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© 2016 AsiaInspection Limited. AI-QR-16-01A Page 1 of 35 Ethical Audit Report Client Icebreaker AI Service No R-us3-1658993 Supplier Double Retail Ltd. Auditor Sevinch Saidova Factory PAFOS Date 31-Aug-2016 Industry Homeware & Gardenware Country Greece Factory Overall Score of a possible 10 Audit Rating Approved Critical NC Major NC Minor NC Score out of 10 Health & Safety, Hygiene 35% 0 4 0 8,8 Waste Management 20% 0 0 2 8,7 Child Labor 15% 0 0 0 10 Hours, Wages & Benefits 20% 0 0 0 10 Labor Practices 10% 0 0 0 10 Total 0 4 2 9.3 NC: Non-Compliances 9.3 8.5 N/A 7.9 Green 9.3 Factory Overall Score Your suppliers’ average Country average Industry average Valid until: 31-Aug-2017

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Page 1: Ethical Audit Reportpafos.gr/pdf/R-us3-1658993-AI Ethical Audit... · Relationship between audited company and supplier is very good. They work together from 1999 Partial Owned-0%

© 2016 AsiaInspection Limited.

AI-QR-16-01A Page 1 of 35

Ethical Audit Report

Client Icebreaker AI Service No R-us3-1658993

Supplier Double Retail Ltd. Auditor Sevinch Saidova

Factory PAFOS Date 31-Aug-2016

Industry Homeware & Gardenware Country Greece

Factory Overall Score of a possible 10

Audit Rating Approved

Critical NC Major NC Minor NC Score out of 10

Health & Safety, Hygiene 35% 0 4 0 8,8

Waste Management 20% 0 0 2 8,7

Child Labor 15% 0 0 0 10

Hours, Wages & Benefits 20% 0 0 0 10

Labor Practices 10% 0 0 0 10

Total 0 4 2 9.3 NC: Non-Compliances

9.3

8.5

N/A

7.9

Green

9.3

Factory Overall Score

Your suppliers’ average

Country average

Industry average

Valid until: 31-Aug-2017

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Ethical Audit Report

Description of audited plant The social accountability audit at Pafos SA is conducted on an semi-announced audit basis on 31, August 2016. The auditor was greeted by Mrs.Mina Skariba /Factory H&S Representative. After exchanging business cards, an opening meeting was held to introduce the purpose and procedures of current audit. Document review, Health and safety walkthrough and private employee interviews were conducted at the facility. The facility is located at 32011 Inofita Viotias Greece -Greece county .The main processes are including cutting, assembling, painting, QC and packing. The factory has one building with two floors. They have: eating room, warehouse, cutting, assembling, painting, finishing sections and administration, no dormitories were available. There were total 63 employees and they were all hired by the factory directly. No worker was employed through labor brokers or agents. No recruitment fees were charged by the factory per management review and workers’ interview Supplier Name: Double Retail Ltd. During interview with the management, it was noted that: Relationship between audited company and supplier is very good. They work together from 1999 Partial Owned-0% There is no other subcontractors They have ISO 9001-2008 BY TUV HELLAS

Important remarks Part 1 Health & Safety, Hygiene 1. Sufficient fire fighting equipment’s such as fire hydrant, fire extinguishers were installed and smoke detectors. 2. Sufficient documents such as fire certificate and construction certificate was provided for review. 3. No kitchen or dormitory was available for employee, a dinning place was provided for employees. 4. They have PPE equipment in the facility. Also PPE’s are posted. 5. Auditor noted that of the second emergency exit door in packing area, leading to the outside area of the facility are blocked. 6. Four fire extinguishers were blocked in production area. 7. There is no emergency exit lighting in the incoming materials warehouse.(new warehouse 8. Missing evacuation plan in the incoming materials warehouse.(new warehouse) Part 2 Waste Management 1. EIA documents except environmental policy were provided for review. 2. The factory did not monitor water and energy consumption. Part 3 Child Labour 1. From the facility tour, it was noted that there were no children on site. 2. The facility verifies all employees’ original ID cards at the time of recruitment and keeps the photocopies of employee’ ID cards in the personnel files. Part 4 Working Hours, Wages and Benefits 1. All workers are provided social insurance, according to the legal requirements 2.The maternity leaves are paid according to regulations 3. No overtime work observed based on records sample and employees interviews. 4.The workers were received pay slip for each month Part 5 Labour Practices 1. Through the facility management and employee interview, it was noted that no physical abuse or discipline happened in the facility. 2. The interviewed employees raised no concerns of forced or bonded labour. 3. They stated that they are free to leave their working stations once their shifts end. 4. There is an open door policy that employee can complain directly to the top management and suggestion boxes. 5. No issue of discrimination in this facility.

Home Workers and Subcontractors Is there any home workers used by factory? No If yes, description: N/A Is there any subcontractor used by factory? No If yes, description: N/A

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Ethical Audit Report

Content :

A. OBSERVATION & QUESTIONS.............................................................................................................................................................7

BASIC FACTORY PROFILE ............................................................................................................................................................................7 PART 1 HEALTH & SAFETY, HYGIENE ............................................................................................................................................................8

1. General................................................................................................................................................................................ 8 2. Building Safety .................................................................................................................................................................... 9 3. Fire Safety ......................................................................................................................................................................... 10 4. Machines/Installations ...................................................................................................................................................... 13 5. Hazardous Materials ......................................................................................................................................................... 14 6. Canteen and Dormitories (if Applicable) ........................................................................................................................... 17

PART 2 WASTE MANAGEMENT .................................................................................................................................................................18 1. Legal Authorizations.......................................................................................................................................................... 18 2. Solid and Hazardous Wastes ............................................................................................................................................. 18 3. Waste Water, Air Emissions and Noise .............................................................................................................................. 19 4. Energy and Water reduction ............................................................................................................................................. 20

PART 3 CHILD LABOUR ............................................................................................................................................................................22 1. Child Labour ...................................................................................................................................................................... 22 2. Young Workers .................................................................................................................................................................. 22

PART 4 WORKING HOURS, WAGES AND BENEFITS ........................................................................................................................................24 1. Working Hours .................................................................................................................................................................. 24 2. Wages and Benefits........................................................................................................................................................... 25

PART 5 LABOUR PRACTICES ......................................................................................................................................................................28 1. Ability for Workers to be represented towards management .......................................................................................... 28 2. Forced Labour ................................................................................................................................................................... 28 3. Discrimination ................................................................................................................................................................... 29 4. Disciplinary Practices ........................................................................................................................................................ 29

B. EMPLOYEE’S INTERVIEW ..................................................................................................................................................................31

C. CORRECTIVE ACTION PLAN ..............................................................................................................................................................32

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Ethical Audit Report

Number of days spent: ONE MAN-DAY

Auditor 1: Sevinch Saidova Supervisor: Lalit Gupta

Departure time from home / office Arrival time at Factory Departure time from Factory

08.00 9.20 17.00

GPS Location Map Factory Gate

Factory Building Incoming material in the factory

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Ethical Audit Report

Management Licenses / Accreditations

Certificates Licenses / Accreditations

Workers on site Workers on site

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Ethical Audit Report

Workers on site Workers on site

Workers on site Workers on site

Workers on site Workers on site

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Ethical Audit Report

A. Observation & Questions Basic Factory Profile

Item Finding Comments 1 Date of formation 31.08.2016

2 Legal status Private

3 Location 32011 Inofita Viotias Greece -Greece county

4 GPS Location 38°17'19'' N 23°36'30'' E

5 Area (m2) 8.000 sqm

6 Owner Mr.Stelios Pafos and Mr.Kostas Pafos

7 Total staff in the factory 63

8 Total office staff 12

9 Total Management staff 5

10 Number of workers 46

11 Factory Manager Mr.Stelios Pafos

12 Health and Safety Manager Mr.Michalies Atanaspolis

13 Main products Furniture

14 Main markets Chanel, Samsung, Wind Cosmote,Kowrres

15 Annual turnover 4.764836euro.

16 Business license Date of issue: 04.12.1948

Registration # 033708880 Expiry date: N/A

17 Payroll records of all employees

12 months from August 2015 till September 2016

18 Time cards for all employees

12 months from August 2015 till September 2016

19 Subcontractors No Subcontractors

20

Co

mm

un

icat

ion

eq

uip

men

t

Telephone 32

Fax 0

Computer 33

Internet WI-FI

Homepage www.furniture-constructions.com

Digital camera 5

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Ethical Audit Report

Part 1 Health & Safety, Hygiene

1. General

Item No

Requirement Result Comments

1.1 Is a risk analysis conducted to identify the risks associated with production and is this risk analysis reviewed regularly and updated when necessary?

Pass There was a risk analysis conducted to identify the risks associated with production and updated regularly

1.2 Is there a senior management representative for Health & Safety?

Pass Factory has designated a senior management representative ( Mrs. Mina Skariba) for Health and Safety.

1.3 Does the factory arrange health and safety training for new workers and for everyone who changes working roles?

Pass During review of documents, it was noted that the factory arranges initial job training regarding health and safety t all new workers.

1.4 Does the factory have a working environment that is well-ventilated, comfortable temperature, decent lighting, clean, tidy and enough room for each worker? If there are any possible issues that would impact the health of the worker, please give details.

Pass The factory had a working environment that was well-ventilated, comfortable temperature, decent lighting, clean, tidy and enough room for each employee.

1.5 Are all serious work-related accidents reported and recorded and corrective actions taken to prevent recurrence of work-related accidents?

Pass The factory had production safety policy, and factory provided work-related accident/injury records for review, no work-related accidents/injury happened in the past year.

1.6 Is appropriate and adequately maintained personal protective equipment (PPE) provided by the factory?

Pass The factory had provided PPE (face mask and gloves) in the chemical place.

1.7 Have workers been trained in the use of PPE and are using provided equipment correctly?

Pass The employees had been trained in the use of PPE, the last time was on 26-Oct-2015, and employees were using provided equipment correctly.

1.8 Do workers have access to an adequate amount of fresh drinking water?

Pass Workers are provided drinking water however. Also there was testing report for drinking water.

1.9 Is there an adequate number of first aid kits? Pass During factory tour, it was noted that the adequate numbers of first aid kits are provided by the factory in all working areas. Total four first aid kit.

1.10 Are first aid kits easily accessible and clearly marked and the content within the expiry date, applicable and replaced when used?

Pass The first aid kits were clearly marked and the worker could have access to them, and based on sampled check the first aid kits, all fist articles were in good condition.

1.11 Are adequate workers trained on first aid? Specify the number of trained personnel at the factory

Pass There were total 26 first aiders available in the factory, which was adequate in quantity.

1.12 Are lavatory and or washroom facilities, clean, well maintained, adequate in number, separated by sex, and with relevant privacy?

Pass They have total 16 toilets. The lavatory facilities are clean, well maintained, adequate in number, separated by sex, and relevant privacy.

Picture(s)

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Ethical Audit Report

First aid kit First aid kit with medical materials

Test for drinking water Toilet

2. Building Safety

Item No

Requirement Result Comments

1.13 Are legal construction certificates (building structure) available?

Pass During the review of documents, it was noted that all legal construction certificates for building are available.

1.14 Are all site buildings, including dormitories maintained in good condition without posing a threat to the health of workers?

Pass Based on on-site observation, the working environment is well-ventilated, comfortable temperature, decent lighting, clean, tidy and enough room for each worker.

Picture(s)

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Ethical Audit Report

Construction certificate for building Lay out for building

3. Fire Safety

Item No

Requirement Result Comments

1.15 Does the factory have adequate unblocked fire exits for every factory workshop/floor?

Major Auditor noted that of the second emergency exit door in packing area, leading to the outside area of the facility are blocked.

1.16 Has the factory been certified by the local fire bureau, and made efforts to comply with recommendations from audits?

Pass The factory had obtained fire service acceptance certification from the local fire bureau.

1.17 Are there an adequate number of fire extinguishers and or other fire extinguishing systems in each building (including the dormitories)?

Major Four fire extinguishers were blocked in production area. There are an adequate number of fire extinguishers (total 54 sets) and hydrants (total 15 sets) in the factory.

1.18 Are all fire extinguishing systems (including fire hoses) inspected, maintained properly and ready to use at all times?

Pass The factory has regular inspection or maintenance records for all fire equipment’s.

1.19 Are fire drills conducted regularly? Pass During workers interview and review of documents, It was noted that employees are receive firefighting training and fire drills. The factory conducted last fire drill on February 2016.

1.20 Are there fire alarms on each floor and adequate emergency lighting above exits and in working order?

Major There were fire alarms on each floor in the facility. There is no emergency exit lighting in the incoming materials warehouse.(new warehouse)

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1.21 Are there fire/evacuation procedures in place with relevant evacuation plans posted in every workshop?

Major Missing evacuation plan in the incoming materials warehouse.(new warehouse) The fire/evacuation procedures are posted in other working place. Where “I Am are” clearly marked on the evacuation plans.

1.22 Are smoke detectors/sprinklers installed in all workshops/warehouses?

Pass There were sprinklers installed in warehouse.

Picture(s)

Fire hose Fire extinguisher

Evacuation plan Emergency exit sign with battery

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Ethical Audit Report

Fire drill record Fire inspection by external company

Missing evacuation plan in the incoming materials warehouse Fire extinguisher is blocked

No emergency exit lighting in the incoming mat. warehouse Fire extinguisher is blocked

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There is no emergency exit lighting in the incoming materials warehouse.(new warehouse)

The second emergency exit door in packing area, leading to the outside area of the facility are blocked.

4. Machines/Installations

Item No

Requirement Result Comments

1.23 Does the factory have appropriate maintenance/inspections for boilers, elevators, pressure vessels and other equipment per local regulation?

Pass The factory provided inspection report of boilers, pressure vessels for review.

1.24 Are adequate guarding or devices installed for moving/rotating parts of machine, pulleys and belts or any other dangerous parts of machines?

Pass During factory tour, it was noted that all machines with protective devices.

1.25 Are all electricians, welding operators and forklift drivers and other employees who operate special equipment trained and qualified per local regulations?

Pass The factory has a qualified electrician with valid operation license.(Name: Mr.Teodor Paradulakis)

1.26 Are all electrical wires in the facility adequately protected?

Pass All electrical wires in the facility are adequately protected.

1.27 Are there appropriate warning signs and written instructions for the operators of machinery?

Pass The warning signs and written instruction were posted on-site

1.28 Do operators of machinery get training about safety regulations and operating procedures?

Pass Operators of machinery were trained about safety regulations and operating procedures. All training records were available.

Picture(s)

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Ethical Audit Report

Machine inspection record The machine with working instruction

5. Hazardous Materials

Item No

Requirement Result Comments

1.29 Are hazardous materials / chemicals properly stored, with relevant container and secondary container?

Pass All chemicals are properly stored with secondary container.

1.30 Does the factory have MSDS and warning / "No Smoking" signs for each chemical products?

Pass The factory has “No Smoking signs”. MSDS was available for the chemicals used and stored area at the factory.

1.31 Are these materials only accessible to competent employees ?

Pass All materials are accessible to competent employees.

1.32 Are the designated employees properly trained for the handling of these hazardous materials ?

Pass They have properly training regarding hazardous materials.

Picture(s)

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Ethical Audit Report

No smoking sign in the facility. Secondary container.

PPE sign PPE sign

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Ethical Audit Report

PPE’s are available PPE-ear plug

Coffee place MSDS

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Ethical Audit Report

6. Canteen and Dormitories (if Applicable)

Item No

Requirement Result Comments

1.33 Are the factory kitchen and canteen clean and hygienic with adequate facilities and the required permits and certificates, including canteen staff health certificate?

Pass They factory eating place was clean and hygienic.

1.34 Are workers’ dormitories separated from production's building and/or warehouse?

N/A No dormitory is available.

1.35 Are all exits unblocked and unlocked at all times for emergency evacuation in dormitories?

N/A No dormitory is available.

1.36 Are workers free to exit & re-enter dormitory freely? Please provide details of any limitations.

N/A No dormitory is available.

1.37 Does each worker have adequate living space? Please indicate the space per worker and number of workers per room.

N/A No dormitory is available.

1.38 Are the dormitories clean? Are there adequate toilets with hand basins available to workers at adequate distance at dormitory? Are there adequate bathrooms available to workers at dormitory? Are sanitary areas clean and hygienic with available washing facilities.

N/A No dormitory is available.

1.39 Are there recreation areas for the workers? N/A No dormitory is available.

Special Remarks on this section 1. Sufficient fire fighting equipment’s such as fire hydrant, fire extinguishers were installed and smoke detectors. 2. Sufficient documents such as fire certificate and construction certificate was provided for review. 3. No kitchen or dormitory was available for employee, a dinning place was provided for employees. 4. They have PPE equipment in the facility. Also PPE’s are posted. 5. Auditor noted that of the second emergency exit door in packing area, leading to the outside area of the facility are blocked. 6. Four fire extinguishers were blocked in production area. 7. There is no emergency exit lighting in the incoming materials warehouse.(new warehouse 8. Missing evacuation plan in the incoming materials warehouse.(new warehouse)

Critical NC Major NC Minor NC Score /10

0 4 0 8.8/10

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Ethical Audit Report

Part 2 Waste Management 1. Legal Authorizations

Item No

Requirement Result Comments

2.1 Does factory have a valid Environmental Impact Assessment (where applicable)?

Pass During review of documents, it was noted that the factory has obtained the Environmental Impact approval. They have Environmental policy

2.2 Does factory have a valid Approval Report of Environmental Impact Assessment, or relevant legal document to start operations?

Pass Factory has obtained the Environmental Impact approval

2.3 Does factory maintain a valid Pollutant Discharge Permit or equivalent, where applicable?

N/A No such requirement for the factory.

Picture(s)

Environmental Impact Environmental policy

2. Solid and Hazardous Wastes

Item No

Requirement Result Comments

2.4 Does factory inventory all solid wastes, including kind, sources, and quantities?

Pass The factory provide treatment records and master list of all solid wastes, including kind, sources, and quantities for review

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2.5 Does factory adequately separate recyclable from non-recyclable wastes in workshops/warehouses?

Pass The factory adequate separate recyclable from non-recyclable wastes in workshops and warehouse

2.6 Can factory prove that they have taken actions to reduce/recycle/re-use solid wastes as much as possible?

Pass They take actions to reduce/recycle/re-use solid waste.

2.7 Does factory inventory all hazardous wastes, including kind, sources, and quantities?

Pass The chemical use and stock records were provided for review

2.8 Does factory store hazardous wastes in a relevant ways, closed, with control access and ensure it cannot spill?

Pass The factory store hazardous wastes in a relevant ways, closed, with control access and ensure it cannot spill.

2.9 Is factory able to prove that hazardous wastes are transferred to 3rd party with relevant certifications, and keep records of wastes transfer including quantities?

Pass All wastes had been transferred to licensed vendor for disposal. The factory are prove that hazardous wastes are transferred to 3rd party with relevant certifications, and keep records of wastes transfer including quantities

Picture(s)

Treatment records for all wastes Transportation permit of the solid waste

3. Waste Water, Air Emissions and Noise

Item No

Requirement Result Comments

2.10 Does factory inventory all waste water, including domestic waste water and industrial waste water, with sources and quantities?

Pass No industrial water is generated from production processes. Only domestic waste water is generated

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2.11 If applicable, is factory able to demonstrate that waste water is treated adequately before discharge, with relevant equipment and trained staff?

N/A No waste water except the living water produced or discharged.

2.12 Is factory able to demonstrate that waste water at discharge point is meeting the local standards requirement (through lab testing reports)?

N/A No waste water except the living water produced or discharged.

2.13 When observing waste water discharge point, does water seem to have color or odor on audit day?

N/A No industrial water is generated from production processes. Only domestic waste water is generated.

2.14 Does factory inventory all air emissions, with sources and identification of treatment needed?

Pass No air emission is generated from production processes.

2.15 Is factory able to demonstrate that air quality at factory's boundaries is meeting the local standards requirement (through lab testing reports)?

Pass No air emission is generated from production processes.

2.16 On audit day, is there any smell, fog, or dust observed by auditor on factory's direct environment, linked to factory's activity?

Pass The workshop seem in good environment. No dust or fog was observed.

2.17 Is factory able to demonstrate that noise level at factory's boundaries is meeting the local standards requirement (through lab testing reports)?

Pass The noise and temperature levels at factory’s boundaries on lab testing report are available

Picture(s)

Dust clean system in the facility Test Report for each working place for noise

4. Energy and Water reduction

Item No

Requirement Result Comments

2.18 Can factory demonstrate that energy use is monitored and that actions have been taken to reduce energy use?

Minor The factory did not provide any evidences to demonstrate that energy use is monitored and that actions have been taken to reduce energy use.

2.19 Can factory demonstrate that water use is monitored and that actions have been taken to reduce water use?

Minor The factory did not provide any evidences to

demonstrate that the factory had monitored and

taken actions to reduce water use.

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Special Remarks on this section 1. The noise and temperature levels at factory’s boundaries on lab testing report are available. 2. The factory did not monitor water and energy consumption.

Critical NC Major NC Minor NC Score /10

0 0 2 8.7/10

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Ethical Audit Report

Part 3 Child Labour 1. Child Labour

Item No

Requirement Result Comments

3.1 Does the factory complies with the legal minimum age ? Please note the age of the youngest worker found.

Pass Local minimum age: 16 years old. Greek Labour Code The minimum wage of employment shall be 16. The employees on the work floor seem mature and the youngest employee was 24 years old who was born on, 06-April-1992 and was recruited in March 2015

3.2 Does the factory have effective procedures such as verifying suspected young worker documents to confirm the correct age of the worker at the time of recruitment?

Pass The factory had established the workers requirement procedure.

3.3 Does the factory sign contracts with all workers and keep copies or records of ID documents of workers or similar way to check age?

Pass During the review of personal files, it was noted that ID copies are kept in files; and the factory signed labor contracts with all employees.

3.4 Does the factory have understand the requirements of laws and regulations on child labour and young workers? If so, is there a written child labor policy?

Pass Based on management review, they were familiar with the child labor requirement, and obtained the child labor laws in the factory.

2. Young Workers

Item No

Requirement Result Comments

3.5 Are young workers exempted from hazardous work?

N/A As observed on the work floors, all the employees are mature and the youngest employee was 24 years old.

3.6 Are young workers exempted from night shift? N/A No young workers were found during audit day

3.7 Are young workers exempted from overtime? N/A No young workers were found during audit day

3.8 Are young workers registered and given annual health checks?

N/A No young workers were found during audit day

Picture(s)

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Child labor policy Labor contract

Special Remarks on this section 1. From the facility tour and workers interview, it was noted that there were no children on site. 2. The facility verifies all employees’ original ID cards at the time of recruitment and keeps the photocopies of employee’ ID cards in the personnel files.

Critical NC Major NC Minor NC Score /10

0 0 0 10/10

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Part 4 Working Hours, Wages and Benefits

1. Working Hours

Item No

Requirement Result Comments

4.1 Do the working hours of individual workers comply with local regulation? Do the working hours exceeds the international recommendation of 60 hours / week ?

Pass Greek Local legal standard: Article 3863/2010 1) Full working hours shall not exceed 8 hours per week and 40 hours a week. The rule is 8 hours of work, 5 days a week. In general, it is not permissible to ‘offset’ working time, not even with the employee’s consent. The only exceptions are as follows: a) a 9-hour working day is permitted, where the total working time for the week does not exceed 40 hours. b) over the course of a 6-month period, work can be increased by 2 hours a day (i.e. up to 10 hours) with a corresponding reduction in the working time each day by 2 hours during the next 6-month period (i.e. up to 6 hours). Instead of reduced employment, it is possible for rest days to be given. c) It is also possible to increase the rate of work by up to 256 hours within a period of 8 calendar months, with a corresponding period of reduced employment during the other months of the same calendar year. Special legislative provisions apply to undertakings which operate using shifts. Factory provided 100% of workers manually attendance records (from 01-August-2015 to 01-September-2016) for review. 10 sampled workers’ time records, February 2016 , June-2016 and July-2016 were selected to check details. The working hours per day are 08:00 AM to 16.30PM, with 30 minutes lunch break ; 8 hours per day; 5 days per week; total of 40 hrs. per week. There are payrolls for each month and 12 month records from 01-June-2015 to June-2016 were checked. The working hours are specified in the manually attendance records. Remark: Based on the electronic time card system, payroll records, management and worker interview, it was noted that there were overtime hours per day, per week, per month.

4.2 Do workers have 1 day off within 7 days (or 2 days off within 14 days where applicable)?

Pass During review of time system and interview of workers, it was noted that they have 2 days off / week (Saturday and Sunday).

4.3 Does the factory record the working hours of individual workers in a reliable manner?

Pass They have electronic time card system for recording working hours.

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4.4 Are workers given reasonable time for lunch and rest breaks?

Pass Based on the working time procedure daily schedule is 08:00 AM to 16.30PM, with 30 minutes lunch break(from 12.00 till 12.30)

4.5 Are workers assigned overtime on a voluntary basis?

Pass Overtime is conducted on a voluntary basis.

4.6 Do workers have legal vacation, national holidays and paid leave?

Pass During review of time system and interview of workers, it was noted that they have 2 days off / week (Saturday and Sunday).

Picture(s)

Working policy Attendance book

2. Wages and Benefits

Item No

Requirement Result Comments

5.1 Is there any evidence that the legal minimum wage is not paid for regular working hours ? Please specify

Pass Local legal standard:# 3863/2010 According to the Greek National Collective Agreement minimum wage for daily salaried employees starts : Minimum wage for daily salaried employees starts: 22,83€ per day (age<25) and 26,18€ (age>25). According to Law No 3863/2010,Article 74: The 41st to 45th weekly hours of work (for the 5 days per week contracted) and the 41st to 48th weekly hours of work (speaking of 6 days per week contracted) are compensated as +20% (called “overwork” and does not need special permit to be

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performed). Any working hour beyond the 45th or the 48th, weekly working hour to the limit of 120 hours per year is compensated as +40% as long as a relevant permit is in place and with a +80% if no permit is in place. Any further overtime working hours (above the limit of 120/year) is compensated with a 60% Minimum wage according to actual legislation, In this facility the lowest agreed and paid daily wage is 28,00 € (gross) is paid for all employees. No overtime work was observed through the records. Factory provided 100% of workers payroll records (from 01-August-2015 to 01-September-2016) for review. 10 sampled workers’ electronic attendance records and payroll records February-2016, June 2016 and July 2016 were selected to check minimum wage, overtime wage.

5.2 Are overtime hours paid with legal premium? Pass No overtime work in the facility confirmed from the worker's interview

5.3 Does the factory have written employment conditions on compensation, compensation methods and benefits that is communicated to and understood by all workers?

Pass They have written employment conditions on compensation and understood by all workers.

5.4 Is the payment paid at a reasonable and legal frequency (monthly), and in a form convenient for workers (cash, bank,…)?

Pass Payment is done per month, first payment 15th, and second payment to 30th. Payment is done via bank.

5.5 Do workers receive a pay slip to sign that has information that will allow them to confirm their wages and see all deductions and bonuses?

Pass The pay slip was provided for workers confirmed by workers interview. (Confirmed from the worker’s interview.

5.6 Are deductions fair, reasonable and legal (such as social insurance or other tax)?

Pass all deductions are according to the actual legal requirements.(social insurance, health insurance, income tax)

5.7 Are all workers provided social insurance as per local legal requirements? If no, please specify what is the percentage of employees without social insurance scheme.

Pass During review of payroll records and interview of workers, it was noted the all workers are provided social insurance, according to the legal requirements.

5.8 Is maternity and paid leaves paid as per regulations?

Pass During the review of documents, it was noted that maternity leaves are paid according to regulations.

5.9 If deductions as disciplinary practices are used, are they falling under regulatory rules?

Pass No disciplinary deduction noticed .They have rules regarding disciplinary deductions, according to legislation, are established in the internal regulation for employees.

Picture(s)

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Social insurance records Payroll record

Nil

Overtime policy including in Social policy Nil

Special Remarks on this section 1. All workers are provided social insurance, according to the legal requirements 2.The maternity leaves are paid according to regulations 3. No overtime work observed based on records sample and employees interviews. 4.The workers were received pay slip for each month

Critical NC Major NC Minor NC Score /10

0 0 0 10/10

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Part 5 Labour Practices 1. Ability for Workers to be represented towards management

Item No

Requirement Result Comments

6.1 If applicable by Local Law, do workers have the right to join or for trade unions and bargain collectively, without interference of employer?

Pass Based on the worker interview, the workers have the right to join or for trade unions .They have employee’s representative in the facility.

6.2 If there is no union, are there fair and effective parallel means to resolve grievances of workers (workers representatives,…)?

Pass Based on the worker interview, they communicated with management face to face directly.

6.3 Is there evidence that workers cannot efficiently communicate grievances to management out of direct supervisors?

Pass No evidence shows that workers cannot efficiently communicate grievances to management out of direct supervisors.

2. Forced Labour

Item No

Requirement Result Comments

7.1 Is there evidence that work is conducted in voluntary basis, with no threat of penalty or sanctions, and the factory do not use forced, bonded or involuntary prison labour?

Pass Based on workers interview and on-site observation, the work was conducted in voluntary basis, with no threat of penalty or sanctions, and the factory do not use forced, bonded or involuntary prison labor.

7.2 Is there evidences that factory do not require workers to lodge deposits or original documents such as work permits/ID papers, cards, training certificates, etc.?

Pass

The factory only kept employees' copy of ID cards,

copy of training certificates.

7.3 Are workers free to quit their jobs within the legal framework and without debts forcing them to continue working for the factory?

Pass The employees were free to quit their jobs within the legal framework.

7.4 The factory doesn't withhold any part of workers salary or benefits in order to force such worker to continue working for the factory?

Pass During review of documents and interview of employees, it was noted that factory doesn't withhold any part of workers salary or benefits in order to force such worker to continue working for the factory

7.5 Are workers allowed to leave the factory compound after work at any time and freely move about during a shift (attend to hygiene etc)? If not, please specify.

Pass Workers were allowed to leave the factory compound after work at any time and freely move about during a shift confirmed by workers interview and on-site observation

Picture(s)

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Nil

Labor policy regarding anti-forced labor Nil

3. Discrimination

Item No

Requirement Result Comments

8.1 Is non-discrimination guarantee in term of employment, promotion, compensation, welfare, dismissal and retirement, etc. within the company based on criteria of race, birth, religion, national or social origins, sex, family responsibilities, marital status, handicap, sexual orientation or political opinions?

Pass Discrimination procedure was available in the factory. During the review of documents and workers interview, it was noted that the factory is not involved in any type of discrimination on criteria of race, birth, religion, national or social origins, sex, family responsibilities, marital status, handicap, sexual orientation or political opinions.

8.2 The factory doesn't insist on blood tests, pregnancy or virginity tests before hiring?

Pass No such practices ( confirmed per documents check and interviews)

8.3 Is there a written anti-discrimination policy? Pass During review of the documents, it was noted that the factory has anti-discrimination policies.

Picture(s)

Nil

Anti-discrimination policy including in the Social policy Nil

4. Disciplinary Practices

Item No

Requirement Result Comments

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9.1 Is mental / physical /sexual coercion forbidden and avoided in the factory? If not, please give details of the situation.

Pass The mental / physical /sexual coercion was forbidden and avoided in the factory.

9.2 Does the factory have documented disciplinary rules that are clearly communicated to all workers?

Pass During review of documents, it was noted that the factory has disciplinary rules that are clearly communicated to all workers according to the collective labor contract and internal regulation for employees.

9.3 Does the company keep a record of fines/disciplinary actions?

Pass During worker’s interview, it was noted that no such fines by the factory.

9.4 Are the complaint and appeal methods defined and proved to be efficient?

Pass Factory has established the employees appeal policy, and the workers could complaint with management directly.

Picture(s)

Nil

Ethical Code of Conduct including disciplinary practices policy Nil

Special Remarks on this section 1. There was no forced, bonded or involuntary prison labor found in the factory. All provisions regarding forced labor, discrimination and disciplinary practices are very clear specified in the Ethical Code of Conduct of the factory. 2.These are in complete conformity with the national and international regulatory requirements 3. Workers were not required to lodge “deposits” or their identity papers with their employer and were free to leave their employer after reasonable notice confirmed by document review and workers interview.

Critical NC Major NC Minor NC Score /10

0 0 0 10/10

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B. Employee’s interview

Interview Nb Dept. Comments*

1 Machining Individual interview & no violation was observed

2 Cutting Individual interview & no violation was observed

3 Cutting Individual interview & no violation was observed

4 Machining Individual interview & no violation was observed

5 Laser Individual interview & no violation was observed

6-7-8 Machining/Cutting/Assembling No negative comments

* Comments: During the interviews, if any data is found that contradicts findings of Audit Part A (such as: fake birth date or fake date of hire), the whole related section in Audit Part A must be scored 0. No details of employees interviews are available in report in order to

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C. Corrective Action Plan Client Icebreaker AI Service No R-us3-1648702

Supplier Double Retail Ltd. Auditor(s) Sevinch Saidova

Factory Pafos SA Date 31-Aug-2016

Industry Homeware & Gardenware Country Greece

Audit Type Initial Audit

Item No

Result Finding/Violation Corrective Action Factory

estimated date for Completion

1.15 Major

Auditor noted that of the second emergency exit door in packing area, leading to the outside area of the facility are blocked.

All emergency exit doors should be unblocked.

28-Sep-2016

1.17 Major Four fire extinguishers were blocked in production area.

Should unblocked all fire extinguishers 28-Sep-2016

1.20 Major There is no emergency exit lighting in the incoming materials warehouse.(new warehouse)

Should provide the emergency exit lighting in the incoming materials warehouse.(new warehouse

28-Sep-2016

1.21 Major Missing evacuation plan in the incoming materials warehouse.(new warehouse)

Should be posted evacuation plan in every workshop

28-Sep-2016

2.18 Minor

The factory did not provide any evidences

to demonstrate that energy use is

monitored and that actions have been

taken to reduce energy use for checked.

Energy use monitored and actions taken to reduce energy use

30-Nov-2016

2.19 Minor

The factory did not provide any evidences

to demonstrate that the factory had

monitored and taken actions to reduce

water use.

Monitor and take actions to reduce water use

30-Nov-2016

Asia Inspection maximum suggested timings for implementation of Corrective Actions are: - 7 Days to submit Action Plan + 30 Days to book a follow-up audit for Critical NCs - Audit date + 30 days for Major NCs - Audit date + 90 days for Minor NCs

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IMPORTANT NOTES THE ABOVE RESULT(S) REFLECT(S) ASIAINSPECTION LIMITED’S FINDINGS AT THE TIME AND PLACE OF AUDIT. WITH REGARD TO THE RANDOM SAMPLE CHARACTER OF THE AUDIT, IT SHOULD BE NOTED THAT ADDITIONAL NONCONFORMITIES MAY EXIST, WHICH WERE NOT FOUND DURING THE AUDIT. THE AUDITOR'S FINDINGS DO NOT RELIEVE THE AUDITEE OF ITS RESPONSIBILITY TO ENSURE THAT THE REQUIREMENTS OF THE STANDARD ARE FULFILLED AND CONSTANTLY ADHERED TO.

Factory Disclaimer

Original signature of the Factory Representative accepting Asia Inspection policy including bribery issues.

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Confirmation of Compliance with AI Code of Conduct

Original signature of the Factory Representative confirming that auditor respected AI Code of Conduct.

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Corrective Action Plan

Original signature of the Factory Representative agreeing with the Audit Findings and Corrective Action Plan defined.

END