Social Audit Corrective Action Plan Cap

SOCIAL AUDIT CORRECTIVE ACTION PLAN (CAP)

Recommended Corrective Action(S)

Monitoring & Documentation

Non-Compliance Finding (S)

Description Of Non Compliance 1 No notice sent to the inspector of factories pertaining to the weekly rest day work No compensatory office provided to the worker working on weekly off.

Legal requirement According to Section 52(1) of The Factories Act, 1948, No adult worker shall be required or allowed to work in a 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 said day, and (b) the manager 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 require the worker 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 factory Recommended corrective action Factory shall ensure to sent the notice to the inspector of factories

Description Of Non Compliance 3

Legal Requirement

Child Labour

Factory has not provided payroll for the 7 security guards employed through Protector Security Services P. Limited so the compliance to these guards could not be verified for minimum wages, overtime hour's payment and benefits

Description Of Non Compliance 1 Legal Requirement 1 Out of 20 Personnel files verified 2 files According to Schedule IB (I) (I) & (iv) The were found without valid age proof records Industrial Employment ( Standing Orders) Central Rules 1946iv) Record of age, - (a) Every workman shall indicate his exact date of birth to the employer or the officefr authorised by him in this behalf, at the time of entering service of the estabnlishment. The employer of the officer authorised by him in this behalf may before the date of birth of a workman is entered in his, service card, require him to supply ;Recommended corrective action factory shall ensure to provide the age proof records for all the workers as required

Description Of Non Compliance 1 Chemical container (While petrol) were not labeled and no MSDS were not available for the same in the finishing section

Safety

According to Section 13A of the Payment of Wages Act, 1936, every employer shall maintain such register and records giving such particulars of persons employed by him, the work 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 prescribed Recommended Corrective action Factory shall ensure to provide payroll for the security guards too.

Legal Requirement 1 According to rule 62 C (1) Tamil Nadu Factoryu Rules 1950. The occupier of every factory carrying on a "hazardous process" shall arrange to obtain or develop information in the form of Material Safety Date Sheet (MSDS) in respect of every hazardous substance or m,aterial handled in the manfacture, transportation and stroage in the factory. It shall be accessible upon request to a worker for reference.

Health & Safety

Recommended corrective action Factory shall ensure tom label all the chemicals stored in containers and shall display the appropriate MSDS (Material Safety Datasheet) in all the areas of storage and usage. Description Of Non Compliance 2 Mock fire drill not conducted once in two months

& Safety (Domitories / Housing

Description Of Non Compliance 3 The factory has not conducted water test for the drinking water provided at the factory for workers

Legal Requirement 2 According to rules 61 (12c) of the Tamil Nadu Factories Rules 1950, fire fighting drills shall be held as often as necessary and at least once in every period of two months. Recommended Corrective action Factory shall ensure to conduct mock fire drill once in 02 months Legal Requirement 3 According to rule 35 of the Tamil Nadu Factories Rules 1950, the water provided for drinking shall be suppliers (a) from a public water -supply system, or (b) from any other source approved in writing by the Health Officer: Recommended corrective action Factory shall ensure to test the drinking water for pot ability

Description Of Non Compliance 4 The factory has employed more than 250 workers however no canteen facility provided for the workers

Legal Requirement 4 According to Section 46 (1) of The Factories Act, 1948 The state government may m,ake rules requiring that in any secialised factory wherein more than two hundred and fifty workers are ordinarilly employed, a canteen or canteens shall be provided and maintained by the occupier for the use of the workers Recommended corrective action Factory shall ensure to provide canteen as per local law

Description Of Non Compliance 5 Broken needle records maintained for one section of factory properly but not for the other section.

Legal Requirement As per the Client Requirement Recommended corrective action Factory shall ensure to maintain the broken needle records for all sections

Health & Safety (Domitories / Housing Compensation & Benefits

Descritption Of Non Compliance 1 It was noted factory is contributing Provident Fund on the basic and D.A bifurcation done by the factory itself, which is less than the minimum wages.

Legal Requirement According to Section 6 of The Employee's Provident Fund and Miscellaneous Provision Act, 1952. The contribution which shall be paid by the employer to the fund shall be 12% of basic wages, dearness allowance and retaining allowance if any Recommended corrective action Factory shall ensure to contriobute the PF deductions according to the minimum wage to be paid for the workers

Descritption Of Non Compliance 2 The ESI deduction is not rounded off to next one rupees as per the requirement

Legal Requirement According to Rule 51 of The Employees State Insurance (central) Rules, 1950, The Government of India Ministry of labour and eimployment vide their notification N.S-38912/1/2003-SS 1 dated 26.08.04 has amended Rule 51 of the ESI (central) Rules.1950 relating to rounding of contribution to next higher rupee. The factory shall follow the same. Recommended corrective action Factory shall ensure to deduct ESI contribution as per local law.

Descriptiopn Of Non Compliance 3 The factory has not contributed ESI for the overtime payment and attendance bonus provided to the workers

Legal Requirment As per Section 2 (22) of the Employees State Insurance Act 1948, "Wages "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 employee in respect of any period of authorized leave, lock-out, strike, which is not illegal or layout, and other additional

remuneration, if any, paid at intervals not exceeding two months, but does not include-a) any contribution paid by the employer to any pension fund or provident fund or under this Act b) any travelling allowance or the value of any travelling concession c) any sum paid to the person employed to defray special expenses entailed on him by the nature of his employment or Any gratuity payable on discharge Recommended corrective action The factory shall ensure to provide ESI deduction for the overtime payment and bonus also Descriptiopn Of Non Compliance 3 The factory has paid less than minimum rate of wages prescribed by local law currently for 33 workers.

Legal Requirment According to Section 12 of the Minimum Wages Act, 1948, The employer shall pay to every employee engaged in scheduled 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 period for 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 action Factory shall ensure to provide minimum rate of wages to the workers as per requirment

Descriptiopn Of Non Compliance 1

Legal Requirment

ork

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 1948, No adult woker shall be required or allowed

Hours of Work

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 action Factory shall ensure to provide alternate day off for the weekly rest day work

Descriptiopn Of Non Compliance 2 Legal Requirment 2 Overtime hours exceeding the legal limit for According to Section 64 (4) of The Factories Act, workers as well as security guards 1948, in making rules under this section, the 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 quarter Recommended corrective action Factory shall ensure to restrict the overtime hours within the legal limit

Descriptiopn Of Non Compliance 3

Environmental:

NOC for Air and Water expired on. September 19.2007, but no renewal obtained so for

Legal Requirment 3 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 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

Environmental: Sub-Contracting & Homework

days befor the date of expiry of this consent Recommended corrective action Factory shall ensure obtain the NOC from the consent department

Descriptiopn Of Non Compliance 1

Legal Requirment 1

Factory has doing sub - contracting work for As per the client requirement washing 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

nded Corrective Action(S)

52(1) of The No adult worker llowed to work in a y of the week to as the said day),

e a holiday for he three days r after the said

e factory has, r the substituted whichever is

at the office of the ion to require the e said day and of e substituted, and e to that effect in

ective action to sent the notice

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

n 13A of the Act, 1936, every ain such register ch particulars of him, the work he deduction made receipts given by particulars and in

rective action to provide payroll

e IB (I) (I) & (iv) The nt ( Standing s 1946iv) Record

e of birth to the efr authorised by he time of entering ishment. The er authorised by y before the date of entered in his, him to supply ;ective action o provide the age he workers as required

C (1) Tamil Nadu The occupier of g on a "hazardous e to obtain or n the form of Sheet (MSDS) in ardous substance n the manfacture,

cessible upon or reference.

ective action tom label all the ontainers and shall te MSDS (Material all the areas of

1 (12c) of the Tamil s 1950, fire fighting

st once in every

rective action to conduct mock

of the Tamil Nadu

shall be suppliers er -supply system, source approved

ective action to test the drinking

46 (1) of The

ke rules requiring factory wherein

y employed, a shall be provided e occupier for the

ective action to provide canteen

ective action to maintain the broken

6 of The Employee's Miscellaneous Provision bution which shall be to the fund shall be dearness allowance

ective action to contriobute the ding to the minimum

1 of The Employees tral) Rules, 1950, The Ministry of labour and ir notification

mended Rule 51 ules.1950 relating ution to next ctory shall follow

ective action to deduct ESI

of the Employees 1948, "Wages

employee, if the of employment express

t to an employee od of authorized , which is not other additional

paid at intervals onths, but does not

aid by the employer or provident fund or

wance or the value

e person employed enses entailed on him mployment or on discharge ective action ure to provide ESI rtime payment and

n 12 of the Minimum he employer shall pay ngaged in scheduled m wages, at a rate not m rate of wages fixed by hat class of employees in out any deduction except d within such time and tions as may be ng to the Minimum Wages yment in Tailoring Industry our and Employment, tification No. II (2) / ed in T.N. Government on 2, dated 02/02/2005 at ed DA payable for the period 1/04/2008 to 31/03/2009 onth. This calculates nd INR 2435 per month as rs Category )

ective action to provide minimum rate of as per requirment

n 52 (1) of The Factories Act, shall be required or allowed

n the first day of the week o as the said day ) unless e a holiday for whole day on immediately before or after

factory has before the said d day under clause

at the office of the Inspector re the worker to work on the ay which is to be Displayed a notice to that

ective action to provide alternate day off

n 64 (4) of The Factories Act, under this section, the all not exceed, except in n under clause (a) of ollowing limits of work

of hours of work in any day (ii ) the spread over, or rest, shall not exceed ne day. (iii) the total a week including overtime (iv ) the total numbers of all not exceed fifty for any

ective action to restrict the overtime

4 and 25 of the water (prevention ion ) Act 1974 - The applicant ation along with prescribed fee for t at least 120 days before the date ent As per the Section 21 of the ntrol of Pollution) Act 1981.-The an application along with nt of fresh consent at least 120

of expiry of this consent ective action obtain the NOC from the consent

ective action to obtain approval from the client

Preliminary Remediation Reasons and Action Plans ( RRAP )

Clause No

Audit Findings

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

Remedial Steps (to be Completed by factory)

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

pleted by factory)

Date completed

Preliminary Corrective Action Plan (CAP)

Clause no

Audit Findings

Corrective Action Plan (to be completed by factory )

1.1.1

The factory has organization chart with different level but this is not complete. For example the security in charge is not covered in this chart. Responsibility is not defined for individuals staff

FACTORY ORGANISATION WITH DEFINED RESPONSIBILITY FOR EACH INDIVIDUAL STAFF PREPARED AND ENCLOSED HEREWITH AS ANNEXURE 1

1.2.1

Supplier list is available but no procedure for approval and monitoring program

1.2.2

No procedure in place for supplier approval

PROCEDURE FOR APPROVAL AND MONITORING SUPPLIER EVALUATION ALREADY EXISTS COPY ATTACHED HEREWITH SAME AS ABOVE

1.4.1

No recall procedure in place

1.4.2

No incident reporting and customer notification procedure in place

1.5.1

No customer complaint and investigation system in place

1.5.2

No customer complaint in place and no records

1.6.1

No operation procedure in place for all the activities so not assessed and investigated for non-conformity against procedure

WORK INSTRUCTIONS AND PROCEDURE IS ALREADY IN PLACE, COPY ENCLOSED

1.6.2

No assessment and no root cause analyasis for NCs

ASSESSMENT AND ROOT CAUSE ANALYSIS OF NON CONFORMITIES ARE

1.7.1

No formal training procedure for workers and or contract actors and monitoring

1.7.2

No training records available

1.8.1

No formal procedure and instruction available for product safety, legality and quality

PRODUCT RECALL PROCEDURE FORMULATED NOW INCIDENT REPORTING AND CUSTOMER NOTIFICATION PROCEDURE FORMULATED NOW CUSTOMER COMPLAINT AND INVESTIGATION PROCEDURE FORMULATED NOW SAME AS ABOVE

DONE THRU FOLLOWING WORK INSTRUCTIONS

TRAINING POLICY EXISTS PROCEDURE FORMULATED NOW COPY ENCLOSED TRAINING RECORDS ARE FORMATTED AND OBSERVED NOW PROCEDURE AND INSTRUCTION FOR PRODUCT SAFETY, LEGALITY AND QUALITY FORMULATED NOW

1.8.2

No formal documents in place for different activities

DOCUMENTS ARE IN PLACE FOR ALL ACTVITIES ARE IN PLACE AS PER WORK INSTRUCTIONS RECORDS ARE FORMATTED AND OBSERVED NOW

1.9.1

Document related to safety legality of the relevant were not available

1.9.2

No formal document control in place

1.9.3

No documents related to legality safety and quality maintained and handling procedure in place

1.9.4

Documents are not controlled so version not established

DOCUMENTS ARE NOW CONTROLLED AND VERSION ESTABLISHED

1.10.1

Quality records maintained but no time sepcific as per customers

2.4.2

Maintenance program is not formal and adequate

QUALITY RECORDS MAINTAINED WITH TIME SPECIFIC AS PER CUSTOMERS NOW MAINTENANACE PROGRAM IS NOW MDE FORMAL AND ADEQUATE

2.6.1

Workers were found wearing jewelery and watches in all the sections

WEARING OF JEWELLRY IS A CUSTOM FOR INDIAN WOMANHOOD. MEASURES

2.7.1

No pest control procedure in place currently

PEST CONTROL PROCEDURE FORMULATED NOW

2.7.3

No pest control activities in place so this is not verifiable

2.8.1

No glass control in place

2.8.2

No glass control for glass window breakages

BEING NEW FACTORY BUILDING NO PEST CONTROL TOOK PLACE. BUT NOW COMMENCED SAID ACTIVITY GLASS CONTROL PROCEDURE FORMULATED NOW SAME AS ABOVE

2.8.3

No glass control policy and procedure so no records available

SAME AS ABOVE

2.9.1

MSDS was not provided for the stain remover white petrol

MSDS NOW FORMULATED

2.9.2

No persons authorization for chemical handling

PERSONS ARE IDENTIFIED AND 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

FORMAL DOCUMENT CONTROL IS IN PLACE NOW RECORDS ARE FORMATTED AND OBSERVED NOW

TAKEN NOW TO RESTRICT AT PACKING AREA

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 measuring tape 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

CKING AREA

. BUT NOW