SOCIAL AUDIT CORRECTIVE ACTION PLAN (CAP)

Non-Compliance Finding (S) Recommended Corrective Action(S)

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Description Of Non Compliance 1 Legal requirement No notice sent to the inspector of factories According to Section 52(1) of Thepertaining to the weekly rest day work Factories Act, 1948, No adult workerNo compensatory office provided to the shall be required or allowed to work in a worker working on weekly off. factory on the first day of the week

(hereinfafter referred to as the said day),unless -(a) he has or will have a holiday for whole day on one of the three days immediately before or after the saidday, and(b) the manager of the factory has,before the said day or the substitutedday under clause (a) whichever isearlier, -(I) delivered a notice at the office of the Inspector of his intention to require theworker to work on the said day and of the day which is to be substituted, and(ii) Displayed a notice to that effect in the factoryRecommended corrective actionFactory shall ensure to sent the noticeto the inspector of factories

Description Of Non Compliance 3 Legal Requirement

Factory has not provided payroll for the 7 According to Section 13A of thesecurity guards employed through Payment of Wages Act, 1936, everyProtector Security Services P. Limited so employer shall maintain such registerthe compliance to these guards could not and records giving such particulars ofbe verified for minimum wages, overtime persons employed by him, the workhour's payment and benefits performed by them, the deduction made

from their wages, the receipts given by them and such other particulars and in such form as may be prescribedRecommended Corrective actionFactory shall ensure to provide payrollfor the security guards too.

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Description Of Non Compliance 1 Legal Requirement 1Out of 20 Personnel files verified 2 files According to Schedule IB (I) (I) & (iv) Thewere found without valid age proof records Industrial Employment ( Standing

Orders) Central Rules 1946iv) Recordof age, - (a) Every workman shallindicate his exact date of birth to theemployer or the officefr authorised byhim in this behalf, at the time of enteringservice of the estabnlishment. The employer of the officer authorised byhim in this behalf may before the date ofbirth of a workman is entered in his,service card, require him to supply ;-Recommended corrective actionfactory shall ensure to provide the ageproof records for all the workers as required

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Description Of Non Compliance 1 Legal Requirement 1 Chemical container (While petrol) were not According to rule 62 C (1) Tamil Nadulabeled and no MSDS were not available Factoryu Rules 1950. The occupier offor the same in the finishing section every factory carrying on a "hazardous

process" shall arrange to obtain ordevelop information in the form of Material Safety Date Sheet (MSDS) inrespect of every hazardous substanceor m,aterial handled in the manfacture,transportation and stroage in the factory. It shall be accessible uponrequest to a worker for reference.

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Recommended corrective actionFactory shall ensure tom label all thechemicals stored in containers and shalldisplay the appropriate MSDS (MaterialSafety Datasheet) in all the areas of storage and usage.

Description Of Non Compliance 2 Legal Requirement 2Mock fire drill not conducted once in two According to rules 61 (12c) of the Tamilmonths Nadu Factories Rules 1950, fire fighting

drills shall be held as often asnecessary and at least once in everyperiod of two months.Recommended Corrective actionFactory shall ensure to conduct mockfire drill once in 02 months

Legal Requirement 3 According to rule 35 of the Tamil Nadu

Description Of Non Compliance 3 Factories Rules 1950, the waterThe factory has not conducted water test provided for drinking shall be suppliers - for the drinking water provided at the (a) from a public water -supply system,factory for workers or (b) from any other source approved

in writing by the Health Officer:Recommended corrective actionFactory shall ensure to test the drinkingwater for pot ability

Description Of Non Compliance 4 Legal Requirement 4The factory has employed more than 250 According to Section 46 (1) of Theworkers however no canteen facility Factories Act, 1948 The stateprovided for the workers government may m,ake rules requiring

that in any secialised factory whereinmore than two hundred and fiftyworkers are ordinarilly employed, acanteen or canteens shall be providedand maintained by the occupier for the use of the workersRecommended corrective actionFactory shall ensure to provide canteenas per local law

Description Of Non Compliance 5 Legal Requirement

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g Broken needle records maintained for one As per the Client Requirementsection of factory properly but not for the other section. Recommended corrective action

Factory shall ensure to maintain the broken needle records for all sections

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Descritption Of Non Compliance 1 Legal RequirementIt was noted factory is contributing According to Section 6 of The Employee'sProvident Fund on the basic and D.A Provident Fund and Miscellaneous Provisionbifurcation done by the factory itself, which Act, 1952. The contribution which shall beis less than the minimum wages. paid by the employer to the fund shall be

12% of basic wages, dearness allowanceand retaining allowance if anyRecommended corrective actionFactory shall ensure to contriobute the PF deductions according to the minimum wage to be paid for the workers

Descritption Of Non Compliance 2 Legal RequirementThe ESI deduction is not rounded off to According to Rule 51 of The Employeesnext one rupees as per the requirement State Insurance (central) Rules, 1950, The

Government of India Ministry of labour and eimployment vide their notification N.S-38912/1/2003-SS 1dated 26.08.04 has amended Rule 51of the ESI (central) Rules.1950 relatingto rounding of contribution to nexthigher rupee. The factory shall followthe same.Recommended corrective actionFactory shall ensure to deduct ESIcontribution as per local law.

Descriptiopn Of Non Compliance 3 Legal RequirmentThe factory has not contributed ESI for the As per Section 2 (22) of the Employeesovertime payment and attendance bonus State Insurance Act 1948, "Wagesprovided to the workers "means all remuneration paid or

payable in cash to an employee, if the terms of the contract of employment express or implied were fulfilled and includes any payment to an employeein respect of any period of authorizedleave, lock-out, strike, which is notillegal or layout, and other additional

remuneration, if any, paid at intervalsnot exceeding two months, but does not include--a) any contribution paid by the employerto any pension fund or provident fund orunder this Actb) any travelling allowance or the valueof any travelling concessionc) any sum paid to the person employedto defray special expenses entailed on himby the nature of his employment orAny gratuity payable on dischargeRecommended corrective actionThe factory shall ensure to provide ESIdeduction for the overtime payment and bonus also

Descriptiopn Of Non Compliance 3 Legal RequirmentAccording to Section 12 of the Minimum

The factory has paid less than minimumrate of wages prescribed by local law to every employee engaged in scheduledcurrently for 33 workers. employment under him wages, at a rate not

less than the minimum rate of wages fixed by such notification for that class of employees in that employment without any deduction except as may be authorized within such time and subject to such conditions as may be prescribed. According to the Minimum Wages Notification for Employment in Tailoring Industry G.O (2D) No.74, Labour and Employment, dated 10/12/2004 Notification No. II (2) / LE/98/2005, Published in T.N. Government Gazette, Part II, Section 2, dated 02/02/2005 at pages 58 59n Revised DA payable for the periodfor the period from 01/04/2008 to 31/03/2009 shall be Rs532 per month. This calculates INR 93.65 per day and INR 2435 per month as per Zone-B for Helpers Category )

Recommended corrective actionFactory shall ensure to provide minimum rate of wages to the workers as per requirment

Ho

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Descriptiopn Of Non Compliance 1 Legal Requirment

No compensatory off provided for the weekly According to Section 52 (1) of The Factories Act, rest day within 03 days for workers as well

Wages Act, 1948, The employer shall pay

1948, No adult woker shall be required or allowed

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rk as security guards to work in a factory on the first day of the week

(hereinafter referred to as the said day ) unless -(a ) he has or will have a holiday for whole day on one of the three days immediately before or after the said day, and (b) the manger of the factory has before the said day or the substituted day under clause (a) whichever is earlier -(I) delivered a notice at the office of the Inspector of his intention to reuire the worker to work on the said day and or the day which is to be substituted, and (ii) Displayed a notice to that effect in the factory

Recommended corrective actionFactory shall ensure to provide alternate day off for the weekly rest day work

Descriptiopn Of Non Compliance 2 Legal Requirment 2Overtime hours exceeding the legal limit for According to Section 64 (4) of The Factories Act, workers as well as security guards

State Government shall not exceed, except in respect of exemption under clause (a) of sub-section (2) the following limits of work inclusive of overtime - (I) the total number of hours of work in any day shall not exceed ten (ii ) the spread over, inclusive of intervals for rest, shall not exceed twelve hours in any one day. (iii) the total numbers of hours in a week including overtime shall not exceed sixty (iv ) the total numbers of hours of overtime shall not exceed fifty for any one quarterRecommended corrective actionFactory shall ensure to restrict the overtime hours within the legal limit

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Descriptiopn Of Non Compliance 3 Legal Requirment 3As per the Section 24 and 25 of the water (prevention

NOC for Air and Water expired on. and Control of Pollution ) Act 1974 - The applicant September 19.2007, but no renewal shall make an application along with prescribed fee forobtained so for grant of fresh consent at least 120 days before the date

of expiry of this consent As per the Section 21 of the Air (Prevention & Control of Pollution) Act 1981.-The applicant shall make an application along with prescribed fee for grant of fresh consent at least 120

1948, in making rules under this section, the

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days befor the date of expiry of this consentRecommended corrective actionFactory shall ensure obtain the NOC from the consent department

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Descriptiopn Of Non Compliance 1 Legal Requirment 1

Factory has doing sub - contracting work for As per the client requirementwashing and embroidery. For this no approval from the Client. Recommended corrective action

Factory shall ensure to obtain approval from the client before doing sub contracting

Recommended Corrective Action(S) Factory Proposed Action Step(S) Compliance Target Date(S)

According to Section 52(1) of TheFactories Act, 1948, No adult workershall be required or allowed to work in a factory on the first day of the week(hereinfafter referred to as the said day),

(a) he has or will have a holiday for whole day on one of the three days immediately before or after the said

(b) the manager of the factory has,before the said day or the substitutedday under clause (a) whichever is

(I) delivered a notice at the office of the Inspector of his intention to require theworker to work on the said day and of the day which is to be substituted, and(ii) Displayed a notice to that effect in

Recommended corrective actionFactory shall ensure to sent the notice

According to Section 13A of thePayment of Wages Act, 1936, everyemployer shall maintain such registerand records giving such particulars ofpersons employed by him, the workperformed by them, the deduction madefrom their wages, the receipts given by them and such other particulars and in

Recommended Corrective actionFactory shall ensure to provide payroll

According to Schedule IB (I) (I) & (iv) TheIndustrial Employment ( Standing Orders) Central Rules 1946iv) Recordof age, - (a) Every workman shallindicate his exact date of birth to theemployer or the officefr authorised byhim in this behalf, at the time of enteringservice of the estabnlishment. The employer of the officer authorised byhim in this behalf may before the date ofbirth of a workman is entered in his,service card, require him to supply ;-Recommended corrective actionfactory shall ensure to provide the ageproof records for all the workers as required

According to rule 62 C (1) Tamil NaduFactoryu Rules 1950. The occupier ofevery factory carrying on a "hazardousprocess" shall arrange to obtain ordevelop information in the form of Material Safety Date Sheet (MSDS) inrespect of every hazardous substanceor m,aterial handled in the manfacture,transportation and stroage in the factory. It shall be accessible uponrequest to a worker for reference.

Recommended corrective actionFactory shall ensure tom label all thechemicals stored in containers and shalldisplay the appropriate MSDS (MaterialSafety Datasheet) in all the areas of

According to rules 61 (12c) of the TamilNadu Factories Rules 1950, fire fighting

necessary and at least once in every

Recommended Corrective actionFactory shall ensure to conduct mock

According to rule 35 of the Tamil Nadu

provided for drinking shall be suppliers - (a) from a public water -supply system,or (b) from any other source approved

Recommended corrective actionFactory shall ensure to test the drinking

According to Section 46 (1) of The

government may m,ake rules requiringthat in any secialised factory wherein

workers are ordinarilly employed, acanteen or canteens shall be providedand maintained by the occupier for the

Recommended corrective actionFactory shall ensure to provide canteen

Recommended corrective actionFactory shall ensure to maintain the broken

According to Section 6 of The Employee'sProvident Fund and Miscellaneous ProvisionAct, 1952. The contribution which shall bepaid by the employer to the fund shall be12% of basic wages, dearness allowance

Recommended corrective actionFactory shall ensure to contriobute the PF deductions according to the minimum

According to Rule 51 of The EmployeesState Insurance (central) Rules, 1950, The Government of India Ministry of labour and eimployment vide their notification

dated 26.08.04 has amended Rule 51of the ESI (central) Rules.1950 relatingto rounding of contribution to nexthigher rupee. The factory shall follow

Recommended corrective actionFactory shall ensure to deduct ESI

As per Section 2 (22) of the EmployeesState Insurance Act 1948, "Wages

payable in cash to an employee, if the terms of the contract of employment express

includes any payment to an employeein respect of any period of authorizedleave, lock-out, strike, which is notillegal or layout, and other additional

remuneration, if any, paid at intervalsnot exceeding two months, but does not

a) any contribution paid by the employerto any pension fund or provident fund or

b) any travelling allowance or the value

c) any sum paid to the person employedto defray special expenses entailed on himby the nature of his employment orAny gratuity payable on dischargeRecommended corrective actionThe factory shall ensure to provide ESIdeduction for the overtime payment and

According to Section 12 of the Minimum

to every employee engaged in scheduledemployment under him wages, at a rate notless than the minimum rate of wages fixed by such notification for that class of employees in that employment without any deduction except as may be authorized within such time and subject to such conditions as may be prescribed. According to the Minimum Wages Notification for Employment in Tailoring Industry G.O (2D) No.74, Labour and Employment, dated 10/12/2004 Notification No. II (2) / LE/98/2005, Published in T.N. Government Gazette, Part II, Section 2, dated 02/02/2005 at pages 58 59n Revised DA payable for the periodfor the period from 01/04/2008 to 31/03/2009 shall be Rs532 per month. This calculates INR 93.65 per day and INR 2435 per month as per Zone-B for Helpers Category )

Recommended corrective actionFactory shall ensure to provide minimum rate of wages to the workers as per requirment

According to Section 52 (1) of The Factories Act,

The employer shall pay

, No adult woker shall be required or allowed

to work in a factory on the first day of the week (hereinafter referred to as the said day ) unless -(a ) he has or will have a holiday for whole day on one of the three days immediately before or after

(b) the manger of the factory has before the said day or the substituted day under clause

(I) delivered a notice at the office of the Inspector of his intention to reuire the worker to work on the said day and or the day which is to be substituted, and (ii) Displayed a notice to that

Recommended corrective actionFactory shall ensure to provide alternate day off

According to Section 64 (4) of The Factories Act,

State Government shall not exceed, except in respect of exemption under clause (a) of sub-section (2) the following limits of work

(I) the total number of hours of work in any day shall not exceed ten (ii ) the spread over, inclusive of intervals for rest, shall not exceed twelve hours in any one day. (iii) the total numbers of hours in a week including overtime shall not exceed sixty (iv ) the total numbers of hours of overtime shall not exceed fifty for any

Recommended corrective actionFactory shall ensure to restrict the overtime

As per the Section 24 and 25 of the water (prevention and Control of Pollution ) Act 1974 - The applicant shall make an application along with prescribed fee forgrant of fresh consent at least 120 days before the date of expiry of this consent As per the Section 21 of the Air (Prevention & Control of Pollution) Act 1981.-The applicant shall make an application along with prescribed fee for grant of fresh consent at least 120

, in making rules under this section, the

days befor the date of expiry of this consentRecommended corrective actionFactory shall ensure obtain the NOC from the consent

Recommended corrective actionFactory shall ensure to obtain approval from the client

Preliminary Remediation Reasons and Action Plans ( RRAP )

Remedial StepsClause No Audit Findings (to be Completed by factory)

1.1 Employee back roud checked but no policy in place. The back round check conducted only for the packing section workers only

1.4 Resignation policy in place but this is not copletely provided information regarding security

1.5 Resignation policy in place but this is not completely provided information regarding security

2.7 E,F & H System of security arrangement No CCTV / No security alaram

2.9 No Security alaram

2.1 No electronic motion detector

2.13 No electronic system in place

2.14 No recorded secuirty tapes available

3.5 No procedure in place to handle the extended absences

3.6 No procedure in place to handle the extended absences

3.16 No written procedure to isolate the area to screen incoming packages and mails

4.1 Factory has policy and procedures but this is not covered certain requirments like termination procedures, incoming package checking procedure etc

4.4 The procedure not available for unmanifested or unapproved parts or components or raw materials

4.5 No written procedure but the goods movements are controlled on incoming and out going But records are maintained

4.6 No written procedure in place. And Finieshed products found stored along with other un finished goods.

4.7 No written procedure but the containers and trailers incoming or outgoings are controlled and monitored

4.14 No written procedure in place for container timely

movement

4.16 Procedure in place but not reviewed annually

4.18 Sub contracting facilities were not provided with adequate supervision for security no records available

4.19 No random documented security assessment on regular basis

4.22 No corrective action procedure maintained as no assessment done on regular basis

5.3 Passowords not change periodically

6.1 No formal training procedure in this regard however factory was trained for CT PAT once in the previous year

6.2 The training program could not be verified as the record does not have the modules or procedural security.

6.3 The security training is not effective so that worker understand fully about the requirment and importance

6.4 Internal conspiracies were not part of the training program

6.5 No documents or records of training which shows tranining covers the objective of cargo or packed product security

6.6 Container security procedure is in place but not training records available

6.7 No records showing training for unauthorized access

6.8 Incidengt reporting was not part of the security procedure

6.9 Proper training records were not maintained to verify this requirement

6.1 No formal training records for information system security principle

6.11 No mandatory training prescribed in the factory

6.12 No procedure in place to increase security based on the employees report

6.13 No specific periodic security meeting for the employees in place

Remedial Steps Date(to be Completed by factory) completed

Preliminary Corrective Action Plan (CAP)

Clause no Audit FindingsCorrective Action Plan

(to be completed by factory )

1.1.1 The factory has organization FACTORY ORGANISATION WITH chart with different level but this DEFINED RESPONSIBILITY FOR EACHis not complete. For example the INDIVIDUAL STAFF PREPARED ANDsecurity in charge is not covered ENCLOSED HEREWITH AS ANNEXURE 1in this chart. Responsibility is not defined for individuals staff

1.2.1 Supplier list is available but no PROCEDURE FOR APPROVAL AND procedure for approval and monitoring MONITORING SUPPLIER EVALUATION program ALREADY EXISTS COPY ATTACHED

HEREWITH1.2.2 No procedure in place for supplier SAME AS ABOVE

approval

1.4.1 No recall procedure in place PRODUCT RECALL PROCEDUREFORMULATED NOW

1.4.2 No incident reporting and customer INCIDENT REPORTING AND CUSTOMERnotification procedure in place NOTIFICATION PROCEDURE

FORMULATED NOW1.5.1 No customer complaint and investigation CUSTOMER COMPLAINT AND

system in place INVESTIGATION PROCEDUREFORMULATED NOW

1.5.2 No customer complaint in place and no SAME AS ABOVE records

1.6.1 No operation procedure in place for all WORK INSTRUCTIONS AND PROCEDURE the activities so not assessed and IS ALREADY IN PLACE, COPY ENCLOSED investigated for non-conformity against procedure

1.6.2 No assessment and no root cause ASSESSMENT AND ROOT CAUSEanalyasis for NCs ANALYSIS OF NON CONFORMITIES ARE

DONE THRU FOLLOWING WORK INSTRUCTIONS

1.7.1 No formal training procedure for workers TRAINING POLICY EXISTS and or contract actors and monitoring PROCEDURE FORMULATED NOW COPY

ENCLOSED1.7.2 No training records available TRAINING RECORDS ARE FORMATTED

AND OBSERVED NOW1.8.1 No formal procedure and instruction PROCEDURE AND INSTRUCTION FOR

available for product safety, legality and PRODUCT SAFETY, LEGALITY AND quality QUALITY FORMULATED NOW

1.8.2 No formal documents in place for DOCUMENTS ARE IN PLACE FOR ALLdifferent activities ACTVITIES ARE IN PLACE AS PER

WORK INSTRUCTIONS1.9.1 Document related to safety legality of RECORDS ARE FORMATTED

the relevant were not available AND OBSERVED NOW

1.9.2 No formal document control in place FORMAL DOCUMENT CONTROL IS IN PLACE NOW

1.9.3 No documents related to legality safety RECORDS ARE FORMATTEDand quality maintained and handling AND OBSERVED NOWprocedure in place

1.9.4 Documents are not controlled so version DOCUMENTS ARE NOW CONTROLLED not established AND VERSION ESTABLISHED

1.10.1 Quality records maintained but no time QUALITY RECORDS MAINTAINED WITHsepcific as per customers TIME SPECIFIC AS PER CUSTOMERS

NOW2.4.2 Maintenance program is not formal and MAINTENANACE PROGRAM IS NOW

adequate MDE FORMAL AND ADEQUATE

2.6.1 Workers were found wearing jewelery WEARING OF JEWELLRY IS A CUSTOMand watches in all the sections FOR INDIAN WOMANHOOD. MEASURES

TAKEN NOW TO RESTRICT AT PACKING AREA2.7.1 No pest control procedure in place PEST CONTROL PROCEDURE

currently FORMULATED NOW

2.7.3 No pest control activities in place so BEING NEW FACTORY BUILDING NO this is not verifiable PEST CONTROL TOOK PLACE. BUT NOW

COMMENCED SAID ACTIVITY2.8.1 No glass control in place GLASS CONTROL PROCEDURE

FORMULATED NOW2.8.2 No glass control for glass window SAME AS ABOVE

breakages

2.8.3 No glass control policy and procedure SAME AS ABOVEso no records available

2.9.1 MSDS was not provided for the stain MSDS NOW FORMULATEDremover white petrol

2.9.2 No persons authorization for chemical PERSONS ARE IDENTIFIED AND handling AUTHORISED NOW FOR HANDLING

2.9.3 The chemical is not segregated and stored at stain removing section

3.1.1 Factory has not conducted hazard analysis system

3.1.2 No hazard analysis system in place for foreign materials

3.3.1 Factory does not have procedure for testing and analysis. Factory follows client instruction for the testing and inspections

3.4.1 No procedure in place for prevents contamination of raw materials

3.4.2 Materials and products were not stored at designated place

3.5.3 Metal detector is not installed

3.5.4 No metal detector so no operating proceddure available

3.5.5 No metal detector so no operating procedure and records available

3.5.6 No metal detector is installed so no procedure to do in case of failure

3.7.1 No procedure in place for segregation investigation and disposition of raw materials

3.7.2 No procedure for NC product control and no documentation in place

3.7.4 NC products are not handles as per requirment

4.1.1 Factory has not identified the parameters affecting the safety quality and legality

4.1.2 No flow diagram or check list in place

4.2.2 Incoming inspection is carried out but not formally with any systematic manner with specified procedure

4.2.3 No formal accept or reject criteria is defined for raw material procedure

4.2.4 No insepection schedule or sampling plan

in place

4.3.2 No procedure in place for settings of critical machines

4.3.3 No procedure for random sampling in use

4.3.5 No formal documented inspection procedure No proper sample pla in place

4.3.6 No inspection criteria available in the factory based on customer requirment

4.3.7 No formal inspection schedule and sampling plan

4.4.1 Pre final inspection is carried out but nopt as per the customer requirment

4.7.1 Weighing machine is callbrated but measuring tape and fusing machines were not callbrated

4.7.2 Weighing machine is callbrated but measuringtape and fusing machines were not callbrated

4.7.3 Weighing machine is callbrated but measuring tape and fusing machines were not callbrated

4.7.4 Only weighing machine is callbrated

4.7.5 No records for callbration of measuring tape and fusing machine

Date Completed

23.6.2008

23.6.2008

23.6.2008

25.6.2008

25.6.2008

25.6.2008

25.6.2008

25.6.2008

25.6.2008

TAKEN NOW TO RESTRICT AT PACKING AREA

PEST CONTROL TOOK PLACE. BUT NOW