3.2 Levels of Certification

There are three levels of WRAP certification – Platinum, Gold, and Silver. The level of certificate issued to a facility is determined by the independent WRAP Review Board and depends on the extent to which the audit indicates full compliance with, and management commitment to, the WRAP Principles.

“Platinum” level certification

?Valid for two years

?Facility must demonstrate full compliance for 3 consecutive certification audits

?Facility must s uccessfully pass each audit with no corrective actions

?Facility must maintain continuous certification with no gaps between successive certifications ?Facility remains subject to an unannounced audit during its certification period

“Gold” level certification

?Valid for one year

?Facility must demonstrate full compliance with all WRAP Principles

?Facility remains subject to an unannounced audit during its certification period

“Silver” level certification

?Valid for 6 months, and can be issued under two circumstances:

1. A facility may request a Silver level certification if an audit finds that it is in substantial

compliance with the WRAP Principles, but has minor non-compliances in policies, procedures or training that must be addressed. Important points to note:

o Factories may not have any “red flag” non-compliances such as child labor, egregious health & safety or environmental issues, prison labor, forced labor or involuntary labor, or

harassment or abuse of employees

o Factories must demonstrate that employees are paid the legal minimum wage and any required overtime compensation (i.e., if inconsistent wages are identified, the facility is not

eligible to request a Silver certificate)

o Qualifying factories must request a Silver certification from the WRAP office, in writing, at the conclusion of their first formal audit. They must also submit their comprehensive

corrective action plan and any evidence of remediation

2.The WRAP Review Board may recommend a Silver certificate if the facility has demonstrated

difficulty in achieving full compliance, or has other risk factors that indicate it may not be able to sustain compliant practices for a full one-year certificate. The facility may have these issues

during their initial audit(s) and may eventually be recommended for certification after proper

remediation.

Additional information:

?Silver factories that have two successive ‘clean’ audits will be eligible for a Gold certificate ?All factories awarded a Silver certificate must reapply prior to the expiration of their six-month certificate and pay a reduced registration fee of US$895

?Re-certification applications received after the expiration of the Silver certificate will be charged the full registration fee of US$1,195

? A facility may not be awarded a Silver certificate more than 3 times

1.4 Accreditation of Monitoring Partners

WRAP works solely with monitoring firms who have successfully met the requirements outlined in WRAP Policies for Recognition of Monitoring Partners (available for download in the WRAP database and in Appendix I). Only auditors who have successfully completed the WRAP five-day lead auditor course and are employed full time by the monitoring partner are eligible to conduct WRAP audits. WRAP may also require auditors to conduct witnessed audits, the cost of which will be borne by WRAP unless exceptions are made. If the witnessed audit identifies areas of improvement, the monitoring partner will be responsible for the cost of an additional witness audit. Approval of auditors will only be given after the successful completion of the course examination and any witnessed audits that WRAP deems necessary.

All accredited auditors must wear a valid WRAP monitor identification badge at all times while on location at the facility being audited. It is the responsibility of the monitoring firm and the individual auditor to remain valid by keeping up to date on refresher training as required by WRAP.Failure to coordinate and complete periodic training will result in the withdrawal of the auditor’s accreditation with WRAP. Dates and locations of monitor refresher courses can be found on the WRAP website. WRAP requires each monitoring partner company to have internal controls and systems that regularly update and inform their auditors on revisions or additions to the local and national laws and changes to the WRAP program. Changes to the WRAP program will be announced formally and in advance of expected implementation in order to adequately communicate updates to individual auditors.

WRAP requires auditors to operate in their native countries, and monitoring firms are limited to audits in countries for which they have been approved. For country exceptions, the monitoring firm must request approval in writing from WRAP prior to an audit taking place. Complete information of the WRAP requirements can be found in WRAP Policies for Recognition of Monitoring Partners.

WRAP has the right to request audit files from any WRAP audit at any time. WRAP may assess the internal management systems of the monitoring partner to ensure all persons involved in WRAP audits are maintaining the standards of integrity and confidentiality listed in this Handbook and in the WRAP Policies for Recognition of Monitoring Partners.

WRAP may at any time investigate the integrity and/or competence of an individual auditor and/or monitoring partner if there is reason to believe the standards listed in this Handbook and WRAP Policies for Recognition of Monitoring Partners are not being met, or if there is reason to believe the reputation of WRAP is at stake due to auditor or monitoring firm activity.

If a monitoring firm wishes to appoint a new WRAP accredited auditor, releases an auditor from duty, or has an auditor resign from their firm, WRAP must be informed within one week. Please contact the Senior Manager, Compliance Administration or call WRAP HQ at +1-703-243-0970.

2. AUDIT DOCUMENTS

WRAP requires all monitoring activity to be conducted using the below standardized supporting documents and methodology, with which all auditors must be familiar prior to the audit.

These documents are available for download by monitors with a username and password on the WRAP website. Updates will be formally announced and provided to the contact person at each monitoring firm. All auditors are required to produce and maintain audit files that support the assessments generated for each facility for a minimum period of three years.

1. Facility Self-Assessment Questionnaire

2. Man-Day, Interview, and Record Review Requirements

3. Copy of WRAP Principles

4. Opening and Closing Meeting Checklists

5. Documentation Checklist

6. Individual Employee Interview Questions

7. Group Interview Questions

8. Closing Meeting Summary

9. Corrective Action Plan

10. Detailed Audit Report

11. Facility Certification Recommendation

12. Photo Template

2.1 Facility Self-Assessment Questionnaire

The Facility Self-Assessment Questionnaire is a required tool that informs facilities of WRAP requirements and expectations. For more information, see Section 3.1.

2.2 Man-Day, Interview, and Record Review Requirements

The Man-Day, Interview, and Record Review requirements show minimum required sample sizes to ensure an adequate number of records are reviewed and employee interviews conducted. Audit reports not following these requirements will not be accepted, and the monitoring partner may be required to return to the facility to complete the lacking interviews and/or record reviews. Please see Appendix II. Important Notes:

? 1 man-day is equivalent to 8 hours. Man-days required and reported in the audit report must be fully spent on-site. This do not include time spent traveling, report writing, offsite review, etc.

? No more than 10 hours a day are to be spent on WRAP audits per auditor. If there are unforeseen circumstances, WRAP must be notified as soon as possible.

? Record review periods for new factories and recertification factories are different: o New factories: Preceding 90 days

o Recert factories: Peak, Most Recent, and Random Period over preceding 12 months ? Interviews must be with employees from different work sections and levels within the facility.

? If the facility takes 6 months or more from the date of their previous audit to remediate non-

compliances, an initial audit will be required. See Section 6.1.3 for more information.

? If there are an excessive number of non-compliances raised during the initial audit, WRAP may require an onsite follow-up audit, or in some cases, another initial audit. Monitors must confer with WRAP before they proceed.

2.3 WRAP Principles

All auditors must bring a copy of the 12 WRAP Principles to the audit for reference.

2.4 Opening and Closing Meeting Checklists

The Opening and Closing Meeting Checklists allow the auditor to ensure all areas are discussed during the opening and closing meetings.

2.5 Documentation Checklist

The Documentation Checklist includes records the facility should make available for the auditor’s assessment during the audit, such as pay stubs, time cards, and policies and procedures manuals.

2.6 Individual Employee Interview Guide

The Employee Interview Guide outlines key questions auditors must ask of selected employees during the audit. Interviews must be conducted in a manner that respects individual privacy, may be on or off site, and must be free from management participation in selection, questioning or influencing of employees. Questions provided are for subject matter guidance; auditors should use their judgment in supplementing and expanding on the questions to obtain necessary information. Use of the guide ensures presentation of properly phrased questions and sufficient coverage and follow-up of all subject matter.

2.7 Group Interview Guide

The Group Interview Guide outlines key questions auditors should ask at group interviews. These questions should be general and not personal. If the auditor feels the need to pursue a line of questioning with one member of the group, this should be done at a later time in an individual interview.

2.8 Closing Meeting Summary

The Closing Meeting Summary (CMS) must be completed by the lead auditor and signed by both auditor and facility representative at the end of the closing meeting on the last day of the audit. The monitoring firm is responsible for uploading a combined pdf of the CMS and CAP pages (see below) to the WRAP database within 3 business days of audit completion for every on-site audit.

2.9 Corrective Action Plan

The Corrective Action Plan (CAP) allows the lead auditor to summarize areas of non-compliance and document the corrective actions agreed upon by the facility during the closing meeting. Corrective action findings are completed prior to discussing non-compliances with management. The facility must then write their corrective action plan, along with a proposed date of completion and the person responsible for carrying out the remediation. The auditor may physically write for the facility, but the facility must present their own plan in their own words.

The CAP identifies a remediation plan that the lead auditor considers adequate to ensure the root cause of the issue is being addressed and the facility will be able to achieve full compliance with WRAP’s 12 Principles by the date listed. The signed CAP also serves as documentary evidence that the facility was informed of all findings prior to the auditor’s departure, and must therefore be retained in the audit files. While it is acceptable for some difference of opinion to exist between the facility and auditors on Principle compliance, the auditor should obtain management’s agreement on objective evidence that supports the findings. If substantial and substantive differences exist between a facility and lead auditor over the findings of the on-site evaluation, the lead auditor must inform the facility of their right to appeal to WRAP for review of the objective evidence.

It is acceptable if the facility does not know their plan of action or projected completion date at the time of the Closing Meeting; however, this is an exception and should occur rarely. The auditor must explain the situation on the CAP, but the facility is responsible for updating the auditor within a reasonable amount of time (if that exceeds one week, the monitor must contact WRAP).

2.10 Detailed Audit Report

The Detailed Audit Report provides a comprehensive description of the facility and any findings raised. Each section of the report is to be completed with the requested amount of detail; the general rule is, you cannot include too much information. Findings should be clearly stated in objective terms and provide sufficient information to paint an accurate picture.

Auditors should apply internal controls to ensure the findings documented in reports remain confidential, and the names of individual workers should not be mentioned in cases that may compromise their identity. Distribution of the audit report should be limited to the facility, the entity paying for the audit, and WRAP staff unless otherwise authorized by the facility.

The full audit report should be prepared as soon as possible after audit completion. The auditor should not delete any fields or prepopulated words or boxes, and copying and pasting from previous audit reports is not allowed.

2.11 Facility Certificate Recommendation

The Facility Certification Recommendation (FCR) is to be submitted to the facility, the entity paying for the audit, and WRAP staff along with the final report. The FCR must be completed in full with all required signatures and the dates of all visits, and inserted as the first page of the report.

3. AUDIT PLANNING

3.1 Review of Facility Self-Assessment Questionnaire

Upon completion of the Self-Assessment process, the facility must submit copies of completed documentation to WRAP and the selected independent monitoring partner. The auditor who is to conduct the audit must be in receipt of the completed Self-Assessment for at least 15 days prior to the audit. This will allow the auditor time to review the information within the questionnaire.

Controls should be in place to ensure the auditors are not informing the factories of their audit date; however, this does not mean the completed Self-Assessment should be withheld from the auditor as it is an important document crucial to carrying out of the audit. Methods such as blinding the identifying facility information and releasing the Self-Assessment but not the audit date may be used to keep the audit date confidential. If the actual audit date is released to the facility before the audit, WRAP will take appropriate actions against the monitoring firm and the auditor(s). Sanctions may include but are not limited to: written warning, temporary suspension of WRAP accreditation, or permanent suspension from all WRAP audits.

Returned documents shall be used to perform a preliminary risk assessment of the facility before arriving at the site. The documents have been designed to enable the lead auditor to extract the following types of information from a facility for assessment purposes:

1.The overall profile of the Facility

2.The number of workers employed at the Facility

https://www.360docs.net/doc/9316495592.html,nguages spoken by the management and employees

4.If there are foreign or migrant workers employed

5.Whether or not the facility offers dormitories to their workers

5. The manner in which WRAP requirements have been deployed within the facility

Once the monitoring partner is satisfied that the facility has satisfactorily completed the questionnaire, the monitor should schedule an un-announced on-site visit to the facility. If the lead auditor requires more information that would enhance the on-site monitoring visit, the lead auditor must obtain that information from the facility prior to the on-site compliance visit.

3.2 Types of Audits

All on-site WRAP audits are to be conducted in an unannounced manner with a four-week audit window issued to the facility, with the exception of Post Certification Audits, which are to be completely unannounced. The audit should take place unannounced during the dates of the issued audit window. This includes initial audits, on-site follow-up audits, Post Certification Audits, and Alternative-to-Decertification follow-up audits. The only type of audit that is not unannounced in the WRAP program is a desktop review.

All possible measures should be taken to keep the actual date(s) of the audit confidential through effective and enforced internal management system procedures within the monitoring company. If WRAP has any reason to believe the audit dates are being announced to the facility, or that the monitoring partner is not following protocol, WRAP may impose sanctions.

Additional Expectations for Address Confirmation:

?It is forbidden to contact the facility in such a way that will inform them that an audit will be taking place on a specific date. If the address information is not adequate or complete, please let the requesting office know ASAP so that they may request directions to the facility.

?In the event that the team is on the ground in the general area of the facility and the address and/or directions to the facility are not adequate, the facility may be contacted directly. However, no indication of why and when the visit is occurring may be communicated to the facility unless absolutely necessary to receive accurate information to find the facility.

?Every attempt must be made by the auditors to find the facility without contacting them directly.

3.2.1 First-Time Certification audits

First-time certification audits are for facilities who:

? Are brand new to the WRAP program

? Have been a part of the WRAP program at some point but have since moved to a new

address/location (these factories must register as a New Facility on the WRAP website)

? Have been certified in the past, but the most recent certification has been expired for 12 months or more from the date they pay the WRAP registration fee

Records should be reviewed from the preceding 90 days. The facility must be in operation for at least 90 days and have 90 days of records before the audit is conducted.

First-time certification audits follow the Man-Day, Interview, and Record Review Requirements as found in Appendix II, with careful attention to the presence of dormitories.

3.2.2 Recertification Audits

Recertification audits are conducted in the same way as first-time certification audits, the only difference being that hours and payroll records are reviewed for the whole of the preceding twelve months (see below for breakdown of periods). Please refer to the Man-Day, Interview, and Record Review Requirements found in Appendix II.

Wage and hour records to be reviewed over preceding 12 months:

? Most recently completed period (records of everyone interviewed)

? Peak production period (if applicable; records of everyone interviewed)

? Random period *

* For Random periods, check 20% of records unless payment or working hour discrepancies are found.

3.3 Sequence of Audits

The chart below shows the sequence of audits for facilities prior to and post-certification. All follow-up activities will be determined by the quantity and type of non-compliances raised during the initial or post certification audit. Guidelines for determining follow-up activities are provided in Section 6. Array 3.4 Scheduling of an Audit

The auditor must complete the following before the audit:

? Check that WRAP has received registration payment from facility

a.To verify, check one of the following:

1. Request “WRAP Payment Confirmation” from facility (this is sent by WRAP

once the payment has been received and approved)

2. Login to WRAP database. If the facility is listed in the database within the

auditor’s module, they have paid the registration fee

? Issue the facility a four-week audit window

a. Facility should approve the window and inform auditor of any holidays and days when

facility is not in operation; if the holidays or days off effectively reduce the possible audit

window time to where the audit is not unannounced, a new audit window should be issued ?Receive and review Self-Assessment from facility to ensure that the facility understands WRAP requirements and is ready for the audit

?Plan the number of man-days that are required to be spent at facility. See Appendix II.

?Select auditor/audit team

The cost of the audit will be borne by the facility and paid directly to the monitoring partner they selected from the approved list of accredited independent monitoring firms upon registering with WRAP. The monitoring firm will be independently contracted to perform the on-site evaluation as per the regulations and guidelines of the certification program and this Monitor’s Handbook. The costs entailed in the contracting of a monitoring firm will be negotiated directly between the facility and the selected monitoring partner.

Note: the facility’s registration payment is valid for 6 months from registration. The facility has the option to request a 3-month extension, provided they have been doing substantive work but need more time to take corrective actions.

3.4.1 Selecting the Auditor/Audit Team

The core skills required of each auditor are: knowledge of national and local labor laws, knowledge of observation and testing techniques, knowledge of interrogation for objective evidence, the ability to conduct sensitive and confidential worker interviews, the ability to review employee records, the ability to be a facilitator for compliance, and the ability to read, write and understand the English language. The auditor(s) must be auditing in their home country at factories that speak their native language. They must be fluent in the local language and familiar with regional culture and customs. Special cases will be approved by WRAP on the basis of lack of accredited auditors in the country from all WRAP accredited monitoring partners. The monitoring partner must first seek approval from WRAP before an audit takes place if their auditor is not from the country where the facility is located and does not speak the language spoken by the majority of the workers and the facility management.

Translators must be present if the auditor is not fluent in the language spoken by the majority of the workers and management. Translators must also be independent of the facility; management cannot supply or act as translators. Translators do not count towards the man-day requirements. Auditors should be aware of migrant workers and their language capacities and plan accordingly.