Global Social Compliance Programme

Reference Environmental Audit Process & Methodology

November 2010 About the GSCP Global Social Compliance Programme

/ GSCP objectives and scope / Users & Usage The Global Social Compliance Programme is a business‐driven These tools are openly available for all to use. Users programme for the continuous improvement of working can include GSCP member and non‐member buying and environmental conditions in global supply chains. companies, suppliers and employment sites. Multi‐ The GSCP was created by and for global buying companies Stakeholder Initiatives and other initiatives, auditing (manufacturers and retailers) wanting to work collaboratively bodies and other scheme owners can and are encouraged on improving the sustainability (social and environmental) of to also use the GSCP Reference tools. their often‐shared supply base. To this end, these companies The Reference tools can voluntarily either be: seek to harmonise existing efforts to deliver a shared, global and sustainable approach. • integrated by users into their respective systems; or The scope of the Programme encompasses: • utilised by users as a reference against which to compare their existing tools through the GSCP • social and labour practices, Equivalence Process1. • site‐specific environmental practices (not product related). / Responsibility The Programme can be applied at all levels of the supply The GSCP does not monitor nor audit in any way the chain. compliance by a user’s supply chain with the GSCP The Programme is neither a monitoring initiative, nor Reference tools or any standards. a substitute to existing systems. The GSCP will not The adoption of part or all of one or more Reference undertake accreditation or certification activities as it tools cannot be put forward as a proof of adequate must remain a non‐aligned, neutral reference framework. due diligence. The responsibility of the implementation of these tools, of the monitoring of the user’s supply / The GSCP Reference tools chain’s compliance and of any due diligence linked to it, resides with the user. Any use of the GSCP name or To drive convergence, the GSCP has developed a set of logo has to follow the terms established by the GSCP. Reference tools and processes that provide a common These terms are available on the GSCP website (www. interpretation, based on best existing practice, of fair gscpnet.com). labour/social and environmental requirements and their implementation in the supply chain.

1. The Equivalence Process is a mechanism by which a social and/or environmental compliance scheme is objectively benchmarked against the requirements defined in one or more GSCP Reference tools, to determine their level of equivalence. Through the Equivalence Process, the GSCP enables the comparison of various standards and schemes against the GSCP Reference tools, aiming at bringing convergence in requirements and approaches and building mutual recognition.

The Consumer Goods Forum

The GSCP is housed by The Consumer Goods Forum, a retailer and manufacturer parity industry body, driven by its members2. It brings together retailers, manufacturers and suppliers to collaborate across the value chain to enrich shopper and consumer value in all markets. It supports processes and practices that optimize the value chain as an interrelated whole, in accordance with all anti-trust laws.

2. For more information, please visit www.theconsumergoodsforum.com

Acknowledgments Thank you to those who contributed to this Reference tool

This Reference tool has been developed by supply chain experts from GSCP member companies, with input from key stakeholders, including other brands and retailers, initiatives and international organisations, auditing and certification bodies and civil society representatives. The GSCP would like to thank all those who have helped with the development and continuous improvement of this Reference tool. Global Social Compliance Programme

Table of contents

//Introduction 02

//1. Risk assessment system 04 1.1 Self-assessment questionnaire 04

//2. Audit request 05 2.1 Launching the audit request 05 2.2 Pre-audit employment site profile 05

//3. Preparation 06 3.1 Background and context review 06 3.2 Audit organisation 06 3.3 Communicating the audit arrangements 08 3.4 Supplier preparation 10

//4. Audit execution 11 4.1 Opening meeting 11 4.2 Employment site tour 12 4.3 Interviews 13 4.4 Document review 14 4.5 Alert notifications 15 4.6 Audit team pre-closing meeting 16 4.7 Closing meeting 19

//5. Audit outputs 19 5.1 Audit report 19 5.2 Supplementary audit information 20 5.3 Information management 20 5.4 Audit follow-up 21

//Glossary of terms 22 //List of appendices: There are seven reference tools available that complement the audit process described above by providing further reference guidelines and templates for carrying out the described process. These are: Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile Appendix 3: GSCP Reference Environmental Audit Checks Appendix 4: GSCP Reference Environmental Alert Notification Appendix 5: GSCP Reference Environmental Audit Report Appendix 6: GSCP Reference Environmental Supplementary Audit Information Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

Global Social Compliance Programme_01 Reference Environmental Audit Process & Methodology - november 2010 introduction ystem about The GSCP Reference tools on Environmental Audit Process

isk Assessment S Assessment R isk & Methodology

Scope & usage:

The reference tools on Environmental Audit Process complement the audit process. They apply to the auditing

Audit R equest Audit and Methodology are part of the GSCP set of reference of sites from all sectors, categories and countries. They are tools designed to provide a common interpretation of applicable to first party, second party and third party audits. environmental requirements and their implementation. The reference tools on Environmental Audit Process and tion tion The reference tools on Environmental Audit Process and Methodology are based on the GSCP Environmental Methodology detail the requirements that should be met Reference Requirements but can be adopted and tailored to by buying companies and auditors to conduct best practice other codes of environmental practice. r a Pre pa environmental audits of an Employment Site’s performance. The reference tools are not a substitute for existing audit The reference tools cover all steps to be taken prior, during process or existing systems. and after an audit and include, where relevant, templates to

Overview of the audit process xecution E xecution Audit The REFERENCE TOOL ON ENVIRONMENTAL AUDIT • by developing a Best Practice manual giving examples of PROCESS is designed to provide best practice guidance for “what good looks like” against each topic, with practical the audit process. After benchmarking existing processes, advice on ways to address common environmental the members of the Expert Working Group on Audit Process compliance issues; & Methodology developed the following process. • by encouraging suppliers to request environmental compliance audits themselves. This can be promoted Audit O ut p uts Audit Involvement of suppliers in the audit process as a way of prompting continuous improvement or of demonstrating their own commitment to environmental compliance. ry a ry Suppliers should be involved as much as possible in the audit process.

Gloss This can be done: • by sharing briefing notes with the supplier explaining the background, process, applicable codes and audit methodology; A pp endices

02_Global Social Compliance Programme introduction

Reference Environmental Audit Process & Methodology - november 2010 R isk Assessment S

Audit process

RISK ASSESSMENT SYSTEM ystem STEPs GSCP REFERENCE TOOLs

Collect risk criteria, for example by evaluating: • Réference Environmental Self-Assessment Questionnaire Audit R equest • Country of employment site (Appendix 1) • Industry • Processes • Material use and storage • Sensitivity of local environment/ecosystems • Self-assessment questionnaire (optional) Pre pa r a

REQUEST FOR environmental AUDIT tion STEPs GSCP REFERENCE TOOLs

• Initial communication with employment site • Reference Environmental Pre-Audit Employment Site Audit E xecution • Collection of site information Profile (Appendix 2)

PREPARATION STEPs GSCP REFERENCE TOOLs Audit O ut p uts • Background and content review • No specific tools (une information from Reference • Audit organisation: type, team Environmental Self-Assessment Questionnaire [Appendix 1] • Communication of audit arrangements and Reference Environmental Pre-Audit Employment Site • Supplier preparation Profile [Appendix 2])

AUDIT execution Gloss STEPs GSCP REFERENCE TOOLs a ry

• Opening meeting • Reference Environmental Audit Checks (Appendix 3)

• Site tour • Reference Environmental Alert Notifications (Appendix 4) A pp endices • Management and worker interviews • Document review • Audit team pre-closing meeting • Closing meeting

AUDIT OUTPUTS STEPs GSCP REFERENCE TOOLs

• Audit reporting • Reference Environmental Audit Report (Appendix 5) • Follow-up and verification (if required) • Reference Summary of Environmental Findings and Corrective Actions (Appendix 6)

Global Social Compliance Programme_03 Reference Environmental Audit Process & Methodology - november 2010 introduction ystem 1. Risk Assessment System

A buying company should have in place an efficient process and/or previous audit results. However, it should be noted that isk Assessment S Assessment R isk to measure environmental compliance and identify potential this is not intended to be an exhaustive list. risks in its supply chain. This will enable the company to This information upon which the risk assessment is based focus attention on key areas of potential risk and direct its should be provided by the supplier or employment site either audit resources accordingly. through a self-assessment questionnaire (Appendix 1) or Relevant environmental risk criteria may include: geographical through other existing tools. The risk assessment approach area, sensitivity of local environment/ecosystems, employment should ensure that potential risks are prioritised and are site function, energy use, emissions to air, land and water, appropriate and representative of the employment site and Audit R equest Audit hazardous substances use and storage, waste management, the nature of its activities. pollution prevention, major incident prevention and management, environmental nuisance, licences and permits, tion tion r a Pre pa 1.1 Self-assessment questionnaire

The self-assessment questionnaire is an optional tool and Companies should communicate the following to employment can be used by: sites when requesting this information: • a buying company to risk assess suppliers/employment • reason for the information request; sites (e.g. to provide a basis for the development of an • how the risk assessment fits within the audit process;

xecution E xecution Audit audit programme); • to whom to send the completed self assessment (or how to • a supplier or employment sites as an aid to their own upload the self assessment on to a database); risk reviews and/or preparation for their own self audit programmes; and • timeframe for completion; • an auditor to focus on site investigation on high risk areas. • process and timeframe for updating the self-assessment. A reference self-assessment questionnaire is available in Audit O ut p uts Audit Appendix 1. ry a ry Gloss A pp endices

04_Global Social Compliance Programme introduction

Reference Environmental Audit Process & Methodology - november 2010 R isk Assessment S 2. Audit Request ystem 2.1 Launching the audit request

An audit request may be made by: • any other party with an interest in the commercial relationship Audit R equest and environmental performance of the employment site. • the employment site; For example, industry or monitoring bodies. • the supplier; Any company/organisation requesting an audit is termed an • the buying company; ‘audit requestor’. Pre pa r a 2.2 Pre-audit employment site profile tion When an audit request is made, the auditor may supply • the pre-audit employment site profile should be completed the employment site with a pre-audit employment site and returned to the auditor two weeks from the date of

profile questionnaire. However, the use of the pre-audit the request being made; Audit E xecution employment site profile questionnaire is at the discretion • if an audit is requested and scheduled in less than two of the audit requestor. The pre-audit employment site weeks, the auditor and employment site should work profile questionnaire asks for general information about the together to ensure the pre-audit employment site profile site, for example its: location, size, production processes, is returned as soon as possible, and in any event before the licences and permits, energy use, sources of emissions to audit is carried out. air, land and water, hazardous substances use and storage, waste management, pollution prevention measures, major A pre-audit employment site profile should have four main incident prevention and management and environmental areas: Audit O ut p uts nuisance. This information allows auditors to: 1. supplier overview; • prepare relevant briefing materials (industry or country- 2. employment site overview; specific); 3. employment site details; • plan the assessment, for example in relation to the experience and language capabilities of the audit team 4. a summary of activities routinely undertaken by contractors

members and the required number of auditor days (cf. on-site. Gloss 3.2.2 Audit length); Where the employment site itself is the audit requestor, the • focus the audit on potential high environmental risk areas. auditor should ensure that an agreement is in place with the a ry employment site to allow the auditor to communicate audit The audit company should communicate the following findings and alert notifications to relevant customers. to each employment site to be audited and any relevant A pp endices parties, such as agents, in the supply chain: A reference pre-audit employment site profile is available in Appendix 2. • the importance of accuracy in completing the pre-audit employment site profile; • timeframe for completion of the pre-audit employment site profile; • to whom to send the completed pre-audit employment site profile. Recommended timeframe: • the auditor should supply the pre-audit employment site profile to the employment site within five working days of the audit being confirmed;

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Reference Environmental Audit Process & Methodology - november 2010 introduction ystem

Background and context review review and context Background 3. Preparation

3.1 Background and context review isk Assessment S Assessment R isk

The auditing organisation or auditor must be fully aware of environmental legislation and regulatory requirements that the conditions, challenges and issues prevailing in the country, may apply to the employment site. This should include an Audit organisation Audit organisation region and industry where the audit is to be conducted. understanding of non-mandatory schemes and certifications The auditing organisation and/or the auditor should be such as those for environmental management systems knowledgeable and aware of the issues which could impact (EMSs) to the internationally recognised standards of the environment in the country, region or industry/industrial ISO14001 or EMAS. The auditing organisation or auditor Audit R equest Audit sector concerned. The auditing organisation or auditor should also have knowledge of what constitutes operational should have a detailed awareness of the local and national best practice within the industrial sector in question. tion tion

r a Pre pa 3.2 Audit organisation

3.2.1 Audit type To minimise the event that - due to the lack of special Communicating the audit arrangements the audit arrangements Communicating preparations- necessary information and personnel may not Audits should take place during a period when the employment be available on the day of the visit to complete the audit, site is in operation. the buying company should clearly communicate its policy on unannounced audits to suppliers and employment sites. Audits may be: The policy should state that: xecution E xecution Audit • unannounced (the employment site has no prior warning • audits may occur at any time on an unannounced basis; of the audit);

Supplier preparation Supplier preparation • employment sites may be required to provide self • semi-announced (whereby the employment site is aware assessment information on a regular basis and this that an audit will take place during a given time period, but information must be accurate; the actual date of audit is not communicated); • auditors presenting the correct credentials should be • announced (at a mutually convenient date agreed with allowed full access to the employment site; Audit O ut p uts Audit employment site). • the necessary records should always be kept on the In all cases, the buying company should clearly communicate employment site or be readily available (cf. 3.4 Supplier ry a ry its audit policy and process (including the reference Preparation). standard against which audits are conducted as well as

Gloss the expectations in case of non-compliance detected) to > Semi-announced audits suppliers and employment sites as part of its commercial terms. The buying company’s policy may include provision Buying companies should clearly communicate their policy for all types of audit under certain circumstances. on semi-announced audits to suppliers and employment sites. The policy should include the following points: The risk assessment process can be used to influence the type of audit selected. For example, the audit requestor • the buying company will specify a window during which an A pp endices may decide to execute semi-announced audits in all high audit may take place. Audit windows may range between 2 risk employment sites. However, other considerations such weeks and 2 months; as the relationship with the employment site should be • all employment sites are required to provide up-to- taken into account since semi-announced and unannounced date and accurate pre-audit and, when requested, self audits can negatively impact supply chain relationships. assessment information at the beginning of the window; > Unannounced audits • auditors presenting the correct credentials during the audit window should be allowed full access to the employment Unannounced audits allow auditors to assess the operations site; and activities at the employment site in their ‘normal state’, since the employment site has not had the opportunity to • the necessary records should be kept at the employment make any special preparations. site during the window.

06_Global Social Compliance Programme Background and context review introduction

Reference Environmental Audit Process & Methodology - november 2010 R isk Assessment S

> Announced audits 3.2.2 Audit length Audit organisation The right to perform an announced audit should be a normal part of the commercial relationship. However there is a risk The number of auditor days at the employment site should be based on, for example, the size and complexity of the site

that employment sites may make special preparations for ystem the audit and best practice is to use a mix of announced, and the type of operations with the potential to impact the semi-announced and unannounced audits to mitigate this environment. The length of the audit should allow sufficient risk. Buying companies should clearly communicate their time to undertake a site tour of the complete site, interview policy on announced audits to suppliers and employment a number of workers, including individuals who have direct Audit R equest sites. The policy should include the following points: environmental roles and responsibilities and to undertake Communicating the audit arrangements a review of applicable documentation. The length of the • the buying company will agree an audit date with the audit should be agreed between the audit requestor and the employment site in advance; auditor based on existing knowledge of the site and area and • the employment site is required to provide up-to-date and the information provided in the Self-Assessment and/or Pre- accurate pre-audit and, when requested, self assessment Audit Employment Site Profile questionnaire. Pre pa r a information in advance of the audit; In the case of agricultural businesses, consideration should • auditors presenting the correct credentials on the date of be given to the size and geographical spread of the business the audit should be allowed full access to the employment and the number of growing locations to ascertain person tion site; days required. • the necessary records and the concerned personnel should The following provides an indication of the length of audit Audit E xecution

be available at the employment site on the day of the audit. for different sites: Supplier preparation

Indicative Length Site Description of Audit

Less than a 50 employees, single small geographical area site, low pollution/hazard potential 1-2 person days on site (no hazardous substances handled or emissions to air/land/water), simple manufacturing/ processing operations Audit O ut p uts

50-500 employees, larger single geographical site or more than one site, higher pollution/ 2-3 person days on site hazard potential (e.g. handling hazardous substances, on-site waste treatment activities)

500+employees, large single geographical site or multiple sites, high inherent pollution- hazard 4-6 person days on site potential (e.g. handling highly hazardous substances on site), complex processing operations Gloss

However, the information provided in the table above is • language skills; a ry intended as an indication only. The actual length of audit • ethnic/national background reflecting that of the should be agreed between the audit requestor and the

workforce; A pp endices auditing company. • reputation; 3.2.3 Audit team • integrity; • commitment to improving environmental compliance and The audit should be conducted by a competent environmental performance. auditor, who may be self-employed or be employed by a commercial organisation, NGO or industry body3. Auditors To prevent any conflict of interest, the auditor must not and auditing bodies should be selected based on: have any connection with the employment site. It would be recommended that an audit be performed by two auditors, • audit training and skills; particularly if the site is remote and/or there is the potential • audit experience; for safety/security issues to be associated with the audit. • local and industry knowledge;

3. The GSCP has launched an Expert Working Group that works exclusively on auditor competence. Its role is to identify and gather best practice in that area in order to build reference requirements for recognition of auditors and auditing bodies.

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Reference Environmental Audit Process & Methodology - november 2010 introduction Background and context review review and context Background ystem

3.3 Communicating the audit arrangements

3.3.1 Information for the employment site / procedures (e.g. waste handling and disposal, spill containment etc.); The buying company and/or auditor should communicate / training records; the following information to the employment site at least Audit organisation Audit organisation isk Assessment S Assessment R isk / details of permits, consents and licences (or 2 weeks before the audit. This should be communicated in documented exemptions where applicable) for: writing and in the relevant local language. - water abstraction; • Confirmation of receipt of the Pre-Audit Employment Site - effluent wastewater discharges; Profile and any further information required from the - storm water discharges; employment site. - emissions to air; - chemical and fuel storage; • Identity of the audit requestor. Audit R equest Audit - on-site waste management and storage; and • Information about the audit requestor’s policies towards - off -site waste disposal information including contractor’s environmental compliance and the requirements and code licences; tion tion of conducts against which the employment site is being / hazardous substances list/inventory; audited. / safety data sheets for hazardous substances; • Introduction of the audit team. / emission sources inventories (e.g. emissions to air, land r a Pre pa • The audit agenda including: and water);

Communicating the audit arrangements the audit arrangements Communicating / inspection/service logs and inspection reports for

/ timetable; environmental-critical equipment e.g. abatement / topics to be covered. equipment etc.; • Key personnel invited to participate in the audit, including / spill/incident log and remedial steps taken including but not limited to: correspondence with authorities regarding e.g. spills, / management; leaks, odour, noise etc.; xecution E xecution Audit / environmental emergency procedures;

Supplier preparation Supplier preparation / engineering/maintenance; / environmental; / inventory (or similar) of air emission points; / manufacturing/operations; / air emission monitoring log/results; / purchasing/procurement. / greenhouse gas data (use, release etc.); / energy use data; • Information which the employment site should communicate

Audit O ut p uts Audit to relevant workers before the audit covering the audit / water sources (e.g. from abstraction borehole), uses process, purpose, ground-rules for worker interviews, (e.g. process water, cooling etc.) and consumption data; confidentiality of worker interviews. / employment site drainage plan; ry a ry • List of documents (where applicable) that the employment / wastewater monitoring log/results; site will need to make available to the audit team on the / waste documentation including manifests for off site Gloss day of the audit, including: disposal, waste contractor licences and permits etc.; / management structure (e.g. organogram); / site audits of waste contractors; / environmental committee meeting minutes; / bulk tank inventory (including contents, capacity etc.); / employee handbooks; / bund/secondary containment inventory;

A pp endices / previous environmental reports/Corrective Action Plan / tank/bund inspection logs/reports; Report; / tank/bund integrity testing logs/reports; / employment site layout/floor plan; / asbestos survey reports, asbestos register, management / maps of the surrounding area, if available; plan and inspection reports; / information on nearby protected habitats (e.g. local / ozone depleting substances (ODS) inventory and inspection nature reserves) including distance from site, if available; logs/reports; / information on the site geology and hydrogeology, if / polychlorinated biphenyls (PCBs) inventory and inspection available; logs/reports; / company environmental policies; / ionizing radiation sources registration, disposal records and inspection records; / government/agency Inspection Reports, e.g. environ‐ mental compliance, etc.;

08_Global Social Compliance Programme Background and context review introduction

Reference Environmental Audit Process & Methodology - november 2010 R isk Assessment S

/ intrusive soil and groundwater investigation reports / communications with environmental regulating agencies/ and on-going monitoring requirements; authorities relating to environmental violations and Audit organisation / major incident risk assessments and/or incident reports; pollution incidents (air, water, effluent, wastes, odour and noise). / nuisance/complaints log; ystem / notices of violation or fines from a regulating agency; Communicating the audit arrangements Audit R equest 3.3.2 Sample Audit Agenda

Client Name Audit Date(s) Job No

Employment site name and address Pre pa r a Day 1 – date

Duration Auditor 1 Auditor 2 tion Morning Opening meeting & plant tour

Site tour: Site tour: Audit E xecution • Internal production areas • Internal production areas Supplier preparation • Internal areas including boiler room, • Internal areas including boiler room, compressor house, waste handling compressor house, waste handling areas etc. areas etc. • External areas (e.g. waste storage, • External areas (e.g. waste storage, wastewater treatment plant) wastewater treatment plant) and including site perimeter survey and including site perimeter survey • Worker interviews • Worker interviews Audit O ut p uts

Lunch time Lunch break/Auditors’ meeting

Afternoon One-to-one Interviews: Document review • Environmental manager • Engineering/maintenance manager

and or department personnel Gloss • Manufacturing/operations manager

• Procurement/purchasing personnel a ry • Representatives from contractors on-site A pp endices Clarification/Auditor meeting

Closing meeting/End of the audit

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Reference Environmental Audit Process & Methodology - november 2010 introduction Background and context review review and context Background ystem

3.4 Supplier preparation

Employment site management should ensure that: 3.4.1 Information for workers • all documentation is available on the day of the audit. This includes information and documents that are usually Clear information about the audit should be communicated by the employment site to applicable workers explaining the Audit organisation Audit organisation isk Assessment S Assessment R isk stored at another location (e.g. a central office where environmental data or records are held such as waste purpose of the visit and the process. This information should documentation or monitoring results); be available in the principal languages spoken by workers and should include: • relevant personnel are at the employment site; • purpose and scope of the audit; • supervisors and managers are instructed to allow unobstructed access to auditors. • introduction to the auditors and their role (emphasising they are independent and external); Audit R equest Audit • process including confidentiality of worker interviews (where required); tion tion • contact details for the auditor and for any whistle-blowing facility supported by the audit requestor. Communicating the audit arrangements the audit arrangements Communicating r a Pre pa

Sample communication

On (insert date), representatives from (insert audit The visit will primarily consist of meetings with management, company) will be visiting (insert employment site name) to a facility inspection, and document reviews. assess environmental performance and compliance. The A limited number of worker interviews with identified Supplier preparation Supplier preparation

xecution E xecution Audit representatives will be looking at the following areas: workers who have specific roles and responsibilities • environmental management systems; for managing environmental issues or environmental compliance will also be undertaken. Worker interviews may • energy use and Greenhouse Gas (GHG) emissions; also be undertaken to establish the level of awareness of • water use; environmental issues across the facility and to help identify any issues or good practice on-site. The interviews are strictly • wastewater effluent; confidential and the identity of workers who participate will Audit O ut p uts Audit • emissions to air (including ozone depleting substances (ODS); remain anonymous. • waste management; You may be asked questions by the representatives

ry a ry from (insert audit company) as they walk around (insert • pollution prevention/hazardous and potentially hazardous employment site name). The selection of workers is based substances;

Gloss on a representative sample and you are not required to • major incident management; participate in interviews. • contaminated land/soil and groundwater pollution prevention; If you would like to get in touch with the representatives from (insert audit company) to discuss the audit or any other • land use and biodiversity; issues, please do not hesitate to get in contact using the • nuisance. contact details below: A pp endices (Insert contact details of audit company)

10_Global Social Compliance Programme Opening meeting introduction

Reference Environmental Audit Process & Methodology - november 2010 R isk Assessment S Employment site tour 4. Audit Execution ystem

The audit should include the following: • audit team pre-closing meeting; Interviews • opening meeting; • closing meeting, including summary of findings; Audit R equest • employment site tour (and perimeter survey) – this may • agreement of findings. require visits to separate geographical locations if these Document review This chapter sets out best practice for each step of the audit. are part of the activities operated by the employment site relevant to the products being produced for the buying As a general principle, the conduct of the audit team at all company requesting the audit; times must be in the best interest of the workers. • management and worker interviews; Pre pa r a

• document review; Alert notifications tion 4.1 Opening meeting • establish the audit agenda and indicate the personnel required at each stage of the inspection; The opening meeting must be conducted in the language Audit E xecution • review the information provided in the pre-audit Audit team pre-closing meeting spoken by management. It should be attended by relevant employment site profile (including previous corrective people including: action report and follow-up actions); • environmental Manager (or similar); • provide the employment site management with the list • senior site management; of the documents to be reviewed during the audit [see section 3.3.1 Information for the Employment Site]; • managers responsible for key functions, e.g. Production Manager, Maintenance Manager. • confirm key workers and personnel who have responsibilities Audit O ut p uts for environmental issues and their availability for interview/ This should be formally presented in a format agreed with the participation during the course of the audit; audit requestor to ensure the audit requestor’s perspective is clearly communicated in an appropriate tone. • confirm any special arrangements/precautions required for Closing meeting the employment site tour; In the opening meeting, the audit team should: • confirm permission to take photographs. • introduce the audit team; Gloss Agree process for communicating issues as they arise during • explain the purpose and scope of the audit, including: the audit. It is best practice to communicate issues as they / potential benefits to the employment site (opportunity arise to build consensus around findings and corrective a ry for management to identify and manage risk, opportunity actions and allow management to: to engage in continuous improvement, opportunity to meet customer needs, opportunity to save money • provide additional evidence where necessary; A pp endices through environmental improvement, improved • address issues immediately; compliance with environmental legislation etc.); • confirm the importance of attendance at the closing / clarify that the purpose of an audit is continuous meeting and ensure that all key personnel can attend; improvement; / the standard against which the audit will be conducted • provide an opportunity for questions and to address (the GSCP Environmental Reference Requirements and concerns; customer requirements, applicable local, national and • confirm the process for presenting audit findings tothe international laws, whichever are the more stringent); employment site and confirm how audit findings will be • explain that the minimum expectation on the employment followed-up. site in relation to the audit is transparency; • outline the audit process;

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Reference Environmental Audit Process & Methodology - november 2010 Opening meeting Opening meeting introduction

ystem 4.2 Employment site tour

4.2.1 Process • identify potential sources and impacts to the environment;

Employment site tour tour site Employment • note other physically observable evidence that relate to The purpose of the employment site tour is to enable other areas of the standards; the audit team to observe the current practices in all isk Assessment S Assessment R isk areas of the employment site and to form a view of how • identify and confirm -off site contractors or suppliers that these practices measure up to the GSCP Environmental provide environmental services to the employment site

Interviews Interviews Reference Requirements, applicable legal and regulatory (e.g. waste contractors, maintenance service providers of

requirements and other applicable requirements, e.g. environment-related equipment); customer requirements/policies. The findings from the tour • observe management systems and practices, including the are triangulated with evidence from management and key relationship and interactions between management and personnel interviews and document review. Audit R equest Audit workers. As a general principle, the auditor should be able to visit all Document review review Document The team should raise issues as they arise during the the areas of the employment site and should set the pace employment site tour, giving managers the opportunity tion tion of the tour. However, in some cases, employment sites to seek clarification, respond, and provide explanations or may prohibit visitors from walking unaccompanied through further evidence. employment site production areas or forbid photography for

r a Pre pa reasons of safety or commercial confidentiality. The auditor The auditors should look to identify areas where there should note restrictions on access or photography in the is high potential for pollution or other environmental Alert notifications Alert notifications audit report, and if restrictions seem unreasonable should incidents. The audit should consider routine site operations escalate according to the audit requestor’s policy. and activities, but also non-routine operations and activities, e.g. maintenance, cleaning and operations and activities Auditors should make every effort to ensure production is not undertaken on-site by contractors. disrupted during the employment site tour, whilst ensuring that they are able to view the production area during busy production periods. It should be possible to move around

xecution E xecution Audit 4.2.2 Perimeter survey the site without delaying or halting production. A perimeter survey should be undertaken, where feasible, to The ability for management to continue production at the provide supplementary information about the employment site during a visit is crucial to gaining an accurate idea of site and its local context and to identify specific risk issues to Audit team pre-closing meeting meeting pre-closing Audit team current practices and to securing management co-operation

the environment and/or the surrounding areas. for the remainder of the visit. Further, the safety of the auditor and the persons accompanying them on the site The perimeter survey should focus on:

Audit O ut p uts Audit tour is of paramount importance. Auditors should keep this in mind during the site tour. In order to achieve this, the • the general nature of the surrounding environment (e.g. auditor should for example: rural, industrial, residential neighbourhood, business ry a ry

Closing meeting Closing meeting district, etc.); • ask that they be accompanied by only one or two people; usually the site or environmental manager, or whoever is • the nature of immediate neighbouring facilities (e.g. Gloss best placed to answer questions on environmental issues manufacturing, waste treatment/disposal, etc.); (e.g. facility maintenance or operations representatives); • areas of potential off-site impact to the employment site • be aware of site traffic and stay on dedicated pedestrian (e.g. pollution or contamination associated with- off site routes (wherever possible); bulk storage tanks, off-site waste storage areas, etc.); • areas of potential impact from on-site activities (e.g.

A pp endices • avoid walking where workers are trying to move or transport product from one area to another. distressed vegetation, the nature and quality of external surface areas etc.); The audit team should walk around the employment site, external areas and site perimeter (where feasible), internal • other facilities located on the employment site property production areas, raw material/chemical and waste storage (e.g. waste water treatment plants, electricity substations areas, bulk storage areas, boiler rooms, compressor houses etc.); and other applicable areas with managers in order to: • other production units within the employment site property, • understand the work done at the employment site; which are not part of the scope of the audit. • evaluate environmental practices;

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Reference Environmental Audit Process & Methodology - november 2010 Employment site tour R isk Assessment S

4.3 Interviews

Interviews with managers and a limited number of worker Location: interviews with key workers who have specific roles and ystem

• formal interviews should take place in a quiet, private area Interviews responsibilities for managing environmental issues or away from management offices with no representatives of environmental compliance will be undertaken. Worker management present; interviews may also be undertaken to establish the level

of awareness of environmental issues across the facility • informal interviews may also take place during the physical Audit R equest and to help identify any issues or good practice on-site. tour of the employment site, at lunch time or in breaks; Document review The interviews are strictly confidential and the identity of • where possible, worker interviews should be held in workers who participate will remain anonymous. the interviewee’s language, where this is not possible worker interviews may be conducted through a translator. 4.3.1 Worker interviews Translators must be independent of employment site management and must speak the language concerned. Pre pa r a Points raised by workers should be fed back as early as Protection of workers: Alert notifications possible to members of the team carrying out management interviews or document review to facilitate verification. • auditors should ensure that problems raised by workers are discussed with management in a non-attributable tion Audit team members carrying out worker interviews must way. Auditors must ensure that the comments they report have the skills to make workers feel at ease. It is best practice cannot be traced back to an individual worker; to use interviewing techniques to encourage interviewees to Audit E xecution identify the issues of most importance to them. In any case, • auditors/worker interviewers should leave a contact Audit team pre-closing meeting the interviewer should use appropriate body language (e.g. telephone number, preferably their mobile number avoid sitting behind a desk, make regular eye contact, smile, and their local office phone number, with all workers etc.) interviewed so that workers can alert the worker interviewer if there are reprisals or intimidation; Selection: • the auditor should keep a confidential note of who is being • the interviewer should aim to talk to a number relevant

interviewed. Audit O ut p uts workers, taking into account: / different departments, including workers associated Interview structure: with managing waste, undertaking environmental • introduction: The audit team should introduce themselves monitoring as well as production workers; and communicate the purpose of the audit. They should Closing meeting / health & safety representatives/personnel, where assure interviewees that all information shared during the appropriate; interview will remain unattributed;

/ environmental committee representative(s), if applicable; • confidentiality: No manager or representative of the Gloss / new employees/trainees (to evaluate training quality); employment site, apart from the workers concerned,

/ employees from different shifts. should be present during any worker interview. a ry A pp endices

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Reference Environmental Audit Process & Methodology - november 2010 Opening meeting Opening meeting introduction

ystem 4.4 Document review

In countries where there are data protection requirements obtain the written permission of workers to view personnel Employment site tour tour site Employment (e.g. all EU countries), auditors should respect data files during any interviews (e.g. when reviewing training protection requirements during reviews of environmentally- records etc.). Workers should be assured that they are able related documents. Auditors should also, where applicable, to refuse permission to view their files if they so wish. isk Assessment S Assessment R isk Interviews Interviews

Example data protection consent form

In order to administer your employment, your employer about environmental standards. As part of this review, collects and uses certain personal information (such as (Insert Audit Company Name) may need access to your Audit R equest Audit your contact details, roles and responsibilities and training personnel file.

Document review review Document records/attendance). This information constitutes your

personnel file. You have confirmed that you are happy for (Insert Audit tion tion Company Name) to have access to your personnel file for (Insert Audit Company Name) has been engaged to review the purposes of the review. the environmental practices of your employer for the purposes of ensuring compliance with the (Insert Code(s)) Please sign below to give your permission. r a Pre pa Alert notifications Alert notifications

4.4.1 Document sampling • information on the site geology and hydrogeology, if available; The documentation requested by the auditor should be • company environmental policies; available on-site, including, but not limited to, applicable

xecution E xecution Audit licences/permits, internal and external reports, emission • government/agency Inspection Reports, e.g. environmental sources inventories, spill or incident release records and compliance, etc.; notifications, maintenance records, integrity testing records, • procedures (e.g. waste handling and disposal, spill waste documentation, environmental committee meetings containment etc.);

Audit team pre-closing meeting meeting pre-closing Audit team or minimisation projects, monitoring data and training

materials. Auditors should review documentation from • training records; the previous 2 years (e.g. monitoring data, maintenance • details of permits, consents and licences (or documented Audit O ut p uts Audit records), however, older documentation may reasonably be exemptions where applicable) for: requested where it is necessary to demonstrate compliance. If records for the previous 2 years are not available, the / water abstraction; ry a ry

Closing meeting Closing meeting employment site should explain why this is the case. For / effluent wastewater discharges; example, the employment site has been operational for less / storm water discharges;

Gloss than 2 years. / emissions to air; The auditor should go through a comprehensive document / chemical and fuel storage; trail including the following (this is not an exhaustive list): / on -site waste management and storage; and • management structure (e.g. organogram); / off -site waste disposal information including contractor’s • environmental committee meeting minutes; licences; A pp endices • employee handbooks; • hazardous substances list/inventory; • previous environmental reports/Corrective Action Plan • safety data sheets for hazardous substances; Report; • emission sources inventories (e.g. emissions to air, land and • employment site layout/floor plan; water); • maps of the surrounding area, if available; • inspection/service logs and inspection reports for environ‐ mental-critical equipment e.g. abatement equipment etc.; • process diagrams; • spill/incident log and remedial steps taken including • information on nearby protected habitats (e.g. local nature correspondence with authorities regarding e.g. spills, reserves) including distance from site, if available; leaks, odour, noise etc.;

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Reference Environmental Audit Process & Methodology - november 2010 Employment site tour R isk Assessment S

• environmental emergency procedures; • ionizing radiation sources registration, disposal records and inspection records; • inventory (or similar) of air emission points; • intrusive soil and groundwater investigation reports and • air emission monitoring log/results; on-going monitoring requirements; ystem Interviews • greenhouse gas data (use, release etc.); • major incident risk assessments and/or incident reports; • energy use data; • nuisance/complaints log; Audit R equest

• water sources (e.g. from abstraction borehole), uses (e.g. • notices of violation or fines from a regulating agency; Document review process water, cooling etc.) and consumption data; • communications with environmental regulating agencies/ • employment site drainage plan; authorities relating to environmental violations and pollution • wastewater monitoring log/results; incidents (air, water, effluent, wastes, odour and noise). Particular emphasis should be placed on evidence that there is • waste documentation including manifests for offsite a systematic approach to managing all aspects of the relevant Alert notifications disposal, waste contractor licences and permits etc.; Pre pa r a codes or requirements. • site audits of waste contractors;

• bulk tank inventory (including contents, capacity etc.); 4.4.2 Document inconsistencies tion • bund/secondary containment inventory; Inconsistencies between different types of documents

• tank/bund inspection logs/reports; and worker testimony may be considered a critical non- Audit E xecution

compliance, depending on the potential environmental Audit team pre-closing meeting • tank/bund integrity testing logs/reports; issues and risks presented by those inconsistencies. Where • asbestos survey reports, asbestos register, management deemed to be a critical non-compliance, it should be raised plan and inspection reports; appropriately with employment site management and as per the Alert Notification process. • ozone depleting substances (ODS) inventory and inspection logs/reports; If a non-compliance related to permit or licence requirements/

conditions is identified, the audit team should identify the Audit O ut p uts • polychlorinated biphenyls (PCBs) inventory and inspection context of the issue, and its frequency, and the department(s) logs/reports; concerned both at the closing meeting and in the audit report. Closing meeting

4.5 Alert notifications Gloss Where a ‘critical’ non-compliance (whether a non-compliance If an auditor believes they might be at risk as a result of

with legal requirements or the GSCP Environmental communicating a critical non-compliance, the audit team a ry Reference Requirements) is identified, the auditor should, should wait until it is removed from that situation before wherever possible, inform the audit requestor as soon as issuing the alert notification. possible. If the audit requestor is on site, the auditor should A pp endices Examples of non-compliances can be found in paragraph communicate the critical non-compliance immediately. This “4.6.1 Non-compliances, Observations and Good Practices will enable the audit requestor and the employment site to Evaluation” work together to plan an appropriate and timely resolution to the issue. A reference alert notification is available in Appendix 4.

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Reference Environmental Audit Process & Methodology - november 2010 Opening meeting Opening meeting introduction

ystem 4.6 Audit team pre-closing meeting

mployment site tour tour site mployment The audit team should meet before the closing meeting The reference Summary of Findings and Corrective Actions E to discuss the findings of the audit (interviews, document includes: checks, employment site tour) and agree the performance • audit findings: Confirmation of performance level in level demonstrated by the site in relation to each of the 11 isk Assessment S Assessment R isk relation to each of the 11 Performance Areas, summary of defined Performance Areas and identify inconsistencies, nterviews nterviews

I non-compliances, good practice, and evidence found; non-compliances, observations, and good practice. The analysis of evidence gathered is a pre-requisite to the closing • classification of non-compliances; meeting. It must be completed even if the auditor is alone at • reference to the applicable code of conduct and/or law the employment site. which has been contravened; The audit team should prepare for the closing meeting by • recommended corrective actions: Auditors suggestion on ocument review review ocument Audit R equest Audit

D identifying and agreeing: how the audit findings can be resolved;

• the performance level demonstrated by the site in relation • person/party responsible for corrective action; to each of the 11 defined Performance Areas; tion tion • verification method: • level 1 Non-compliances identified including: / a desk-based follow up may be used to verify corrective / their status/severity (critical, major, minor); actions for minor non-compliances but provide less r a Pre pa Alert notifications Alert notifications / supporting vidence;e assurance than a follow-up audit. Desk-based verification / recommended corrective actions, how these can be should check corrective actions through photos, copies verified, and a suggested timeframe for completion; of certificates/licences/permits, monitoring data, etc. submitted by the employment site. Desk-based follow- • systematic problems and issues from one-off, isolated, up cannot be used where actions need to be verified non-systematic issues; through worker testimony; • the root cause of problems, where possible; / follow-up audit are recommended for critical or major xecution E xecution Audit • good practice examples; non-compliances or when corrective actions can be evaluated only through interviews and extensive • a prioritisation of issues; documentation reviews [see section 5.4 for guidance • any requests for additional information or evidence. on conducting follow-up audits];

Audit team pre-closing meeting meeting pre-closing Audit team • timescale for completion: The amount of time required for A note on Corrective Actions the issue to be closed. The time allocated for corrective Audit requestors (companies and/or individuals) may take a actions to be completed should be appropriate, realistic Audit O ut p uts Audit number of different approaches with respect to corrective and timely. actions, for example: The Summary of Findings and Corrective Actions should: ry a ry • require auditors solely to identify corrective actions and Closing meeting Closing meeting • be clearly described and presented in both English and the require the employment site to develop the corrective language spoken by the employment site management; Gloss action plan following the audit or • be distributed as follows: • require auditors to identify evidence-based findings and work with the employment site to develop a corrective / one original, signed copy for the employment site action plan or manager; / a second original, signed copy retained by the auditor • require auditors to identify evidence-based findings,

A pp endices together with other audit documentation; develop the appropriate corrective action and agree with the employment site on their follow-up. / a hard or soft copy to the audit requestor. However, reference is made here to both ‘findings and corrective actions’ on the understanding that the 4.6.1 Confirmation of performance level identification of corrective actions may be required. and evaluation of non-compliances, observations and good practices The reference Summary of Findings and Corrective Actions (Appendix 6) has been designed to provide a structure to Auditors should confirm the level that the employment site the audit team’s findings and help the audit team develop a demonstrates in relation to each of the 11 Performance Areas corrective action plan and structure a closing meeting. and the evidence upon which this is based (an employment site can demonstrate different levels of performance against different Performance Areas).

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Reference Environmental Audit Process & Methodology - november 2010

E mployment site tour R isk Assessment S

For the employment site to be identified as meeting a Follow-up audits are recommended for critical or major non- particular performance level in relation to a Performance compliances or when corrective actions can be evaluated only Area, it must be meetingall of the individual requirements in through interviews and extensive documentation reviews[see that (and any preceding) performance level. For example, a section 5.4 for guidance on conducting follow-up audits]. ystem

site cannot achieve performance level 2 unless it is meeting I nterviews all of the level 1 and level 2 requirements. An employment 4.6.1.1 Categorisation examples site can be fully meeting a particular performance level and The below provides guidance on how to categorise different be demonstrating that it meetssome of the requirements of

issues as minor, major or critical non-compliances. The list Audit R equest the next performance level. gathers examples and is not intended to be exhaustive. It D ocument review Auditors should classify non-compliances against Level 1 gives an indication of how various issues should be considered Requirements and observations and examples of good practice in light of the reference guidelines and the reference code against all performance level. and taking into account the potential environmental impact of the issues identified and the regulatory regime of the Should any critical or major legal non-compliance be country. These examples are for illustration only; auditors

identified in relation to a particular Performance Area, then Alert notifications

should still use their discretion when classifying non- Pre pa r a the employment site cannot be considered as meeting compliances. the basic requirements associated with Level 1 for that Performance Area. Minor tion In relation to Level 1 Requirements, Auditors should record • basic environmental management structure and defined non-compliances, whether they be non-compliances management responsibilities are in place, however, this is not documented; with legal requirements or non-compliances with the Audit E xecution Audit team pre-closing meeting Environmental Framework Requirements themselves. • site has identified and is managing its potentially significant Non-compliances should be categorised as: aspects and impacts but has not documented this process/ the results; • minor non-compliance; • relevant inventory/register established in relation to a • major non-compliance; or particular Performance Area, but not actively maintained; • critic al non-compliance. • an occasional or isolated compliance issue e.g. missing Audit O ut p uts The auditor should record in the Audit Report (Appendix 5) records/documentation in relation to permit/consent/ whether a non-compliance identified is a non-compliance licence requirements; with specific legal requirements. • the site has a mechanism to remain up to date with appli- cable local legal requirements, but has not documented

If no non-compliances are identified, then the Employment Closing meeting Site is considered to have met the Level 1 Requirements this process; for that Particular Performance Area. However, should any • an issue which presents a risk to the environment (low risk) critical or major non-compliances be identified in relation (either on-site or the surrounding areas); Gloss to a particular Performance Area, then the employment site cannot be considered as meeting the basic requirements • site has a procedure to ensure that external third parties a ry associated with Level 1 for that Performance Area. If only utilised by the site for environmental matters (e.g. waste minor non-compliances are identified, then it will be removal/disposal) are appropriately licensed, but has not judgement decision by the Auditor (and possibly by the Audit documented this process; A pp endices Requestor) as to whether the Employment Site is considered • occasional or isolated instances of missing monitoring/ to have met the Requirements of Level 1 in relation to that performance data (that is not a legal requirement). particular Performance Area. Major Non-compliances and observations should be classified according to: • basic management structure/defined management responsibilities not in place, either in relation to overall • the frequency of the problem or whether the issue is an environmental management or particular Performance isolated occurrence; Area; • the potential severity of the problem; • site has identified that it has potentially significant • the probability of recurrence of the problem. environmental aspects/impacts, but has not acted on this information; The auditor must be able to justify his/her classification with detailed evidence. • site is not aware of its legal requirements in relation to a particular performance area;

Global Social Compliance Programme_17

Reference Environmental Audit Process & Methodology - november 2010 Opening meeting Opening meeting introduction tem s • site has no mechanism for remaining up to date with • non-operation of critical abatement equipment e.g. air applicable legal requirements; emission scrubber, incineration unit etc.; ment Sy ment mployment site tour tour site mployment E ss • sit e not aware of relevant permit/ licence/ consent/exemption • evidence of the deliberate provision of false information e requirements; to auditors or regulators so as to disguise non-compliances

Ass with permit/licence/consent requirements; k k • breaches of legislation or permit/licence/consent s i

R requirements which represents risk of moderate harm to • perf ormance or monitoring data manipulated or misreported nterviews nterviews I the environment e.g. exceedance of wastewater discharge to intentionally mislead regulators; t limits, exceedance of air emission limit concentration etc.; s • a major non-compliance from a previous audit that has not • a systemic breach or violation of a legal requirement; been addressed or for which no significant improvement eque

R has been made by the time of a follow up audit and which • a breach of a legal requirement or environmental permit/ has increased the level of environmental risk, e.g. of licence/consent which is considered likely to attract udit causing incidents; ocument review review ocument A

D regulator intervention;

• site knowingly utilises illegal/unlicensed external third • site has not confirmed that all external third parties utilised parties in relation to environmental matters (e.g. waste by the site for environmental matters (e.g. waste removal/ removal/disposal); disposal) are appropriately licensed; • site has not provided identified and/or provided training • relevant inventory/register not established in relation to a

reparation reparation to employees on environmental matters which represent a

P particular Performance Area; Alert notifications Alert notifications serious or significant impact to the environment. • c onsumption/generation data not collected in relation to Critical non-compliances should trigger an alert notification a particular Performance Area that is relevant to the site. [see section 4.5]. Critical An Observation xecution xecution

E • an environmental aspect which represents imminent risk • a possible issue which could develop into a non-compliance of serious or significant impact to the environment (e.g. if action is not taken by theE mployment Site (i.e. a potential udit major damage to a local ecosystem, closure of a potable A non-compliance); water abstraction point, known on-site or off-site impact

s to soil, groundwater or surface water); • an issue, on which the auditor has some evidence to indicate that it may be present, but is not confirmed by more than • site has identified that permit/licence/consent/exemption one data point; utput required, but has not obtained it; O Audit team pre-closing meeting meeting pre-closing Audit team • an opportunity for improvement e.g. how the employment • relevant inventory/register not established in relation to site can meet the requirements of the next performance level. udit a particular Performance Area, which has the potential A to result in non-compliance with permit/licence/consent Good Practice requirements or which results in mis-management of A positive, innovative or novel approach, technology ora ar environmental matters with the potential for significant process to managing environmental issues in relation to a Closing meeting Closing meeting ss impact to the environment; particular Performance Area that improves performance

Glo y • site currently under threat of prosecution, fine and/or over and above the standard. enforcement in relation to an environmental issue; s Level 2 and Level 3 findings • an attempt to pervert the course of the audit through fraud, coercion, deception or interference; Given that the GSCP Environmental Reference Requirements at levels 2 and 3 are intended to drive performance ppendice • a systemic violation of a legal requirement that has improvement. As such, the Auditor should record only A attracted (or could likely attract) regulator intervention whether the Employment Site has met or not met a particular (e.g. continued illegal disposal of waste materials, either Requirement, together with observations and examples of on-site or off-site); good practice, if applicable. Where the auditor identifies • auditors denied access or obstructed from conducted from that a Requirement is not met, they should provide a short conducting a proper audit; description as to why.

18_Global Social Compliance Programme Audit report in t ro

Reference Environmental Audit Process & Methodology - november 2010 duct ion Supplementary audit information R isk A ssess m ent 4.7 Closing meeting

The purpose of the closing meeting is to go through the • answer questions that management have; findings, agree them and agree the corrective action Sy

• explain when the full report will be completed and who it ste m plan which sets out areas for improvement, actions and timeframes. Corrective actions should focus on long term will be sent to; sustainable solutions which take account of the root cause of • get sign-off on the Summary of Findings and Corrective Information management any problem. This meeting should involve all those attending Actions by both auditor and employment site: A the opening meeting and should: udit / when agreed with the audit requestor, a copy of the • reconfirm the purpose of the assessment; corrective action plan should be left with management; R equest • confirm the performance level for each of the 11 Performance / the corrective actions should include a timeframe for Areas; completion and the type of verification needed; • recognise good practices; • if the Summary of Findings and Corrective Actions is Pre p not agreed, the auditor should leave a copy with the Audit follow-up • agree any non-compliances;

employment site and report disputed points to the audit ara • record non-compliances which can be corrected immediately; requestor, copying the employment site. t ion Aud i t

5. Audit Outputs E xe cut ion

5.1 Audit report Aud i t The context, findings, issues and actions, where applicable, • for each non-compliance or observation, provide a: against each of the 11 Performance Areas should be reported / description of the non-compliance or observation and Outputs to the audit requestor. The report should be available its frequency; in English to ensure that it can be shared with various / evidence found to substantiate it; stakeholders, as well as in the language of the management wherever this is possible. The report should be delivered to / classification to applicable law, code of conduct, etc. G lossar the audit requestor within 10 business days of the audit. The report must not include any information that could The report should include: be used to identify specific workers – such as names, ID numbers, job descriptions and/or work location. • a summary of the auditors’ evaluation of the employment y site’s performance against each of the 11 Performance The report should include photos4 of the employment site Areas; such as: App en d i c e • identified non-compliances which indicate that the • outside general overview; employment site is not meeting Level 1 of the GSCP • inside general overview;

Environmental Reference Requirements; s • key activities and processes that have potential environ‐ • observations and good practices. mental impact; For each environmental Performance Area, the report • waste handling and storage areas; should: • hazardous substance storage areas; • describe the current situation including which of the GSCP Environmental Reference Requirements the site is • areas of potential impact to soil and groundwater including currently meeting; staining and distressed vegetation; • provide evidence and information to substantiate the • bulk storage tanks and secondary containment; findings;

4. Photographs should only be taken with the permission of the employment site as they may contain or reveal confidential information.

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Reference Environmental Audit Process & Methodology - november 2010 Audit report Audit report introduction

ystem • wastewater treatment areas; Unless agreed by all parties in writing, the audit organisation will not distribute the report to any entities except the audit • abatement equipment; requestor. However, the audit requestor should share the • good practices where these can be photographed; report with the employment site/customer/supplier as soon as possible in order to facilitate co-operation on continuous • non-compliances where these can be photographed. improvement. isk Assessment S Assessment R isk A reference audit report is available in Appendix 5. Supplementary audit information audit information Supplementary

5.2 Supplementary audit information

Auditors may feel the need to separately report to the audit • concerns about the possibility of falsified records. Audit R equest Audit requestor in the event that, for example, the auditor has: The process for reporting such information should be agreed • information that is too sensitive for the audit report itself; between the audit requestor and the auditor in advance of

tion tion the audit.

Information management management Information • concerns which cannot be substantiated through evidence and/or interviews; A template for reporting additional information is available in Appendix 7, Reference Environmental Supplementary

r a Pre pa • commentary/insight on the attitude of management Audit Information. towards the non-compliances or where management was obstructive to the audit process; Audit follow-up Audit follow-up

5.3 Information management xecution E xecution Audit Within 10 days of the completion of each audit, the auditor The auditor or audit organisation should: should provide the following documents to the audit • be available after the audit to further clarify or explain requestor: decisions and ratings to the employment site and/or audit • the Pre-Audit Employment Site Profile; requestor as needed; • the completed audit report, including photographs; • have an appeals procedure should the employment site or audit requestor challenge one of the findings and in case of Audit O ut p uts Audit • summary of findings (and corrective actions, if applicable); any complaint by the employment site against the auditor. • supplementary audit information, where applicable; ry a ry • copies of any alert notifications that were issued during the audit. Gloss

5.3.1 Audit records

All documents (unless they are “business confidential”), hand • environmental licences and permits;

A pp endices written notes, signed Summary of Findings and Corrective • surveys (e.g. asbestos surveys); Actions and audit report should be retained by the auditor for reference for at least five years. • key environmental monitoring results; It is recommended that the auditor retain copies of at least • communications or notices of violations issued by the following documents assuming that this has been agreed regulatory authorities; between the audit requestor and the employment site: • evidence relating to non-compliances, wherever possible. • official documents on legal status of the company (business If copying facilities are not available, auditors should licence); photograph these documents. • insurance policies/certificates (relating to buildings and Data and privacy laws in some countries prohibit copies people); being made of certain documents; in such cases, auditors should respect these restrictions.

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Reference Environmental Audit Process & Methodology - november 2010 Supplementary audit information R isk Assessment S

5.4 Audit follow-up

Audit follow-up focuses on the corrective actions agreed Follow-up Audit Guidance: during the audit and closing meeting, if applicable (i.e. the • the audit should be carried out once the deadline for ystem identification of corrective actions was part of the audit addressing all of the issues has passed; scope). Information management • follow-up audits should generally take place within six Where such corrective actions were agreed:

months of the date of the initial audit; Audit R equest • the auditor will be responsible for verifying whether actions • a follow-up report should be issued. This is an updated have been taken and recording verification of actions; version of the original report, with all new issues and • for corrective actions where - desk based verification is updates to previous issues clearly highlighted; adequate, the auditor will review evidence submitted[ see / for all sections where non-compliances have previously section 4.6]; been raised there should be a clear explanation of the Audit follow-up • where a follow-up audit is required, the length of time evidence reviewed, comments on applicability and Pre pa r a taken at the follow-up should be related to the number effectiveness and whether the issue is now considered and severity of issues to be verified; closed or remains open;

/ improvements should be mentioned even if the non- tion Follow-up audits may be commissioned by the audit compliances are not fully corrected; requestor, typically in relation to critical or major non- compliances identified in relation to Level 1 issues, and/ / if new non-compliances are found these should be or when corrective actions can be evaluated only through recorded and marked as “new” and should be reported Audit E xecution interviews and extensive documentation reviews. in as much detail as they would have been in the initial report; • a partial follow-up audit does not include a full review / a desk-based follow up may be used to verify corrective but only focuses on the issues identified in the corrective actions for minor non-compliances but provide action plan; less assurance than a follow-up audit. Desk-based • a full follow-up audit should include a full review of all verification should check corrective actions through photos, copies of certificates, invoices, submitted by

areas of the standard audit process, including the complete Audit O ut p uts re-sampling of documents, conducting interviews and the employment site. Desk-based verification cannot the employment site tour. The auditor should focus on be used where actions need to be verified through identifying changes which would address issues raised in worker testimony. the initial report, but also investigate potential additional issues. Typically, a full follow-up audit would only be necessary where the non-compliances identified in the initial audit Gloss indicated that an environmental management system

was not in place or that there were extensive/systematic a ry failings associated with the site’s existing environmental management system. A pp endices

Global Social Compliance Programme_21 Reference Environmental Audit Process & Methodology - november 2010 introduction ystem

isk Assessment S Assessment R isk Glossary of terms Audit R equest Audit A Corrective action plan tion tion Announced audit A plan of action drawn up at the end of an audit that records what measures have to be taken and within what time limit to remedy the non-compliance. An audit which is undertaken on a specified date that is r a Pre pa chosen in agreement with the employment site.

Audit requestor E Employment site Generic term referring to any entity that has requested and commissioned an audit, including the requesting entity’s An individual/specific production site, farm, winery, quarry, customers (where known) where agreements allowing such mine, service site etc. (including where applicable selected xecution E xecution Audit disclosure are in place. sub-contractors/homeworkers).

C EMAS Code of conduct The European Union (EU) Eco-Management and Audit Scheme (EMAS), is a voluntary initiative designed to help companies evaluate, report on and improve their environmental

Audit O ut p uts Audit A set of standards concerning environmental practices adopted performance. Its aim is to recognise and reward those by a company and applied to its suppliers, employment sites organisations that go beyond minimum legal compliance and and subcontractors. continuously improve their environmental performance. It is ry a ry a requirement of the scheme that participating organisations Comply/compliance regularly produce a public environmental statement that Gloss reports on their environmental performance. To meet local environmental laws and regulations and/or the GSCP Environmental Reference Requirements, applicable codes EMS – Environmental Management System of conduct and international labour standards requirements. A management system is a set of interrelated elements

A pp endices Continuous improvement used to establish policy and objectives and to achieve those objectives. The recurring process of enhancing the environmental management system in order to achieve improvements Environmental audit in overall environmental performance consistent with an (hereafter referred to as ‘audit’) organisation’s environmental policy. Systematic, independent and documented process for Corrective action obtaining evidence and evaluating it objectively to determine the extent to which environmental standards criteria are met. Measures taken to eliminate a non-compliance identified during an audit.

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Reference Environmental Audit Process & Methodology - november 2010 R isk Assessment S

F I First party audit Initial audit ystem An internal audit that an organisation performs on itself to The first audit undertaken on an employment site which evaluate conformity with procedures or a defined standard, assesses compliance against a specific code of conduct, or is for example an audit could solely be against regulatory requested by a specific customer. requirements. Audit R equest

Follow-up audit M

An audit to assess the effectiveness of corrective actions, Management undertaken to address issues from a previous audit. A follow- up audit can be either a full or a partial follow-up audit (see People who identify and achieve organizational objectives definitions below). through the deployment of appropriate resources. A Pre pa r a manager can have responsibilities in one or more of five key Full follow-up audit areas: managing activities; managing resources; managing information; managing people; and managing him- or tion herself at the same time as working within the context An audit to assess the effectiveness of corrective actions, of the organizational, political, and economic business undertaken to address issues from a previous audit. The audit environments. Audit E xecution should include a full review of all areas of the standard audit process, including the complete re-sampling of documents, conducting interviews and the employment site tour. P G Partial follow-up audit An audit to assess the effectiveness of corrective actions,

Good practice Audit O ut p uts undertaken to address issues from a previous audit. The audit does not include a full review, but only focuses on the A positive, innovative or novel approach, technology ora issues identified in the corrective action plan. process to managing environmental issues in relation to a particular Performance Area that improves performance over and above the standard. R

Greenhouse gas intensity Re-audit Gloss

The quantity of greenhouse gases emitted, for example, per A new audit which is performed on an employment site that a ry unit of production. This is normalised data (as opposed to has already been audited under the same code of conduct or absolute data), which allows comparison of greenhouse by the same customer. gas emissions even if there are increases or decreases in A pp endices production. S Grey water (also referred to as grey water or gray water) Second party audit

Wastewater, typically generated from domestic-style An external audit of one organisation (e.g. supplier of activities, for example washing machines, showers, bathtubs, products or services) performed by another organisation hand washing, and sinks, together with some industrial (typically a customer for those products or services) to processes, which is recycled/re-used and put to a different evaluate conformity with procedures or a defined standard. use, for example, use in toilet flushing, cleaning or irrigation. The grey water may require some treatment (physical, biological or chemical) to ensure that it is of sufficient quality for the new use. Grey water must NOT be used as potable (drinking) water.

Global Social Compliance Programme_23 Reference Environmental Audit Process & Methodology - november 2010 introduction

ystem Semi-announced audit Third party audit

An audit which is undertaken on an un-specified date, An external audit of an organisation, conducted by an scheduled within a set period (between 2 weeks and 2 independent party or body, to evaluate conformity with months), which is agreed with the employment site. The procedures or a defined standard. The audit may, for employment site will be informed that an audit will take place example, be on behalf of another organisation or be isk Assessment S Assessment R isk during this period but will not be informed of the exact date. performed by a certification body to assess compliance with the international management systems standard ISO14001. Stakeholder

Any person, company, organisation or other party that is U affected by the activity and/or operations of a company. Unannounced audit Audit R equest Audit Subcontractor An audit carried out without prior warning to the employment site. An individual or a group of individuals to whom a contractor tion tion outsources the manufacture of a product or part-product. V

r a Pre pa Summary of findings and corrective actions Verification A summary document which provides information about all issues and other findings from an audit, as well as corrective Examination of claims made about the actual observance of actions and time frames for completing these. code or standard provisions by suppliers or of claims made about the activities that a company undertakes to give effect Supplier to its code. Verification implies that participating companies must have internal auditing or monitoring systems in place. xecution E xecution Audit Any contract partner which supplies the retailer/brand with goods or services. W T Worker Target (environmental) A person working on an employment site, in any capacity. Audit O ut p uts Audit

A detailed performance requirement (quantified where possible and applicable to all or parts of the organisation), ry a ry that arises from the setting of environmental objectives and which needs to be set and met in order to achieve those Gloss objectives. A specific task in the achievement of an environmental objec‐ tive. Environmental targets must be stated in a measurable and quantifiable manner. ISO14001:2004 A pp endices Targets can be based on absolute data or normalised data.

24_Global Social Compliance Programme GSCP Reference Environmental Audit Report GSCP Reference Environmental Self Assessment Questionnaire introduction

Appendix 1 R isk Assessment S GSCP Reference

Environmental GSCP Reference Environmental Supplementary Audit Information Self-Assessment ystem Questionnaire Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile

This tool forms part of the GSCP set of reference tools The self assessment reference tool below is structured in designed to provide a common interpretation of local and accordance with the GSCP Draft Environmental Framework Pre pa r a international environmental standards and requirements and Requirements but is not designed to be used as a self audit environmental reference codes (if available and applicable). against these Requirements. Buying companies or suppliers may The Environmental Reference Requirements reflect a tailor the reference self-assessment to their specific by adding tion common understanding of good environmental practice and or removing questions to meet their specific requirements. are applicable to all raw material processing, agricultural,

Companies should communicate the following to employment Audit E xecution manufacturing and logistics sites in the supply chain. The sites when requesting this information: Environmental Reference Requirements provide a model GSCP Reference Environmental of Findings and Corrective Summary Actions for a site in the supply chain to demonstrate continuous • reason for the information request; improvement in its environmental performance from basic • how the risk assessment fits within the audit process; compliance to leading-edge performance (across three defined ‘levels’ for eleven different performance areas). • to whom to send the completed self assessment (or how to upload the self assessment on to a database); The reference tools on Environmental Audit Process and

Methodology are based on the GSCP Environmental • timeframe for completion; Audit O ut p uts Reference Requirements but can be adopted and tailored to • process and timeframe for updating the self-assessment; other codes of environmental practice. GSCP Reference Environmental Audit Checks The self-assessment questionnaire can be used by: • confidentiality arrangements when sharing information provided in this questionnaire. • a buying company to risk assess suppliers/employment sites (e.g. to provide a basis for the development of an Employment sites should be encouraged to answer the self assessment questionnaire in full and add commentary and/ audit programme); Gloss or evidence against each point rather than just marking Yes • a supplier or employment sites as an aid to their own or No. risk reviews and/or preparation for their own self audit a ry programmes; and

• an auditor to focus on site investigation on high risk areas. A pp endices GSCP Reference Environmental Alert Notification

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Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem Reference Self-Assessment GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference Questionnaire isk Assessment S Assessment R isk Company Overview

Name of company which owns the employment site to be audited GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Ownership type (e.g. joint venture, partnership,

Audit R equest Audit corporation, foreign investment, other):

Registered head office address tion tion

Ownership type (e.g. joint venture, partnership, r a Pre pa corporation, foreign investment, other) GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

Year company formed

Does the company own any other employment sites? If yes, how many and in which countries? xecution E xecution Audit Annual turnover of company (USD$) GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

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Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

GSCP Reference Environmental Supplementary Audit Information

ystem

Employment Site Overview Audit R equest

Employment site name

Full address GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a Country

Employment site website tion

Employment site manager Audit E xecution

Name of person completing GSCP Reference Environmental of Findings and Corrective Summary Actions this questionnaire

Job Title/Role of person completing this questionnaire

Telephone number of person completing Audit O ut p uts this questionnaire GSCP Reference Environmental Audit Checks Email address of person completing this questionnaire Gloss a ry A pp endices GSCP Reference Environmental Alert Notification

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Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem Employment Site Production Systems and Processes

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference Industry sector:

isk Assessment S Assessment R isk

Principal products: GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion Main production processes (e.g. Stitching, labelling, injection, moulding, baking, harvesting, dyeing etc.): r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

Main raw materials used: xecution E xecution Audit GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

04_Global Social Compliance Programme GSCP Reference Environmental Audit Report GSCP Reference Environmental Self Assessment Questionnaire introduction

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

Employment Site Size and Location

What is the employment site size? GSCP Reference Environmental Supplementary Audit Information acres/hectares/m2 (please state units used) ystem

Approximately, what area of the site is covered by buildings (%): Audit R equest

What age are the buildings on-site (if known)?

Is the site owned or leased? Owned Leased GSCP Reference Environmental Pre-Audit Employment Site Profile

Are there any other parties on site as tenants Yes No or sub-tenants? Pre pa r a If yes, please name them tion Describe surrounding land use (residential, industrial, rural etc.) and identify neighbouring

facilities and types: Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions North:

South:

East: Audit O ut p uts West: GSCP Reference Environmental Audit Checks State the distance to, and size of, the nearest residential communities

Are there any sensitive habitats nearby,

such as nature reserves, national parks, Gloss wetlands or sites of special scientific interest?

If yes, please describe a ry

What is the location of the nearest surface A pp endices water course (river, stream, canal, lake, reservoir, pond, etc.)? GSCP Reference Environmental Alert Notification Are there any boreholes/wells or natural springs either on-site or in the surrounding area?

When was the site first developed from greenfield (if known)?

Please summarise the previous land-uses of the site (if known), e.g. type of operation, occupier of the site etc.?

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Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem 1. Environmental Management Systems

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference 1.1 Does your site have a policy defining its approach to environmental Yes No management? If yes, please attach

isk Assessment S Assessment R isk 1.2 Is your site committed to any industry or governmental environmental Yes No codes? If yes, please provide details GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit 1.3 Does your site have a dedicated manager who is responsible for Yes No environmental issues? If yes, please specify exact title and name Name: tion tion Title:

1.4 Has your site assessed its environmental risks? Yes No r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

1.5 Does your site have a system or process for assessing environmental risks Yes No associated with the introduction of new (or changes to existing) materials, processes or activities?

1.6 Does your site set environmental objectives and targets to improve Yes No environmental performance (e.g. reductions in water use, reductions xecution E xecution Audit in energy use, reductions in wastes generated)? If yes, please provide details GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

1.7 Does your site have a system in place that will alert relevant personnel Yes No Audit O ut p uts Audit to changes in any applicable environmental laws?

1.8 Does your site have defined standards for suppliers (e.g. suppliers Yes No ry a ry of services, contractors, raw material suppliers) that prescribed expected levels of environmental performance?

Gloss If yes, please attach a copy

1.9 Does your site have a procedure in place to evaluate and select suppliers Yes No

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference (e.g. suppliers of services, contractors, raw material suppliers) based on GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

their ability to meet the standards mentioned in Q1.8? If yes, please attach a copy A pp endices

1.10 Is there a site environmental committee? Yes No If yes, does this include representatives from various business functions? Yes No … GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

06_Global Social Compliance Programme GSCP Reference Environmental Audit Report GSCP Reference Environmental Self Assessment Questionnaire introduction

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S …

1. Environmental Management Systems

1.11 Does your site have procedures in place to control the way work is done Yes No

or activities are completed that address environmental issues? GSCP Reference Environmental Supplementary Audit Information ystem

1.12 Does your site have specific written environmental procedures Yes No (e.g. for waste handling and disposal, spill prevention etc.)? Audit R equest 1.13 Are all workers (including temporary workers) trained on relevant Yes No environmental matters and how they, as individuals, may impact the environment? GSCP Reference Environmental Pre-Audit Employment Site Profile 1.14 Is this training repeated on a regular basis? Yes No If yes, how often does this occur? Pre pa r a tion 1.15 Does your site have records of the names of all personnel trained Yes No and the dates they were trained? Audit E xecution

1.16 Are visitors provided with any instructions or information in relation Yes No N/A GSCP Reference Environmental of Findings and Corrective Summary Actions to environmental matters and site rules?

1.17 Are contractors/third party workers provided with training in relation Yes No N/A to environmental matters and site environmental procedures?

1.18 Does your site have a process for periodically reviewing its environmental Yes No Audit O ut p uts performance? If yes, please describe GSCP Reference Environmental Audit Checks Gloss a ry A pp endices GSCP Reference Environmental Alert Notification

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Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem 2. Energy Use, Transport and Greenhouse Gases (GHGs)

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference 2.1 What energy sources does your site use (e.g. mains electricity, locally Sources: generated electricity, coal, oil, gas etc.)? Please explain what they are and what they are used for isk Assessment S Assessment R isk

2.2 Does your site purchase any energy from renewable sources Yes No (e.g. solar, wind etc.)? If so, please provide further details GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit 2.3 Does your site have systems or procedures in place that seek to reduce the site’s environmental impact from: • Energy? Yes No N/A tion tion • Transport? Yes No N/A • Greenhouse gases (GHGs) Yes No N/A

r a Pre pa 2.4 Does your site provide training to relevant personnel in relation to: • Energy? Yes No N/A GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

• Transport? Yes No N/A • Greenhouse gases (GHGs)? Yes No N/A

2.5 Does your site monitor and track energy consumption? Yes No N/A If yes, please specify how it tracks energy use and provide approximate consumption figures for the energy sources listed in 2.1 on an annual

xecution E xecution Audit basis/12 month period GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

2.6 Is your site part of a recognised compliance scheme for greenhouse gas Yes No N/A (GHG) emissions trading? If yes, please provide details of the scheme (e.g. who runs it and the employment site’s membership reference) Audit O ut p uts Audit

ry a ry 2.7 Has your site set any targets in relation to increase efficiency of: • Energy use? Yes No N/A

Gloss • Transport use? Yes No N/A • Greenhouse gas (GHG) generation? Yes No N/A

2.8 Does your site conduct site energy audits? Yes No GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

If yes, how often are these undertaken and when was the most recent audit? How often: A pp endices Date of most recent audit:

2.9 Is your site required to monitor or calculate energy and/or GHG emissions Yes No N/A to demonstrate compliance with applicable permits?

2.10 Does your site monitor or routinely assess emissions of GHGs associated Yes No N/A with site processes/activities, fuel use for on-site or off-site transportation, agricultural activities etc.?

2.11 Does your site monitor or routinely assess emissions of fluorinated-gases Yes No N/A (F-gases)? GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

08_Global Social Compliance Programme GSCP Reference Environmental Audit Report GSCP Reference Environmental Self Assessment Questionnaire introduction

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

3. Water Use

3.1 What sources of water are used at your site (e.g. mains drinking water, Sources:

mains process water, borehole abstraction, surface water abstraction etc.)? GSCP Reference Environmental Supplementary Audit Information Please explain what they are and what they are used for ystem Audit R equest 3.2 If your site uses water abstracted from on-site boreholes or from rivers, Yes No N/A streams, lakes etc. does it require a permit or licence for this activity? If yes, are there limits and/or conditions associated with this permit/licence? Yes No N/A GSCP Reference Environmental Pre-Audit Employment Site Profile 3.3 Does your site have systems or procedures in place that manage water Yes No N/A consumption/use? Pre pa r a

3.4 Does your site provide training to relevant personnel in relation to water use? Yes No N/A

3.5 Has your site set any targets in relation to reducing water consumption? Yes No N/A tion

3.6 Does your site monitor and track water consumption? Yes No Audit E xecution If yes, please specify how it tracks water use and provide approximate consumption figures for all water sources on an annual basis/12 month period GSCP Reference Environmental of Findings and Corrective Summary Actions

Is monitoring and tracking of water consumption a legal requirement Yes No for your site?

3.7 Does your site conduct water audits (or other similar exercises) to identify Yes No Audit O ut p uts where water is being used, whether there are any leaks, whether water is being wasted etc.? GSCP Reference Environmental Audit Checks

If yes, how often are these undertaken and when was the most recent audit? How often:

Date of most recent audit: Gloss

3.8 Does your site use ‘grey’ water? (e.g. water typically generated from Yes No a ry domestic-style activities, for example washing machines, showers, bathtubs, hand washing, and sinks, together with some industrial processes) and recycled on-site) A pp endices

3.9 Is your site free from any fines, prosecution or warning by the regulators Yes No

in relation to water use? GSCP Reference Environmental Alert Notification If not, please provide details (including reason for fine/prosecution/warning, the date on which it occurred, the cost of any fine/details of any custodial sentence or restriction on site activities and whether the matter has been resolved or is ongoing)

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Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem 4. Wastewater / Effluent

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference 4.1 What wastewater/effluent streams are generated at your site? Streams: Please describe isk Assessment S Assessment R isk 4.2 Is there a dedicated drainage system on-site? Yes No N/A If yes, please describe the drainage systems present GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

4.3 Where does wastewater/effluent from your site discharge to (municipal

Audit R equest Audit sewer, river, lake, sea etc.)? Please describe tion tion

4.4 Does your site treat wastewater/effluent prior to off-site discharge? Yes No N/A r a Pre pa Is there a dedicated onsite wastewater/effluent treatment plant? Yes No N/A GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

4.5 Does your site hold the necessary licence or permit for discharging Yes No N/A wastewater/effluent via the drainage system? If so, please provide brief details xecution E xecution Audit 4.6 If your site does have a permit/licence, has your site been fully in Yes No N/A compliance with the requirements and conditions of the permit/licence GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

for the last three years?

4.7 Is your site required to sample/test wastewater discharges? Yes No N/A If yes, please provide details including frequency of testing and whether

Audit O ut p uts Audit this is undertaken on-site or outsourced to an external contractor ry a ry 4.8 Does your site have systems or procedures in place that address wastewater Yes No N/A generation and management? Gloss

4.9 Does your site provide training to relevant personnel in relation Yes No N/A to wastewater management? GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP 4.10 Has your site set any targets in relation to reducing the volume Yes No N/A of wastewater generated? A pp endices

4.11 Is your site free from fines, prosecution or warneing by the regulators in Yes No relation to wastewater management? If not, please provide details (including reason for fine/prosecution/warning, the date on which it occurred, the cost of any fine/details of any custodial sentence or restriction on site activities and whether the matter has been resolved or is ongoing) GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

10_Global Social Compliance Programme GSCP Reference Environmental Audit Report GSCP Reference Environmental Self Assessment Questionnaire introduction

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

5. Emissions to Air

5.1 What are the main point source emissions to air at your site Sources:

(point source emissions are those which discharge via a chimney, stack, GSCP Reference Environmental Supplementary Audit Information extraction system or vent)? ystem Please describe Audit R equest

5.2 What are the main fugitive emissions to air at your site (fugitive emissions Sources: are those which are not controlled (e.g. emissions from a plating bath into the general factory atmosphere and/or unplanned emissions, e.g. leaks from equipment, pipes etc.)? GSCP Reference Environmental Pre-Audit Employment Site Profile Please describe Pre pa r a

5.3 Are there abatement or pollution prevention devices (e.g. filters, scrubbers) Yes No N/A tion on point source emissions to air? If so, please describe the abatement techniques employed at the site Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions

5.4 Does your site hold the necessary licences or permits for emissions to air? Yes No N/A If so, please provide brief details Audit O ut p uts 5.5 If your site does have a permit/licence, has your site been fully Yes No N/A in compliance with the requirements and conditions of the permit/licence for the last three years? GSCP Reference Environmental Audit Checks

5.6 Does your site sample/test emissions to air? Yes No N/A If yes, please provide details including frequency of testing and whether this is undertaken by site personnel or outsourced to an external contractor Gloss a ry

5.7 Does your site have an inventory of equipment on-site that contains ozone Yes No N/A depleting substances (ODSs) (e.g. air conditioning equipment that contains refrigerants)? A pp endices If so, please describe the types and quantities of refrigerants/ODSs present on-site GSCP Reference Environmental Alert Notification …

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Environmental Audit Process & Methodology Reference Tools - november 2010 introduction … ystem 5. Emissions to Air

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference 5.8 Is your site phasing-out the use of ODSs? Yes No N/A

Is the phase-out a legal requirement for your site? Yes No N/A If yes, please provide details of phasing out isk Assessment S Assessment R isk

5.9 Is there a routine or periodic maintenance/inspection programme Yes No N/A in place to test for leaks of ODSs? GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference If yes, is this conducted by a specialist external contractor? Yes No N/A Audit R equest Audit 5.10 Does your site have systems or procedures in place that manage: • Emissions to air? Yes No N/A

tion tion • ODSs? Yes No N/A

5.11 Does your site provide training to relevant personnel in relation to:

r a Pre pa • Emissions to air? Yes No N/A • ODSs? Yes No N/A GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

5.12 Has your site set any targets in relation to reducing: • Emissions to air? Yes No N/A • Quantity of ODSs used on-site? Yes No N/A

5.13 Is your site free from any fines, prosecution or warning by the regulators Yes No xecution E xecution Audit in relation to emissions to air or ODSs? If not, please provide details (including reason for fine/prosecution/warning,

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference the date on which it occurred, the cost of any fine/details of any custodial sentence or restriction on site activities and whether the matter has been resolved or is ongoing) Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

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6. Waste Management

6.1 Does your site generate hazardous waste? Yes No

Typically, hazardous waste is waste that could cause harm to public health and/ GSCP Reference Environmental Supplementary Audit Information or the environment because of its chemical, physical or biological characteristics ystem (e.g., it is flammable, explosive, toxic, radioactive, or infectious). If yes, please list Audit R equest

6.2 What are the main non-hazardous waste your site generates?

Please list GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a 6.3 Does your site have systems or procedures in place that address waste Yes No N/A management? tion 6.4 Are site waste audits undertaken (to identify what wastes are generated Yes No where and to identify what opportunities there may be for reducing waste

or improving the management of waste)? Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions If yes, how often are these undertaken and when was the most recent audit? How often:

Date of most recent audit:

6.5 Are waste materials recycled (either on-site or off-site)? Yes No Audit O ut p uts If yes, please provide details GSCP Reference Environmental Audit Checks

6.6 Is your site required to be registered as a waste producer with the regulatory Yes No authorities?

If yes, please provide details Gloss a ry

6.7 Are hazardous wastes separated from non-hazardous waste streams? Yes No N/A

If yes, please describe A pp endices GSCP Reference Environmental Alert Notification 6.8 Does your site treat wastes on-site prior to off-site disposal? Yes No

If yes, are you required to have a licence or permit do undertake this activity? Yes No N/A

6.9 Does your site burn wastes on-site? Yes No …

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Environmental Audit Process & Methodology Reference Tools - november 2010 introduction … ystem 6. Waste Management

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference 6.10 Does your site bury or dispose of wastes on-site? Yes No

6.11 Does your site use external waste contractors? Yes No isk Assessment S Assessment R isk If yes, is there a choice of which waste contractor company your site can use? Yes No N/A

6.12 If external waste contractors are used, does your site undertake regular Yes No N/A checks/audits of those contractors? GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference 6.13 Are waste contractors required to be licensed by a regulator or local Yes No N/A authority? Audit R equest Audit

6.14 Does your site retain copies of waste contractor licences and permits Yes No N/A on-site? tion tion

6.15 Does your site retain records of off-site transfer, treatment and disposal Yes No N/A of your wastes? r a Pre pa If yes, how often are these retained for? Retention period: GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

If no, does your site know the final destination of its wastes? Yes No N/A

6.16 Does your site provide training to relevant personnel in relation to waste Yes No N/A management? xecution E xecution Audit

6.17 Has your site set any targets in relation to reducing the volume of waste Yes No N/A

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference generated?

6.18 Is your site free from any fines, prosecution or warning by the regulators Yes No in relation to waste issues? If not, please provide details (including reason for fine/prosecution/warning, Audit O ut p uts Audit the date on which it occurred, the cost of any fine/details of any custodial sentence or restriction on site activities and whether the matter has been resolved or is ongoing) ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

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7. Pollution Prevention / Hazardous and Potentially Hazardous Substances

7.1 Does your site store, use or handle hazardous or potentially hazardous Yes No

substances? GSCP Reference Environmental Supplementary Audit Information If yes, what are the main ones? ystem Audit R equest If yes, does it maintain an inventory of those hazardous substances? Yes No N/A

7.2 Does your site have systems or procedures in place that address pollution Yes No N/A

prevention and the management of hazardous and potentially hazardous GSCP Reference Environmental Pre-Audit Employment Site Profile substances? If yes, please describe Pre pa r a

7.3 Is your site required to hold a licence or permit for the hazardous substances Yes No N/A tion present on-site?

If yes, does it hold the requisite licence or permit? Yes No N/A Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions 7.4 Has your site assessed whether any substances stored, used or handled on-site Yes No N/A are prohibited by national or international laws or protocols?

7.5 Does your site maintain up to date safety data sheets (or similar) Yes No N/A for all hazardous substances used on-site? Audit O ut p uts 7.6 Does your site provide training to relevant personnel in relation Yes No N/A to the management and use of hazardous substances? GSCP Reference Environmental Audit Checks

7.7 Has your site set any targets in relation to eliminating or reducing hazardous Yes No N/A substances used on-site?

7.8 Has your site assessed whether polychlorinated biphenyls (PCBs) are present Yes No N/A Gloss in equipment on-site?

… a ry A pp endices GSCP Reference Environmental Alert Notification

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Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction … ystem 7. Pollution Prevention / Hazardous and Potentially Hazardous Substances

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference 7.9 Has your site assessed whether asbestos-containing materials are present Yes No N/A on-site?

7.10 If asbestos containing materials are present, has the site compiled an Yes No N/A isk Assessment S Assessment R isk asbestos register (or similar)? If yes, please provide details GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

7.11 Are there any above ground or underground bulk storage tanks present Yes No on-site? Audit R equest Audit If yes, please describe number, size and substance stored tion tion

7.12 If above ground tanks are present on-site, are they provided with secondary Yes No N/A containment or equivalent? r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference 7.13 Does your site conduct integrity testing of bulk storage tanks? Yes No N/A

If yes, please describe the frequency of testing and when the last testing was carried out

xecution E xecution Audit 7.14 Does your site have emergency spill response (e.g. spill kits, spill response Yes No N/A team etc.)? If yes, please describe GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

7.15 Have there been any instances of incidents/spills of hazardous or potentially Yes No Audit O ut p uts Audit hazardous materials on-site (or of off-site incidents caused by your site’s activities) in the past two years? If yes, please provide details ry a ry Gloss 7.16 Is your site free from any fines, prosecution or warning by the regulators Yes No in relation to the storage or use of hazardous substances? GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference

GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP If not, please provide details (including reason for fine/prosecution/warning,

the date on which it occurred, the cost of any fine/details of any custodial sentence or restriction on site activities and whether the matter has been A pp endices resolved or is ongoing) GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

16_Global Social Compliance Programme GSCP Reference Environmental Audit Report GSCP Reference Environmental Self Assessment Questionnaire introduction

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

8. Major Incident Management

8.1 Have there been any major incidents at your site in the past 2 years? Yes No

If yes, please provide details GSCP Reference Environmental Supplementary Audit Information ystem

8.2 Is your site required to hold a permit/licence or be notified to the authorities Yes No Audit R equest given the potential for a major incident?

8.3 Does your site have a site emergency response plan and/or procedure? Yes No N/A GSCP Reference Environmental Pre-Audit Employment Site Profile 8.4 Are people trained in what to do in an emergency? Yes No Pre pa r a 8.5 Are local communities or emergency services involved in the development Yes No N/A or review of the plan? tion 8.6 Has your site communicated the emergency response plan to those parties Yes No N/A that could be impacted? If yes, please provide brief details Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions

8.7 Are drills or major incident scenarios practised? Yes No N/A

8.8 Is your site free from any fines, prosecution or warning by the regulators Yes No in relation to any major incidents on-site or caused by the site?

If not, please provide details (including reason for fine/prosecution/warning, Audit O ut p uts the date on which it occurred, the cost of any fine/details of any custodial sentence or restriction on site activities and whether the matter has been GSCP Reference Environmental Audit Checks resolved or is ongoing) Gloss a ry A pp endices GSCP Reference Environmental Alert Notification

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Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem 9. Contaminated Land/Soil and Groundwater Pollution Prevention

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference 9.1 Has your site assessed the site sensitivity and potential pathways and Yes No receptors in the vicinity of the employment site? If yes, please briefly describe the sensitivity of the site isk Assessment S Assessment R isk

9.2 Has your site identified any known impact to soil and groundwater Yes No from current activities/operations (is there soil and/or groundwater

GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference contamination)?

9.3 Has your site undertaken any previous intrusive soil and groundwater Yes No Not required Audit R equest Audit investigations? If yes, please provide brief details of the extent and nature of the investigations tion tion

9.4 If yes to 9.3 has any soil and groundwater contamination been identified? Yes No N/A r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference 9.5 Is your site aware of any legal requirements in relation to contaminated Yes No land?

If yes, does this include an awareness of the requirements in relation to the Yes No N/A assessment, investigation, remediation and soil and groundwater pollution prevention? xecution E xecution Audit 9.6 Does your site provide training to relevant personnel in relation Yes No N/A to the prevention of soil and groundwater pollution? GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

9.7 Is your site free from any fines, prosecution or warning by the regulators Yes No in relation to soil or groundwater contamination? If not, please provide details (including reason for fine/prosecution/warning,

Audit O ut p uts Audit the date on which it occurred, the cost of any fine/details of any custodial sentence or restriction on site activities and whether the matter has been resolved or is ongoing) ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

18_Global Social Compliance Programme GSCP Reference Environmental Audit Report GSCP Reference Environmental Self Assessment Questionnaire introduction

Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

10. Land Use and Biodiversity

10.1 Has your site assessed the potential impacts of the site operations Yes No

on designated protected areas or the ecosystem (plants, animals GSCP Reference Environmental Supplementary Audit Information and microorganisms)? ystem

10.2 Is your site aware of the legal requirements in relation to land use Yes No and biodiversity that apply to the employment site? Audit R equest

10.3 Is the site required to hold a permit/licence in relation to land use Yes No or biodiversity issues? GSCP Reference Environmental Pre-Audit Employment Site Profile 10.4 Are there any identified protected habitats or species on the employment site Yes No or in the immediate surrounding areas?

If yes, please briefly describe Pre pa r a tion 10.5 Has your site implemented any control measures to minimise impacts Yes No to biodiversity?

If yes, please provide brief details Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions

10.6 Does your site provide training to relevant personnel on land use Yes No and biodiversity issues?

10.7 Does your site assess land use implications and legal requirements when Yes No planning major on-site projects or expansions? Audit O ut p uts

10.8 Is your site free from any fines, prosecution or warning by the regulators Yes No GSCP Reference Environmental Audit Checks in relation to land use or impacts on biodiversity? If not, please provide details (including reason for fine/prosecution/warning, the date on which it occurred, the cost of any fine/details of any custodial sentence or restriction on site activities and whether the matter has been resolved or is ongoing) Gloss a ry A pp endices GSCP Reference Environmental Alert Notification

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Appendix 1: GSCP Reference Environmental Self Assessment Questionnaire

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem 11. Nuisance

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference 11.1 Has your site identified where there is the potential for nuisance could be Yes No caused by on-site operations?

11.2 If yes to 11.1, what sources (e.g. noise, dust, odour, visual, litter) of potential Types of nuisance: isk Assessment S Assessment R isk nuisance has your site identified and assessed?

11.3 Has your site assessed potential nuisance that might arise from non-routine Yes No

GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference or out of hours’ operations/activities?

11.4 Does your site have systems or procedures in place that manage/reduce Yes No Audit R equest Audit the potential for the site to cause nuisance?

11.5 Has your site received any instances of nuisance or complaints relating to Yes No tion tion on-site activities in the last 2 years? If yes, please provide details as to the nature and extent of these r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference If yes, does your site maintain a log of nuisance/complaints? Yes No

11.6 Does your site provide training to relevant personnel in how to reduce Yes No the potential for nuisance and complaints?

11.7 Is your site free from any fines, prosecution or warning by the regulators in Yes No xecution E xecution Audit relation to nuisance or complaints? If not, please provide details (including reason for fine/prosecution/warning, the date on which it occurred, the cost of any fine/details of any custodial GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

sentence or restriction on site activities and whether the matter has been resolved or is ongoing) Audit O ut p uts Audit ry a ry Gloss END OF QUESTIONNAIRE GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

20_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 2 R isk Assessment S GSCP Reference

Environmental GSCP Reference Environmental Supplementary Audit Information Pre-Audit Employment ystem Audit R equest Site Profile GSCP Reference Environmental Pre-Audit Employment Site Profile

This tool forms part of the GSCP set of reference tools Recommended timeframe: designed to provide a common interpretation of local and Pre pa r a • the auditor should supply the pre-audit employment site international environmental standards and requirements and profile questionnaire to the employment site within five environmental reference codes (if available and applicable).

working days of the audit being confirmed; tion The Environmental Reference Requirements reflect a common understanding of good environmental practice and • the pre-audit employment site profile questionnaire should are applicable to all raw material processing, agricultural, be completed and returned to the auditor two weeks from manufacturing and logistics sites in the supply chain. The the date of the request being made; Audit E xecution

Environmental Reference Requirements provide a model GSCP Reference Environmental of Findings and Corrective Summary Actions • if an audit is requested and scheduled in less than two for a site in the supply chain to demonstrate continuous weeks, the auditor and employment site should work improvement in its environmental performance from basic together to ensure the pre-audit employment site profile compliance to leading-edge performance (across three is returned as soon as possible and in any event before the defined ‘levels’ for eleven different performance areas). audit is carried out. The reference tools on Environmental Audit Process and

Methodology are based on the GSCP Environmental Audit O ut p uts Reference Requirements but can be adopted and tailored to Note on updates other codes of environmental practice. GSCP Reference Environmental Audit Checks When an audit request is made, the auditor should send the It will be agreed between the buying company, the auditor employment site a PRE-AUDIT EMPLOYMENT SITE PROFILE and the site as to whether a full pre-audit profile would be questionnaire asking for general information about location, required each time, or whether just an update of information size, production processes and activities and various that had changed would be needed. Gloss environmental matters. This information allows auditors to: A pre-audit employment site profile should have four main areas:

• prepare relevant briefing materials (industry or country- a ry specific); 1. company Overview; • plan the assessment, for example the required number of 2. employment Site Details; audit days; A pp endices 3. environmental Matters; • focus the audit on priority or higher risk areas and topics.

4. subcontractor Details. GSCP Reference Environmental Alert Notification The audit company should communicate the following to each employment site to be audited and any relevant parties, Where the employment site itself is the audit requestor, the such as agents, in the supply chain: auditor should ensure that an agreement is in place with the employment site to allow the auditor to communicate audit • the importance of accuracy in completing in the pre-audit findings and any alert notifications to any buyers, brands or employment site profile; retailers concerned. • timeframe for completion of the pre-audit employment site profile; • to whom to send the completed pre-audit employment site profile.

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Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem 1. Company Overview GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

Where possible, the pre-audit employment site profile should detail the following overview of the company.

isk Assessment S Assessment R isk Company Overview GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference Name of company which owns the employment site to be audited:

Registered head office address:

Audit R equest Audit Mailing address of company (if different to that of the employment site):

tion tion Telephone number:

Fax number: r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference Ownership type (e.g. joint venture, partnership, corporation, foreign investment, other):

Year company formed:

Business licence No. (if applicable) xecution E xecution Audit Does the company own any other employment sites? GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

If yes, how many? Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

02_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S 2. Employment Site Details GSCP Reference Environmental Supplementary Audit Information 2.1 Employment Site Contact Details ystem

The pre-audit employment site profile questionnaire should request the following contact information. Audit R equest

2.1 Employment Site Contact Details GSCP Reference Environmental Pre-Audit Employment Site Profile

Employment site name:

Full address:

Full address Pre pa r a (in local language, if applicable):

Country tion

Is this site in an Export Processing Yes No Zone (EPZ)? Audit E xecution

Employment site telephone number: GSCP Reference Environmental of Findings and Corrective Summary Actions

Employment site fax number:

Employment site email address:

Reception opening hours’, if applicable

Employment site manager: Audit O ut p uts

Languages of the employment site GSCP Reference Environmental Audit Checks management: Please list the main languages spoken by employment site managers:

Key audit contact: Gloss Key contact job title: a ry Key contact telephone number:

Key contact email address A pp endices

Name of person completing this questionnaire (if different to key audit contact): GSCP Reference Environmental Alert Notification

Telephone number of person completing this questionnaire:

Email address of person completing this questionnaire:

Employment site website (if available):

Closest airport/railway station:

Distance from the above: please specify time and distance plus traffic conditions if relevant

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Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem 2.2 Employment Site Environmental Management

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference The following information is requested to understand internal environmental management systems...

2.2 Employment Site Environmental Management

isk Assessment S Assessment R isk Name and job title of person Name:

GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference responsible for environmental issues: Job Title:

Does the site have an environmental Yes No policy?

Audit R equest Audit Has the site developed an Yes No environmental management system?

tion tion If yes, is the site’s environmental Yes No management system certified to a recognised standard, e.g. 14001, EMAS, etc. r a Pre pa If yes, please state which standard GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

Is there an environmental committee Yes No on-site?

Are internal environmental audits ever Yes No carried out? If so, please state by whom xecution E xecution Audit and the date of the most recent audit

Are environmental audits ever carried Yes No

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference out by external companies/third parties? If so, please state by whom and the date of the most recent audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

04_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

2.3 Employment Site Area, Location and Surrounding Land Uses

The pre-audit employment site profile questionnaire should detail the following information concerning the size ofthe employment site, its location and surrounding land uses. GSCP Reference Environmental Supplementary Audit Information ystem Where relevant, the employment site should be asked to submit a site plan.

2.3 Employment Site Size, Location & Surrounding Land uses Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile What is the employment site size?

acres/hectares/m2 (please state units used)

Approximately, what area of the site is covered by buildings (%): Pre pa r a

What age are the buildings on-site (if known)? tion Is the site owned or leased? Owned Leased If leased, who is the landlord? Landlord: Audit E xecution

Are there any other parties on site as tenants Yes No GSCP Reference Environmental of Findings and Corrective Summary Actions or sub-tenants? If yes, please name them

Describe surrounding land use (residential, industrial, rural etc.) and identify neighbouring Audit O ut p uts facilities and types: GSCP Reference Environmental Audit Checks North:

South: Gloss East: a ry West:

… A pp endices GSCP Reference Environmental Alert Notification

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Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction … ystem 2.3 Employment Site Size, Location & Surrounding Landuses

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference State the distance to, and size of the nearest residential community and sensitive sites (e.g. schools, hospitals, etc.)

isk Assessment S Assessment R isk Are there any sensitive habitats nearby, Yes No

GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference such as nature reserves, national parks, wetlands or sites of special scientific interest? If yes, please describe

Audit R equest Audit Briefly describe the geology beneath the site (if known)

tion tion What is the location of the nearest surface water Name of water course: courses? Distance and direction from site:

r a Pre pa Use: Official grade of water quality if applicable/known GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

Name of water course: Distance and direction from site: Use:

xecution E xecution Audit Official grade of water quality if applicable/known

Are there any boreholes/wells or natural springs Yes No GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

either on-site or in the surrounding area?

If yes, please provide the following information: Well, Borehole or Spring:

Audit O ut p uts Audit Location: Use: ry a ry Well, Borehole or Spring:

Gloss Location: Use: GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

06_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

2.4 Employment Site Production and Processes Overview

The pre-audit employment site profile should detail the following information concerning the employment site’s production systems and production processes. Some employment sites may not be willing to provide some of the information requested GSCP Reference Environmental Supplementary Audit Information ystem because of confidentiality agreements with other customers.

2.4 Employment Site Production Systems and Processes Audit R equest

Industry sector: GSCP Reference Environmental Pre-Audit Employment Site Profile

Principal products:

Main export markets: Pre pa r a Main production processes:

Main production equipment: tion

Main raw materials used: Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions Hazardous chemicals used on-site:

Does the site produce electrical or Yes No N/A electronic products? If yes, please state which products Audit O ut p uts GSCP Reference Environmental Audit Checks

Does your site use any of the following Yes No N/A materials in its products (or their components): • Lead • Mercury Gloss • Hexavalent chromium

• Cadmium a ry • Polybrominated biphenyls • Polybrominated diphenyl ethers A pp endices If yes, please state which GSCP Reference Environmental Alert Notification …

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Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction … ystem 2.4 Employment Site Production Systems and Processes

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference Are any of the following present on-site:

Boilers Yes No N/A isk Assessment S Assessment R isk Air compressors Yes No N/A GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Cooling towers or evaporative Yes No N/A condensers

Electrical substations/transformers/ Yes No N/A

Audit R equest Audit switch-gear

Air conditioning equipment Yes No N/A tion tion Automated gas fire suppression Yes No N/A systems (e.g. halon systems) r a Pre pa Operational Times Yes No N/A GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

Number of operational weeks per Yes No N/A year:

Number of operational days per week: Yes No N/A xecution E xecution Audit Typical hours of operation: GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

Scheduled site shut-downs: Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

08_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

2.5 Employment Site Workforce

The following information is an essential requirement, both to understand potential risks posed by the employment site’s operations and to plan for the audit. Any missing details should be clarified with the employment site directly. GSCP Reference Environmental Supplementary Audit Information ystem

2.5 Employment Site Workforce

Total number of workers Audit R equest

at the employment site: GSCP Reference Environmental Pre-Audit Employment Site Profile

Of which, how many are permanent workers?

And how many are temporary

or agency workers? Pre pa r a

Language(s) spoken

Please detail the different native tion languages of the workforce Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions Nationality of workers Please detail the different nationalities of the workforce Audit O ut p uts Does the site use contractors Yes No N/A to perform any activities on-site? If yes, please provide a brief overview GSCP Reference Environmental Audit Checks of contracted activities Gloss a ry A pp endices GSCP Reference Environmental Alert Notification

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Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem 3. Environmental Matters GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

Where possible, the pre-audit employment site profile should detail the following information relation to environmental matters at the employment site. isk Assessment S Assessment R isk

GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference 3.1 Environmental Matters

Environmental permitting

Is the facility subject to any integrated Yes No environmental operating permits?

Audit R equest Audit If yes, what are the particular processes/activities or quantities of chemicals stored at the site which attract this permitting requirement? tion tion

When was the permit granted and on what date will it require renewal? r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference Are any changes planned in the next Yes No 5 years which will require a new permit or existing permit modification? If yes, please describe xecution E xecution Audit Energy

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Which of the following sources of energy are used on-site:

Mains gas Yes No

Audit O ut p uts Audit Liquefied petroleum gas Yes No

Mains electricity Yes No ry a ry

On-site generated electricity Yes No Gloss Fuel oil (or gas oil) Yes No GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference

GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Coal Yes No

A pp endices Timber Yes No

Other Yes No (please specify)

… GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

10_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S …

Water

Which of the following sources of water are used on-site: GSCP Reference Environmental Supplementary Audit Information ystem Municipal mains water Yes No

Groundwater Yes No

(from wells/boreholes) Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile

Surface water Yes No (e.g. from river, lake, pond etc.)

Other Yes No (please specify) Pre pa r a

Wastewater tion

Which of the following types and/or sources of wastewaters are generated at the facility? Audit E xecution

Process wastewater Yes No GSCP Reference Environmental of Findings and Corrective Summary Actions (i.e. water that comes into contact with the process or product)

Non-contact water Yes No (i.e. heat exchanged cooling water)

Sanitary wastewater Yes No Audit O ut p uts (i.e. domestic wastewater) GSCP Reference Environmental Audit Checks

Surface water Yes No (i.e. storm water run-off/ rainwater run-off)

Are there any of the following on-site: Gloss

Oil or petrol interceptors Yes No N/A a ry

Septic tanks Yes No N/A A pp endices

Wastewater lagoons Yes No N/A GSCP Reference Environmental Alert Notification Soakaways? Yes No N/A

Is there a wastewater treatment Yes No N/A plant on-site? If yes, which type of wastewater treatment (biological, chemical..)?

Are any discharges subject to permit/ Yes No N/A consent by local or state authorities? If yes, please provide details …

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Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction … ystem Emissions to air

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference Does the employment site generate Yes No N/A emissions to air? If yes, please describe isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Is the facility subject to any licenses Yes No N/A for atmospheric emissions?

Are there abatement or pollution Yes No N/A prevention devices (e.g. filters, Audit R equest Audit scrubbers) on point source emissions to air? If so, please describe the abatement

tion tion techniques employed at the site r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference Are any materials burnt or incinerated Yes No N/A

on site?

Does the site use any ozone-depleting Yes No N/A substances in equipment or processes on site? If yes, please describe xecution E xecution Audit GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

Waste management

Please list the main hazardous wastes generated on-site Audit O ut p uts Audit ry a ry Please list the main non-hazardous wastes generated on-site Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference

GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Is the facility subject to any licences, Yes No permits or similar for waste handling, storage, treatment or disposal? A pp endices

Are wastes treated in any way Yes No on site (e.g. incineration, burning, on-site lagoons)? If yes, please describe

… GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

12_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S …

Have any of these activities been Yes No carried out in the past? If yes, please describe GSCP Reference Environmental Supplementary Audit Information ystem

Are wastes disposed to landfill Yes No on site and/or has on-site dumping Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile taken place in the past? If yes, please provide details

Does the on-site disposal facility Yes No accept waste from other sources? Pre pa r a If yes, please provide details tion

What wastes, if any, are recycled? Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions

Hazardous materials

Are any radioactive materials used Yes No N/A on-site? Audit O ut p uts Are any wastes generated on-site Yes No N/A which contain radioactive materials GSCP Reference Environmental Audit Checks

How are radioactive materials disposed of? Gloss

Is asbestos present on-site? Yes No N/A a ry

Has an asbestos survey ever been Yes No N/A

carried out? A pp endices

Have asbestos materials been Yes No N/A

removed from site historically? GSCP Reference Environmental Alert Notification

Is asbestos used in site products? Yes No N/A

Are any CMR materials (Carcinogenic, Yes No N/A Mutagenic, Toxic to Reproduction) used? …

Global Social Compliance Programme_13

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction … ystem Complaints and enforcement

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference Have neighbours or the public complained about nuisance/visual impact from any of the following:

Noise Yes No isk Assessment S Assessment R isk Site aesthetics Yes No GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Lighting at night Yes No

Litter Yes No

Audit R equest Audit Waste materials storage Yes No

Dust Yes No tion tion Vehicle movements Yes No r a Pre pa Other (describe) Yes No GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference If yes, please provide details

Are there any regulatory enforcement Yes No xecution E xecution Audit actions or prosecutions outstanding which relate to the above? If yes, please provide details GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

… Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

14_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S …

Soil and groundwater contamination

Is there soil and/or groundwater Yes No

contamination present on-site? GSCP Reference Environmental Supplementary Audit Information If yes, please provide details ystem Audit R equest

Have any intrusive investigations been Yes No GSCP Reference Environmental Pre-Audit Employment Site Profile performed? If yes, please provide details

Are there potential sources of soil Yes No Pre pa r a and/or groundwater contamination from neighbouring properties?

If yes, please describe tion Audit E xecution

Are regulatory authorities aware Yes No GSCP Reference Environmental of Findings and Corrective Summary Actions of any contamination on-site? If yes, please provide details

Has the facility carried out Yes No Audit O ut p uts (or are there plans to undertake) any site remediation or clean-up programme? GSCP Reference Environmental Audit Checks If yes, please provide details Gloss a ry A pp endices GSCP Reference Environmental Alert Notification

Global Social Compliance Programme_15

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem 3.2 Details of previous environmental audits and outcomes

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference This section provides the audit history of the employment site. This information helps determine the type of audit required and

whether a current audit report can be shared.

3.2 Employment Site Previous Environmental Audits and Outcomes isk Assessment S Assessment R isk

GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference Has your employment site previously been Yes No

audited in relation to environmental issues?

If yes, please provide details of previous audits: Date of audit Code or standard Auditing company/ audited against organisation Audit R equest Audit tion tion

Would you be prepared to share previous Yes No r a Pre pa audit reports and, improvement/action plans conducted for other customers? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

Have any previous corrective actions been Yes No completed?

Please detail outstanding corrective actions Issue found Corrective Timescale Person and your expected completion date? action responsible xecution E xecution Audit GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP

A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

16_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 2: GSCP Reference Environmental Pre-Audit Employment Site Profile

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S 4. Subcontracting GSCP Reference Environmental Supplementary Audit Information ystem 4.1 Products/processes subcontracted overview

The pre-audit employment site profile should detail the following information on the products and/or processes that are Audit R equest subcontracted by the employment site: GSCP Reference Environmental Pre-Audit Employment Site Profile

4.1 Products/Processes Subcontracted

List any production or processes sub-contracted: Pre pa r a

Subcontractor details: Please complete the table below for each process subcontracted. Add more tables as required. tion Subcontracted Process: Process 1

Products involved: Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions No. of subcontracting companies:

Is the concern for the environment part of the subcontractors Yes No selection criteria?

Have you audited these contractors? Yes No Audit O ut p uts If yes, against which code of conduct/requirements? GSCP Reference Environmental Audit Checks

Subcontracted Product: Process 2

Process: Gloss

No. of subcontracting companies: a ry

Have you audited these contractors? Yes No A pp endices

Subcontracted Product: Process 3 GSCP Reference Environmental Alert Notification Process:

No. of subcontracting companies:

Have you audited these contractors? Yes No

Global Social Compliance Programme_17 introduction ystem

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference Appendix 3

isk Assessment S Assessment R isk GSCP Reference GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference Environmental Audit Checks Audit R equest Audit This tool forms part of the GSCP set of reference tools The reference AUDIT CHECKS have been designed to provide designed to provide a common interpretation of local and auditors with the minimum requirements regarding audit

tion tion international environmental standards and requirements and methodology and evidence gathering. The audit checks are environmental reference codes (if available and applicable). structured around the 11 Performance Areas and include The Environmental Reference Requirements reflect a guidance on: common understanding of good environmental practice and r a Pre pa • physical employment site inspection; are applicable to all raw material processing, agricultural,

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference manufacturing and logistics sites in the supply chain. The • employment site procedures and processes; Environmental Reference Requirements provide a model • interviews; for a site in the supply chain to demonstrate continuous improvement in its environmental performance from basic • document checks. compliance to leading-edge performance (across three This document is not intended as a checklist but as a list of GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference defined ‘levels’ for eleven different performance areas).

checks that should be used as guidance by auditors whilst xecution E xecution Audit The Reference tools on Environmental Audit Process not limiting audit activities. and Methodology are based on the GSCP Environmental Reference Requirements but can be adopted and tailored to For your reference, you can make a note when a particular other codes of environmental practice. point has been noted or question asked by ticking the box down the left hand side. Where a particular requirement is being met you can also make note of this. Also, you can modify its format and layout to better suit your working

Audit O ut p uts Audit methodology, e.g. by adding dedicated pages for note-taking. ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

01_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile No es Y Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification s Environmental Environmental management and environmental performance targets are designed to improve or sustain the environment and local ecosystem, or global when appropriate Understanding and awareness of significant environmental aspects and impacts (negative and positive) aspects and impacts (negative environmental of significant and awareness Understanding requirements legal of applicable and awareness Understanding requirements legal local with applicable - date up - to remain Mechanism to activities management of environmental coordination for responsible Member of management reviewed/improved and continually maintained implemented, documented, (EMS) is established, System Management Environmental The EMS includes: Policy a. Environmental targets and objectives setting risk assessment, b. Planning: environmental control and its training; documentation adequate procedures; operational and operation: c. Implementation audit and inspections and measurement, d. Checking: monitoring Review e. Management onInformation performance is environmental madeavailableto internal appropriate and (pleasetoexternal refer stakeholders the guidance section for detailed definition) leading practice drive to strategy looking environmental Forward k u d it Ch ec Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete 2. 3. 4. in place controls b asic management 5 . 2: Level 6. 7. 8. 3: Level 9. 10.  improvement performance significant to achieve stakeholders relevant with engagement 11. Proactive standards voluntary to commitment relevant, 12. Where and should not limit audit activities. as guidance are intended checks The following A system management 1. Environmental level: each performance at requirements site Employment 1: Level 1.

Global Social Compliance Programme_02

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

N o Audit R equest Audit tion tion r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference m ste xecution E xecution Audit Sy m ent Manage

Audit O ut p uts Audit ry a ry Gloss m ental E n v iron on

GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices h ering G at Ev idence GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference Procedures that have been established to manage site aspects and impacts are being followed aspects and impacts are site manage to been established have that Procedures employee in place (e.g. policies and procedures, are written policies and procedures management Environmental etc.) handbook, induction training, legal local with applicable up-to-date remain mechanism to includes a formal system management The environmental register) (e.g. legal/regulatory requirements the coordination for responsible outlines a member of management system management The environmental responsibilities roles and activities and outlines their management of environmental aspects and impacts (negative the significant consider policies and procedures management Environmental site with the employment associated and positive) associated and positive) aspects and impacts (negative the significant and understands, of, is aware M anagement site with the employment management concerning environmental and regulations of laws is aware M anagement been implemented have that controls management describe the basic environmental M anagement workers to communicated effectively are management environmental regarding and processes Policies for coordination of environmental management activities) to ensure that compliance with applicable laws compliance with applicable that to ensure activities) management of environmental coordination for is maintained and regulations management environmental or endorses promotes actively M anagement stakeholders external and internal to appropriate available is made performance on environmental Information performance in environmental improvement appropriate, where demonstrate, M anagement management in environmental leading practice drive to looking strategy a forward promote M anagement designed are targets performance and environmental management environmental how understand M anagement or global when appropriate ecosystem, and local the environment or sustain improve to performance significant to achieve value chain the down stakeholders with appropriate engages actively The site improvement appropriate where standards, voluntary to a commitment promote M anagement environment can impact the activities and operations, and their site’s they, how understand Workers applicable where permit/licence requirements, of environmental aware are workers Key appropriate induction, where issues at management on environmental training receive Workers required training as specific receive responsibilities management with environmental workers Key anagement provide the appropriate resources (including assigning a member of management responsible responsible (including assigning a member of management resources the appropriate provide M anagement 1.1 Physical employment site inspection site employment 1.1 Physical LE V EL 1 site with the employment impacts and aspects associated the significant has identified the site ❒ Based on observations, ❒  and processes procedures site 1.2 Employment LE V EL 1 ❒  ❒  ❒  ❒  1.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  with document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  …

03_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile N o Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions m ste GSCP Reference Environmental Audit Checks Sy Audit O ut p uts m ent Manage

Gloss a ry m ental E n v iron A pp endices on

GSCP Reference Environmental Alert Notification h ering G at Ev idence Procedures that have been established to manage site aspects and impacts are being followed aspects and impacts are site manage to been established have that Procedures employee in place (e.g. policies and procedures, are written policies and procedures management Environmental etc.) handbook, induction training, legal local with applicable up-to-date remain mechanism to includes a formal system management The environmental register) (e.g. legal/regulatory requirements the coordination for responsible outlines a member of management system management The environmental responsibilities roles and activities and outlines their management of environmental aspects and impacts (negative the significant consider policies and procedures management Environmental site with the employment associated and positive) associated and positive) aspects and impacts (negative the significant and understands, of, is aware M anagement site with the employment management concerning environmental and regulations of laws is aware M anagement been implemented have that controls management describe the basic environmental M anagement workers to communicated effectively are management environmental regarding and processes Policies for coordination of environmental management activities) to ensure that compliance with applicable laws compliance with applicable that to ensure activities) management of environmental coordination for is maintained and regulations management environmental or endorses promotes actively M anagement stakeholders external and internal to appropriate available is made performance on environmental Information performance in environmental improvement appropriate, where demonstrate, M anagement management in environmental leading practice drive to looking strategy a forward promote M anagement designed are targets performance and environmental management environmental how understand M anagement or global when appropriate ecosystem, and local the environment or sustain improve to performance significant to achieve value chain the down stakeholders with appropriate engages actively The site improvement appropriate where standards, voluntary to a commitment promote M anagement environment can impact the activities and operations, and their site’s they, how understand Workers applicable where permit/licence requirements, of environmental aware are workers Key appropriate induction, where issues at management on environmental training receive Workers required training as specific receive responsibilities management with environmental workers Key anagement provide the appropriate resources (including assigning a member of management responsible responsible (including assigning a member of management resources the appropriate provide M anagement 1.1 Physical employment site inspection site employment 1.1 Physical LE V EL 1 site with the employment impacts and aspects associated the significant has identified the site ❒ Based on observations, ❒  and processes procedures site 1.2 Employment LE V EL 1 ❒  ❒  ❒  ❒  1.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  with document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  …

Global Social Compliance Programme_04

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference workers receive training on environmental management issues; and management on environmental training receive • workers and responsibilities roles management their environmental to applicable training receive workers • key Relevant employment site permits and licences that relate to environmental management are available and up to date to up and available are management environmental to relate licences that and permits site employment Relevant environmental to relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the on file retained is the documentation management, policy is available environmental An up-to-date is maintained register legal/regulatory An up-to-date documented and these are and responsibilities roles assigned with environmental are management Relevant employment relevant to made available are the site issues at management environmental address that Procedures personnel site indicate: etc.) matrix training (e.g.records, induction materials Training been documented aspects and impacts have Significant (E M S) has been documented System M anagement The Environmental targets and objectives risk assessments, environmental The E M S includes documented of the E M S, has been audited The E M S, or elements available and are documented of the E M S are reviews M anagement in the management engaged are contractors) and their representatives, workers (management, All personnel their function. to issues according of environmental performance environmental include discussion around stakeholders external and/or with internal Communications designed targets performance environmental and management environmental has identified site The employment to improve or sustain the environment and local ecosystem, or global when appropriate ecosystem, and local the environment or sustain improve to impact ecosystem lower with sources water alternative relevant, and used, if has investigated site The employment leading practice drive to looking strategy a forward has established site The employment standards voluntary to has committed site The employment performance significant achieving that value chain show the through stakeholders with appropriate Communications has been discussed improvement 1.4 Document checks 1.4 Document LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  …

05_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a

tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification workers receive training on environmental management issues; and management on environmental training receive • workers and responsibilities roles management their environmental to applicable training receive workers • key Relevant employment site permits and licences that relate to environmental management are available and up to date to up and available are management environmental to relate licences that and permits site employment Relevant environmental to relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the on file retained is the documentation management, policy is available environmental An up-to-date is maintained register legal/regulatory An up-to-date documented and these are and responsibilities roles assigned with environmental are management Relevant employment relevant to made available are the site issues at management environmental address that Procedures personnel site indicate: etc.) matrix training (e.g.records, induction materials Training been documented aspects and impacts have Significant M S) has been documented (E System M anagement The Environmental targets and objectives risk assessments, environmental The E M S includes documented of the E M S, has been audited The E M S, or elements available and are documented of the E M S are reviews M anagement in the management engaged are contractors) and their representatives, workers (management, All personnel their function. to issues according of environmental performance environmental include discussion around stakeholders external and/or with internal Communications designed targets performance environmental and management environmental has identified site The employment to improve or sustain the environment and local ecosystem, or global when appropriate ecosystem, and local the environment or sustain improve to impact ecosystem lower with sources water alternative relevant, and used, if has investigated site The employment leading practice drive to looking strategy a forward has established site The employment standards voluntary to has committed site The employment performance significant achieving that value chain show the through stakeholders with appropriate Communications has been discussed improvement 1.4 Document checks 1.4 Document LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  …

Global Social Compliance Programme_06

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

N o No Audit R equest Audit es Y tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference )

H G s (G GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference G ases xecution E xecution Audit G reen h ouse and

Audit O ut p uts Audit ry a ry , T ransport , Gloss y U se y GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference E nerg on

A pp endices h ering G at Ev idence GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference Based on observations, the site has established procedures to manage energy use, transport and greenhouse gases and greenhouse use, transport energy to manage procedures has established the site Based on observations, etc.) activities of substances, (e.g. management being followed are been established have and G H emissions management use, transport to energy in relation and procedures Policies etc.) training, handbook, induction employee (e.g. policies and procedures, written and implemented E M S use and G H emissions as per the site and audit energy manage in place to and processes systems Formal and G H emissions compliance use, transport concerning energy and regulations of laws is aware M anagement workers to communicated effectively and G H emissions are use, transport energy regarding and processes Policies of G H emissions is tracked calculation the and how consumption energy of how is aware M anagement and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained Meet legal requirements legal Meet maintained held and compliance permits are - date up - to Relevant, transport on - site of G H emissions including fuel use for consumption/calculation of energy Tracking EMS use and G H emissions as per the site and audit energy manage in place to and processes systems Formal stakeholders and external internal appropriate to made available emissions) are vehicle gas emissions (including on - site and greenhouse consumption Energy improvement continuous drive to basis annual an on least at established/reviewed are (normalised) targets reduction emission G H and targets use energy Renewable improvement continuous to drive on an annual basis reviewed which are emissions reduction, vehicle include on - site Targets resources energy of local availability within is sustainable level consumption a. Energy practice standard international recognised beyond and G H emission targets and fuel efficiency energy of stretching achievement b. D emonstrable 2.1 Physical employment site inspection site employment 2.1 Physical LE V EL 1 ❒  and processes procedures site 2.2 Employment LE V EL 1 ❒  ❒  2.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete

2 . 3. 2: Level 4. 5. 6. 7. definition) for further to the guidance section refer (normalised; please in energy reduction d emonstrable 8. 3: Level 9. to the guidance section) refer please further definition (for gas (G H G) intensity reduce greenhouse to mechanisms in place l eading practice G H intensity with lower sources 10. Use of energy reduce G H emissions to ways chain identifying the value down stakeholders with appropriate 11. Engagement system in business 12. Carbon accounting fleet distribution for and technologies of vehicle types, fuels combinations efficient environmentally of the most 13. Specification fleet entire for the improvement continuous to drive on an annual basis reviewed are targets reduction vehicle emission and 14. Fuel consumption and should not limit audit activities. as guidance are intended checks The following 2. Energy use, transport and Greenhouse Gases (G H Gs) and Greenhouse use, transport 2. Energy level: each performance at requirements site Employment 1 : Level 1.

07_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile N o No es Y Pre pa r a tion Audit E xecution ) GSCP Reference Environmental of Findings and Corrective Summary Actions H G s (G G ases GSCP Reference Environmental Audit Checks Audit O ut p uts G reen h ouse and

Gloss a ry , T ransport , y U se y A pp endices GSCP Reference Environmental Alert Notification E nerg on

h ering G at Ev idence Based on observations, the site has established procedures to manage energy use, transport and greenhouse gases and greenhouse use, transport energy to manage procedures has established the site Based on observations, etc.) activities of substances, (e.g. management being followed are been established have and G H emissions management use, transport to energy in relation and procedures Policies etc.) training, handbook, induction employee (e.g. policies and procedures, written and implemented E M S use and G H emissions as per the site and audit energy manage in place to and processes systems Formal and G H emissions compliance use, transport concerning energy and regulations of laws is aware M anagement workers to communicated effectively and G H emissions are use, transport energy regarding and processes Policies of G H emissions is tracked calculation the and how consumption energy of how is aware M anagement and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained Meet legal requirements legal Meet maintained held and compliance permits are - date up - to Relevant, transport on - site of G H emissions including fuel use for consumption/calculation of energy Tracking EMS use and G H emissions as per the site and audit energy manage in place to and processes systems Formal stakeholders and external internal appropriate to made available emissions) are vehicle gas emissions (including on - site and greenhouse consumption Energy improvement continuous drive to basis annual an on least at established/reviewed are (normalised) targets reduction emission G H and targets use energy Renewable improvement continuous to drive on an annual basis reviewed which are emissions reduction, vehicle include on - site Targets resources energy of local availability within is sustainable level consumption a. Energy practice standard international recognised beyond and G H emission targets and fuel efficiency energy of stretching achievement b. D emonstrable 2.1 Physical employment site inspection site employment 2.1 Physical LE V EL 1 ❒  and processes procedures site 2.2 Employment LE V EL 1 ❒  ❒  2.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete

2 . 3. 2: Level 4. 5. 6. 7. definition) for further to the guidance section refer (normalised; please in energy reduction d emonstrable 8. 3: Level 9. to the guidance section) refer please further definition (for gas (G H G) intensity reduce greenhouse to mechanisms in place l eading practice G H intensity with lower sources 10. Use of energy reduce G H emissions to ways chain identifying the value down stakeholders with appropriate 11. Engagement system in business 12. Carbon accounting fleet distribution for and technologies of vehicle types, fuels combinations efficient environmentally of the most 13. Specification fleet entire for the improvement continuous to drive on an annual basis reviewed are targets reduction vehicle emission and 14. Fuel consumption and should not limit audit activities. as guidance are intended checks The following 2. Energy use, transport and Greenhouse Gases (G H Gs) and Greenhouse use, transport 2. Energy level: each performance at requirements site Employment 1 : Level 1.

Global Social Compliance Programme_08

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference workers receive training on energy use, transport and G H issues; use, transport on energy training receive • workers and responsibilities and G H Gs roles use, transport their energy to applicable training receive workers • key and up to date and up to use, to energy relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the held on file and G H Gs, these are transport site employment relevant to made available are the site and G H Gs at use, transport energy address that Procedures personnel tracked is recorded, data transport on-site of G H emissions including fuel use for consumption/calculation Energy and documented for the potential has also considered The site air is maintained. emissions to sources of main point An inventory emissions fugitive indicate: etc.) matrix training (e.g.records, induction materials Training anagement actively promotes or endorses proactive energy conservation energy proactive or endorses promotes actively M anagement target reduction emission transport the on-site reviewing and improvement driving continuous are The management on an annual basis use and G H energy renewable reviewing through improvement continuous driving proactively are M anagement on an annual basis targets emission reduction vehicle emissions) gas emissions (including on-site and greenhouse consumption energy ensures site The employment stakeholders and external internal relevant to is made available data and that use performance in energy improvement appropriate, where demonstrates, site The employment targets use and G H emission reduction energy renewable it is achieving energy of sustainable the concept understands management G H intensity, with lower sources energy For resources energy of local availability within consumption efficiency and fuel to energy relation is in practice standard international recognised what understand M anagement those practices exceed that targets site set and have their sector/geography for and G H emission targets fuel reviewing through fleet transport entire in the improvement continuous driving proactively are M anagement on an annual basis targets reduction vehicle emission and consumption reduce G H to ways to identify value chain the down stakeholders with appropriate engages actively The site emissions intensity mechanisms gas greenhouse practice of leading the implementation promotes actively M anagement use can impact energy activities and operations, and their site’s they, of how understanding a general have Workers emissions gas and greenhouse specific receive responsibilities emissions management gas and greenhouse use, transport with energy workers Key as required training where emissions procedures, gas and greenhouse use, transport energy and understand, access to, have Workers appropriate available and G H Gs are use, transport energy to relate permits and licences that site employment Relevant ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  with document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  applicable where emissions permit/licence requirements, gas use and greenhouse of energy aware are workers ❒ Key appropriate induction, where emission issues at gas use and greenhouse on energy training receive ❒ Workers ❒  ❒  checks 2.4 Document LE V EL 1 ❒  …

09_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification workers receive training on energy use, transport and G H issues; use, transport on energy training receive • workers and responsibilities and G H Gs roles use, transport their energy to applicable training receive workers • key and up to date and up to use, to energy relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the held on file and G H Gs, these are transport site employment relevant to made available are the site and G H Gs at use, transport energy address that Procedures personnel tracked is recorded, data transport on-site of G H emissions including fuel use for consumption/calculation Energy and documented for the potential has also considered The site air is maintained. emissions to sources of main point An inventory emissions fugitive indicate: etc.) matrix training (e.g.records, induction materials Training anagement actively promotes or endorses proactive energy conservation energy proactive or endorses promotes actively M anagement target reduction emission transport the on-site reviewing and improvement driving continuous are The management on an annual basis use and G H energy renewable reviewing through improvement continuous driving proactively are M anagement on an annual basis targets emission reduction vehicle emissions) gas emissions (including on-site and greenhouse consumption energy ensures site The employment stakeholders and external internal relevant to is made available data and that use performance in energy improvement appropriate, where demonstrates, site The employment targets use and G H emission reduction energy renewable it is achieving energy of sustainable the concept understands management G H intensity, with lower sources energy For resources energy of local availability within consumption efficiency and fuel to energy relation is in practice standard international recognised what understand M anagement those practices exceed that targets site set and have their sector/geography for and G H emission targets fuel reviewing through fleet transport entire in the improvement continuous driving proactively are M anagement on an annual basis targets reduction vehicle emission and consumption reduce G H to ways to identify value chain the down stakeholders with appropriate engages actively The site emissions intensity mechanisms gas greenhouse practice of leading the implementation promotes actively M anagement use can impact energy activities and operations, and their site’s they, of how understanding a general have Workers emissions gas and greenhouse specific receive responsibilities emissions management gas and greenhouse use, transport with energy workers Key as required training where emissions procedures, gas and greenhouse use, transport energy and understand, access to, have Workers appropriate available and G H Gs are use, transport energy to relate permits and licences that site employment Relevant ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  with document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  applicable where emissions permit/licence requirements, gas use and greenhouse of energy aware are workers ❒ Key appropriate induction, where emission issues at gas use and greenhouse on energy training receive ❒ Workers ❒  ❒  checks 2.4 Document LE V EL 1 ❒  …

Global Social Compliance Programme_10

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference of local energy sources) energy of local reduce G H intensity to mechanisms leading practice has implemented site The employment being achieved and are stretching are targets Air quality improvement reduce G H to ways identifying that value chain show the through stakeholders with appropriate Communications been discussed emissions have being achieved and are stretching are and G H emission targets and fuel efficiency Energy of vehicle combinations efficient environmentally most the of specifications the documented has site employment The fleet distribution for types, fuels and technologies Reviews of on-site vehicle emissions reduction targets undertaken and available and undertaken targets emissions reduction vehicle of on-site Reviews available and (normalised) undertaken targets and G H emission reduction use targets energy of renewable Reviews recognised TCE, CCl4 in line with halons, phase-out use of specific types ODS, such as CFCs, in place to Targets practice standard international energy of reducing achievement has made demonstrable site the employment how a short summary as to Provide of meeting achievement has made demonstrable site the employment how a short summary as to Provide (normalised) targets air quality improvement or exceeding available are and are undertaken targets reduction vehicle emission and of fuel consumption Reviews availability to the relation (in are sustainable levels consumption energy that has confirmed site The employment ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  …

11_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile No es Y Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification Meet legal requirements legal Meet maintained held and compliance permits are - date up - to Relevant, is undertaken consumption of water Measurement EMS as per the site consumption and audit water manage in place to and processes systems Formal stakeholders external and internal relevant to available made are data consumption Water improvement continuous to drive on an annual basis reviewed are targets efficiency consumption Water area catchment water limits and ecosystem within local is sustainable level consumption water relevant, Where impact ecosystem lower with water sources of alternative relevant, of and use, if Investigation Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete

2. 3. 2: Level 4. 5. 6. 7. (normalised) targets efficiency of water achievement d emonstrable 3: Level 8. 9. practice standard international recognised beyond targets efficiency water of stretching achievement 10 . D emonstrable and recycling re - use, recovery efficiency mechanisms in place, including water 11. L eading practice efficiency water improve chain to the value down stakeholders with appropriate 12. Engagement and should not limit audit activities. as guidance are intended checks The following 3. Water use 3. Water level: each performance at requirements site Employment 1: Level 1.

Global Social Compliance Programme_12

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

N o Audit R equest Audit tion tion r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit U se ater W Audit O ut p uts Audit on

ry a ry Gloss h ering G at GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference Ev idence A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference Employment site operations and activities observed are in line with legal requirements relating to water use to relating requirements legal are in line with observed and activities operations site Employment (including water abstraction permit requirements) permit abstraction (including water (e.g. policies and written and implemented established use management water to in relation and procedures Policies etc.) handbook, induction training, employee procedures, E M S as per the site use management, water to in place relation and processes systems Formal compliance use and water concerning and regulations of laws is aware M anagement workers to communicated effectively use are water regarding and processes Policies and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained conservation water proactive or endorses promotes actively M anagement anagement are proactively driving continuous improvement through reviewing water consumption efficiency consumption water reviewing through improvement continuous driving proactively are M anagement on an annual basis targets external and internal relevant to available is made data consumption water ensures site The employment stakeholders and that use and performance in water improvement appropriate, where demonstrates, site The employment targets efficiency water it is achieving water limits and ecosystem within the local consumption water of sustainable the concept understands M anagement area catchment impact ecosystem lower with water sources alternative and uses, if appropriate, investigate actively M anagement efficiency water setting to relation is in practice standard international recognised what understand M anagement those practices exceed that targets site set and have their sector/geography for targets efficiency water to improve value chain the down stakeholders with appropriate engages actively The site efficiency mechanisms including,water practice of leading the implementation promotes actively M anagement and recycling e.g. recovery re-use, water use can impact activities and operations, and their site’s they, how understand Workers applicable where requirements, permit/licence use/consumption of water aware are workers Key appropriate induction, where use issues at on water training receive Workers required training as specific receive responsibilities management use/consumption with water workers Key appropriate where use procedures, water and understand, access to, have Workers 3.1 Physical employment site inspection site employment 3.1 Physical LE V EL 1 ❒  Site water use procedures implemented use procedures water ❒ Site observed pipes are or water tanks water from leaks ❒ No water in place meters consumption ❒ Water and processes procedures site 3.2 Employment LE V EL 1 ❒  ❒  3.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  with document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  …

13_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile N o Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts U se ater W on

Gloss a ry h ering G at A pp endices GSCP Reference Environmental Alert Notification Ev idence Employment site operations and activities observed are in line with legal requirements relating to water use to relating requirements legal are in line with observed and activities operations site Employment (including water abstraction permit requirements) permit abstraction (including water (e.g. policies and written and implemented established use management water to in relation and procedures Policies etc.) handbook, induction training, employee procedures, E M S as per the site use management, water to in place relation and processes systems Formal compliance use and water concerning and regulations of laws is aware M anagement workers to communicated effectively use are water regarding and processes Policies and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained conservation water proactive or endorses promotes actively M anagement anagement are proactively driving continuous improvement through reviewing water consumption efficiency consumption water reviewing through improvement continuous driving proactively are M anagement on an annual basis targets external and internal relevant to available is made data consumption water ensures site The employment stakeholders and that use and performance in water improvement appropriate, where demonstrates, site The employment targets efficiency water it is achieving water limits and ecosystem within the local consumption water of sustainable the concept understands M anagement area catchment impact ecosystem lower with water sources alternative and uses, if appropriate, investigate actively M anagement efficiency water setting to relation is in practice standard international recognised what understand M anagement those practices exceed that targets site set and have their sector/geography for targets efficiency water to improve value chain the down stakeholders with appropriate engages actively The site efficiency mechanisms including,water practice of leading the implementation promotes actively M anagement and recycling e.g. recovery re-use, water use can impact activities and operations, and their site’s they, how understand Workers applicable where requirements, permit/licence use/consumption of water aware are workers Key appropriate induction, where use issues at on water training receive Workers required training as specific receive responsibilities management use/consumption with water workers Key appropriate where use procedures, water and understand, access to, have Workers 3.1 Physical employment site inspection site employment 3.1 Physical LE V EL 1 ❒  Site water use procedures implemented use procedures water ❒ Site observed pipes are or water tanks water from leaks ❒ No water in place meters consumption ❒ Water and processes procedures site 3.2 Employment LE V EL 1 ❒  ❒  3.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  with document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  …

Global Social Compliance Programme_14

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference workers receive training on water use issues; and on water training receive • workers and responsibilities roles use management their water to applicable training receive workers • key Relevant employment site permits and licences that relate to water use are available and up to date and up to available use are water to relate permits and licences that site employment Relevant use/ water to relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the on file retained is the documentation consumption, and maintained available are consumption water for results M onitoring personnel site employment relevant to made available are the site use issues at water address that Procedures indicate: etc.) matrix training (e.g.records, induction materials Training available are and are undertaken targets efficiency consumption of water Reviews water limits and ecosystem local to the relation (in sustainable is use/consumption water whether has identified Site area) catchment impact ecosystem lower with sources water alternative relevant, and used, if has investigated Site use/consumption water reducing to promote mechanisms leading practice has implemented Site are being achieved and stretching are targets efficiency Water The employment site has made demonstrable achievement of meeting or exceeding water efficiency targets (normalised) targets efficiency water exceeding or meeting of achievement demonstrable made has site employment The efficiency has been discussed water that value chain show the through stakeholders with appropriate Communications 3.4 Document checks 3.4 Document LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  …

15_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile No es Y Pre pa r a site wastewater treatment system treatment wastewater - site tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification standard practice standard Regular wastewater quality testing/ monitoring is undertaken to ensure ongoing compliance with permitted effluent limits and as per the site’s EMS site’s limits and as per the effluent compliance with permitted ongoing to ensure quality testing/ is undertaken monitoring wastewater Regular stakeholders and external internal relevant to available made are quality data Wastewater improvement continuous drive on an annual basis to reviewed are targets improvement quality and volume Wastewater Meet legal requirements legal Meet maintained held and compliance permits are - date up - to Relevant, points and discharge direction flow of wastewater understanding plan in place with a general D rainage potential impact direction and flow their contaminants, of the Identification EMS as per the site effluent wastewater manage in place to and processes systems Formal Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete 8. 9. quality in wastewater improvement 10. D emonstrable 3: Level limits ecosystem and receptors of local context in the are sustainable volume quality and discharge effluent 11. Wastewater in place treatment wastewater 12. L eading practice water reuse of grey including environment, to local discharged wastewater quality of to improve mechanisms in place 13. L eading practice emonstrable achievement of stretching wastewater effluent14. D quality improvement and volume reductiontargets (normalised)beyond recognised international quality effluent wastewater improve chain to the value down stakeholders with appropriate 15. Engagement and should not limit audit activities. as guidance are intended checks The following 7. 2. 3. 4. 2: Level 5. 6. to off quality or connection in wastewater improvements achieve in place to treatment wastewater b asic on - site 4. Wastewater/effluent level: each performance at requirements site Employment 1: Level 1.

Global Social Compliance Programme_16

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

N o Audit R equest Audit tion tion

r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit / E ffluent / Audit O ut p uts Audit astewater W ry a ry on

Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference h ering G at A pp endices Ev idence GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference or connection to off-site wastewater treatment system treatment wastewater to off-site or connection established and implemented have been management wastewater/effluent to in relation and procedures Policies etc.) training, handbook, induction employee (e.g. policies and procedures, written effluent compliance with permitted ongoing to ensure is undertaken quality testing/monitoring wastewater Regular E M S limits and as per the site’s Based on observations, sources of wastewater generated across the employment site have been identified have site the employment across generated wastewater of sources Based on observations, are directed ground and to unprotected direct are not discharging wastewaters that confirmed Based on observation, system a drainage to integrity condition and of sound good in are wastewater receiving sumps/pits Based on observation, to discharge prior treatment plant or undergoes treatment wastewater/effluent to a directed Is wastewater/effluent and blockages contamination from free are drains water/stormwater Surface (e.g. management being followed are discharges wastewater/wastewater manage to established Procedures etc.) activities of wastewater, observed the environment to No spills or leaks quality in wastewater improvements achieve is in place to treatment wastewater basic on-site Check whether and that it is achieving wastewater quality targets wastewater it is achieving and that within the local quality and discharge effluent wastewater of sustainable the concept understands M anagement receptors limits and local ecosystem effluent wastewater setting to relation is in practice standard international recognised what understand M anagement site set and have for their sector/geography (normalised) targets reduction and volume targets quality improvement those practices exceed that targets at the site and this has been implemented treatment wastewater leading practice understand M anagement quality effluent wastewater to improve value chain the down stakeholders with appropriate engages actively The site the quality to improve practice mechanisms of leading the implementation promotes actively M anagement water of grey including reuse environment, local to discharged of wastewater anagement is aware of laws and regulations concerning wastewater/effluent discharge compliance discharge wastewater/effluent concerning and regulations of laws is aware M anagement workers to communicated effectively are wastewater/effluent regarding and processes Policies potential direction and flow their contaminants, the identifies site the employment describe how M anagement site from the employment discharges wastewater/effluent to impact in relation and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained quality and management wastewater proactive or endorses promotes actively M anagement volume quality and wastewater reviewing through improvement continuous driving proactively are M anagement on an annual basis targets improvement stakeholders and external internal relevant to is made available quality data wastewater ensures site The employment quality and performance in wastewater improvement appropriate, where demonstrates, site The employment 4.2 Employment site procedures and processes procedures site 4.2 Employment LE V EL 1 ❒  ❒  4.1 Physical employment site inspection site employment 4.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  4.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  …

17_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile N o Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts / E ffluent / Gloss astewater W a ry on

A pp endices h ering G at GSCP Reference Environmental Alert Notification Ev idence or connection to off-site wastewater treatment system treatment wastewater to off-site or connection established and implemented have been management wastewater/effluent to in relation and procedures Policies etc.) training, handbook, induction employee (e.g. policies and procedures, written effluent compliance with permitted ongoing to ensure is undertaken quality testing/monitoring wastewater Regular E M S limits and as per the site’s Based on observations, sources of wastewater generated across the employment site have been identified have site the employment across generated wastewater of sources Based on observations, are directed ground and to unprotected direct are not discharging wastewaters that confirmed Based on observation, system a drainage to integrity condition and of sound good in are wastewater receiving sumps/pits Based on observation, to discharge prior treatment plant or undergoes treatment wastewater/effluent to a directed Is wastewater/effluent and blockages contamination from free are drains water/stormwater Surface (e.g. management being followed are discharges wastewater/wastewater manage to established Procedures etc.) activities of wastewater, observed the environment to No spills or leaks quality in wastewater improvements achieve is in place to treatment wastewater basic on-site Check whether and that it is achieving wastewater quality targets wastewater it is achieving and that within the local quality and discharge effluent wastewater of sustainable the concept understands M anagement receptors limits and local ecosystem effluent wastewater setting to relation is in practice standard international recognised what understand M anagement site set and have for their sector/geography (normalised) targets reduction and volume targets quality improvement those practices exceed that targets at the site and this has been implemented treatment wastewater leading practice understand M anagement quality effluent wastewater to improve value chain the down stakeholders with appropriate engages actively The site the quality to improve practice mechanisms of leading the implementation promotes actively M anagement water of grey including reuse environment, local to discharged of wastewater anagement is aware of laws and regulations concerning wastewater/effluent discharge compliance discharge wastewater/effluent concerning and regulations of laws is aware M anagement workers to communicated effectively are wastewater/effluent regarding and processes Policies potential direction and flow their contaminants, the identifies site the employment describe how M anagement site from the employment discharges wastewater/effluent to impact in relation and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained quality and management wastewater proactive or endorses promotes actively M anagement volume quality and wastewater reviewing through improvement continuous driving proactively are M anagement on an annual basis targets improvement stakeholders and external internal relevant to is made available quality data wastewater ensures site The employment quality and performance in wastewater improvement appropriate, where demonstrates, site The employment 4.2 Employment site procedures and processes procedures site 4.2 Employment LE V EL 1 ❒  ❒  4.1 Physical employment site inspection site employment 4.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  4.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  …

Global Social Compliance Programme_18

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion

r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference Workers receive training on wastewater/effluent issues; and on wastewater/effluent training receive • Workers responsibilities roles and management their wastewater/effluent to applicable training receive workers • Key Workers understand how they, and their site’s activities and operations, can impact wastewater/effluent quality wastewater/effluent can impact activities and operations, and their site’s they, how understand Workers available and are undertaken are targets improvement quality and volume of wastewater Reviews available results are quality testing/monitoring wastewater Regular volume quality and wastewater exceeding or of meeting achievement has made demonstrable site The employment (normalised) targets improvement sustainable volume is quality and discharge effluent wastewater whether has identified site The employment and discharge volumes and discharge applicable where requirements, permit/licence of wastewater/effluent aware are workers Key appropriate at induction, where issues on wastewater/effluent training receive Workers as required training specific receive responsibilities management with wastewater/effluent workers Key appropriate where procedures, wastewater/effluent and understand, access to, have Workers wastewater/ to relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the retained on file is the documentation effluent, impact potential direction and flow their contaminants, the and documented has identified site The employment the site leaving discharges with wastewater/effluent associated wastewater of understanding general a and confirms is available site plan of the employment drainage An up-to-date points and discharge direction flow indicate: etc.) matrix training (e.g.records, induction materials Training limits) receptors and local ecosystem to the local (in relation use/consumption water reducing to promote mechanisms leading practice has implemented The site are being achieved and stretching are targets reduction volume and quality improvement effluent Wastewater quality effluent wastewater that value chain show the through stakeholders with appropriate Communications has been discussed Relevant employment site permits and licences that relate to wastewater/effluent discharge are available and up to date to available and up are discharge wastewater/effluent to relate permits and licences that site employment Relevant Procedures that address wastewater/effluent issues at the site are made available to relevant employment site personnel site employment relevant to available are made at the site issues wastewater/effluent address that Procedures Interviews with key workers/other workers used to corroborate worker testimony with Document checks with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  LE V EL 2 ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  checks 4.4 Document LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  …

19_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification Workers receive training on wastewater/effluent issues; and on wastewater/effluent training receive • Workers responsibilities roles and management their wastewater/effluent to applicable training receive workers • Key Workers understand how they, and their site’s activities and operations, can impact wastewater/effluent quality wastewater/effluent can impact activities and operations, and their site’s they, how understand Workers available and are undertaken are targets improvement quality and volume of wastewater Reviews available results are quality testing/monitoring wastewater Regular volume quality and wastewater exceeding or of meeting achievement has made demonstrable site The employment (normalised) targets improvement sustainable volume is quality and discharge effluent wastewater whether has identified site The employment and discharge volumes and discharge applicable where requirements, permit/licence of wastewater/effluent aware are workers Key appropriate at induction, where issues on wastewater/effluent training receive Workers as required training specific receive responsibilities management with wastewater/effluent workers Key appropriate where procedures, wastewater/effluent and understand, access to, have Workers wastewater/ to relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the retained on file is the documentation effluent, impact potential direction and flow their contaminants, the and documented has identified site The employment the site leaving discharges with wastewater/effluent associated wastewater of understanding general a and confirms is available site plan of the employment drainage An up-to-date points and discharge direction flow indicate: etc.) matrix training (e.g.records, induction materials Training limits) receptors and local ecosystem to the local (in relation use/consumption water reducing to promote mechanisms leading practice has implemented The site are being achieved and stretching are targets reduction volume and quality improvement effluent Wastewater quality effluent wastewater that value chain show the through stakeholders with appropriate Communications has been discussed Relevant employment site permits and licences that relate to wastewater/effluent discharge are available and up to date to available and up are discharge wastewater/effluent to relate permits and licences that site employment Relevant Procedures that address wastewater/effluent issues at the site are made available to relevant employment site personnel site employment relevant to available are made at the site issues wastewater/effluent address that Procedures Interviews with key workers/other workers used to corroborate worker testimony with Document checks with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  LE V EL 2 ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  checks 4.4 Document LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  …

Global Social Compliance Programme_20

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

no No Audit R equest Audit es Y tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

containing equipment - containing xecution E xecution Audit S, such as CFCs, halons, TCE, CCl4 in line with recognised international standard practice standard international recognised with line in CCl4 TCE, halons, CFCs, as such OD S, A ir to

Audit O ut p uts Audit Em issions on

ry a ry Gloss h ering G at GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference Ev idence A pp endices out use of specific types of types specific of use phase - out to place in Targets Substances: D epleting OD S of and substitution control reduction, D emonstrable Substances: D epleting zone requirements) legal phase - out of all OD S (beyond Complete Substances: D epleting zone S leak detection and maintenance of OD S and maintenance OD S leak detection Proactive Substances: D epleting zone GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference epleting Substances: Meet legal requirements legal Meet Substances: D epleting zone maintained held and compliance permits are - date up - to Relevant, Substances: D epleting zone ( OD S) is maintained substances - depleting ozone of An inventory Substances: D epleting zone equipment of OD S containing Regular maintenance Substances: D epleting zone zone zone Based on observation, site has identified point and fugitive sources of emissions to air sources of emissions and fugitive point has identified site Based on observation, perimeter at the site and the site discernible across to air are no abnormal emissions Based on observation, ozone- contain to potential that has the on-site present that equipment has identified site Based on observation, etc.) conditioning units, (e.g. air chillers, substances depleting followed being are substances air and ozone-depleting emissions to manage to established Procedures etc.) activities equipment, of emission sources, (e.g. management order working it is in appropriate that ensure to has been checked equipment air abatement Emissions to and implemented (e.g. written policies and procedures, employee handbook, induction training, etc.) training, handbook, induction employee (e.g. policies and procedures, written and implemented E M S as per the site air emissions to manage in place to and processes systems Formal Equipment likely to contain ozone-depleting substances has been checked to ensure that it is in appropriate working order it is in appropriate that to ensure has been checked substances ozone-depleting contain to likely Equipment established been have substances ozone-depleting to air and to emissions in relation and procedures Policies General: Meet legal requirements (including monitoring) requirements legal Meet General: maintained held and compliance permits are - date up - to Relevant, General: emissions for fugitive potential has considered and site air is maintained emissions to source of main point An inventory General: EMS air as per the site to emissions manage in place to and processes systems Formal General: limits compliance with permitted ongoing to ensure air emissions quality testing/monitoring is undertaken Regular General: O ❒  5.1 Physical employment site inspection site employment 5.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 5.2 Employment LE V EL 1 ❒  Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete 15. O Level 3: Level limits ecosystem within local sustainable air are Emissions to 16. General: at source reduce emissions to efforts to air or to minimise emissions technologies in place abatement L eading practice 17. General: practice standard international recognised beyond targets air quality improvement of stretching achievement D emonstrable 18. General: air emissions to reduce chain to the value down stakeholders with appropriate Engagement 19. General: performed emissions monitoring Additional and proactive 20. General: 21. O and should not limit audit activities. as guidance are intended checks The following 14. 2. 3. 4. o 5. o 6. o 7. o 2: Level 8. 9. stakeholders and external internal relevant to made available are Air emissions quality data 10. General: improvement continuous drive on an annual basis to reviewed are targets Air quality improvement 11. General: to air (normalised) in emissions reduction D emonstrable 12. General: 13. O 5. Emissions to air 5. Emissions to level: each performance at requirements site Employment 1: Level 1.

21_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile no No es Y Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions containing equipment - containing GSCP Reference Environmental Audit Checks Audit O ut p uts S, such as CFCs, halons, TCE, CCl4 in line with recognised international standard practice standard international recognised with line in CCl4 TCE, halons, CFCs, as such OD S, A ir to

Em issions Gloss on

a ry A pp endices h ering G at GSCP Reference Environmental Alert Notification Ev idence out use of specific types of types specific of use phase - out to place in Targets Substances: D epleting emonstrable reduction, control and substitution of OD S and substitution control reduction, D emonstrable Substances: D epleting zone requirements) legal phase - out of all OD S (beyond Complete Substances: D epleting zone S leak detection and maintenance of OD S and maintenance OD S leak detection Proactive Substances: D epleting zone epleting Substances: Meet legal requirements legal Meet Substances: D epleting zone maintained held and compliance permits are - date up - to Relevant, Substances: D epleting zone ( OD S) is maintained substances - depleting ozone of An inventory Substances: D epleting zone equipment of OD S containing Regular maintenance Substances: D epleting zone zone zone Based on observation, site has identified point and fugitive sources of emissions to air sources of emissions and fugitive point has identified site Based on observation, perimeter at the site and the site discernible across to air are no abnormal emissions Based on observation, ozone- contain to potential that has the on-site present that equipment has identified site Based on observation, etc.) conditioning units, (e.g. air chillers, substances depleting followed being are substances air and ozone-depleting emissions to manage to established Procedures etc.) activities equipment, of emission sources, (e.g. management order working it is in appropriate that ensure to has been checked equipment air abatement Emissions to and implemented (e.g. written policies and procedures, employee handbook, induction training, etc.) training, handbook, induction employee (e.g. policies and procedures, written and implemented E M S as per the site air emissions to manage in place to and processes systems Formal Equipment likely to contain ozone-depleting substances has been checked to ensure that it is in appropriate working order it is in appropriate that to ensure has been checked substances ozone-depleting contain to likely Equipment established been have substances ozone-depleting to air and to emissions in relation and procedures Policies General: Meet legal requirements (including monitoring) requirements legal Meet General: maintained held and compliance permits are - date up - to Relevant, General: emissions for fugitive potential has considered and site air is maintained emissions to source of main point An inventory General: EMS air as per the site to emissions manage in place to and processes systems Formal General: limits compliance with permitted ongoing to ensure air emissions quality testing/monitoring is undertaken Regular General: O ❒  5.1 Physical employment site inspection site employment 5.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 5.2 Employment LE V EL 1 ❒  Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete 15. O Level 3: Level limits ecosystem within local sustainable air are Emissions to 16. General: at source reduce emissions to efforts to air or to minimise emissions technologies in place abatement L eading practice 17. General: practice standard international recognised beyond targets air quality improvement of stretching achievement D emonstrable 18. General: air emissions to reduce chain to the value down stakeholders with appropriate Engagement 19. General: performed emissions monitoring Additional and proactive 20. General: 21. O and should not limit audit activities. as guidance are intended checks The following 14. 2. 3. 4. o 5. o 6. o 7. o 2: Level 8. 9. stakeholders and external internal relevant to made available are Air emissions quality data 10. General: improvement continuous drive on an annual basis to reviewed are targets Air quality improvement 11. General: to air (normalised) in emissions reduction D emonstrable 12. General: 13. O 5. Emissions to air 5. Emissions to level: each performance at requirements site Employment 1: Level 1.

Global Social Compliance Programme_22

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference workers receive training on emissions to air and ODS issues; on emissions to training receive • workers and responsibilities air and ODS roles their emissions to to applicable training receive workers • key anagement is aware of laws and regulations (including monitoring requirements) concerning emissions to air concerning emissions requirements) (including monitoring and regulations of laws is aware M anagement compliance ozone-depleting concerning requirements) (including monitoring and regulations of laws is aware M anagement compliance substances communicated effectively are substances air and ozone-depleting emissions to regarding and processes Policies workers to and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained targets air quality improvement reviewing through improvement continuous driving proactively are M anagement on an annual basis to air in emissions a reduction appropriate, where demonstrates, site The employment targets of ODS and substitution control reduction, appropriate, where demonstrates, site The employment limits ecosystem air within the local emissions to of sustainable the concept understands M anagement setting air quality to relation is in practice standard international recognised what understand M anagement those practices exceed that targets site set and have their sector/geography for targets improvement reduce to efforts to air or to minimise emissions technologies abatement leading practice understand M anagement the site at and this has been implemented source emissions at to air reduce emissions to value chain the down stakeholders with appropriate engages actively The site to air can impact emissions activities and operations, and their site’s they, how understand Workers appropriate at induction, where issues substances air and ozone-depleting on emissions to training receive Workers specific receive responsibilities management substances air and ozone-depleting with emissions to workers Key as required training date and up to available air are emissions to to relate permits and licences that site employment Relevant to date and up available are substances ozone-depleting to relate permits and licences that site employment Relevant to air to emissions relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the held on file these are substances, and ozone-depleting relevant to available made are at the site substances air and ozone-depleting emissions to address that Procedures personnel site employment for the potential has also considered The site air is maintained. emissions to sources of main point An inventory emissions fugitive (ODS) is maintained substances of ozone-depleting An inventory equipment of ODS containing maintenance the regular for available are records maintenance Regular required held on file, where are ODS servicing contractors of external records Competency indicate: etc.) matrix training (e.g.records, induction materials Training The employment site ensures air emissions quality data is made available to relevant internal and external stakeholders and external internal relevant to is made available emissions quality data air ensures site The employment appropriate where procedures, substances ozone-depleting and air to emissions understand, and to, access have Workers Key workers are aware of emissions to air and ozone-depleting substances permit/licence requirements, where applicable where requirements, permit/licence substances air and ozone-depleting of emissions to aware are workers Key 5.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 to air management emissions proactive or endorses promotes actively ❒ M anagement and maintenance) detection (including leak ODS management proactive or endorses promotes actively ❒ M anagement ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  with document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  checks 5.4 Document LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  …

23_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification workers receive training on emissions to air and ODS issues; on emissions to training receive • workers and responsibilities air and ODS roles their emissions to to applicable training receive workers • key anagement is aware of laws and regulations (including monitoring requirements) concerning emissions to air concerning emissions requirements) (including monitoring and regulations of laws is aware M anagement compliance ozone-depleting concerning requirements) (including monitoring and regulations of laws is aware M anagement compliance substances communicated effectively are substances air and ozone-depleting emissions to regarding and processes Policies workers to and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained targets air quality improvement reviewing through improvement continuous driving proactively are M anagement on an annual basis to air in emissions a reduction appropriate, where demonstrates, site The employment targets of ODS and substitution control reduction, appropriate, where demonstrates, site The employment limits ecosystem air within the local emissions to of sustainable the concept understands M anagement setting air quality to relation is in practice standard international recognised what understand M anagement those practices exceed that targets site set and have their sector/geography for targets improvement reduce to efforts to air or to minimise emissions technologies abatement leading practice understand M anagement the site at and this has been implemented source emissions at to air reduce emissions to value chain the down stakeholders with appropriate engages actively The site to air can impact emissions activities and operations, and their site’s they, how understand Workers appropriate at induction, where issues substances air and ozone-depleting on emissions to training receive Workers specific receive responsibilities management substances air and ozone-depleting with emissions to workers Key as required training date and up to available air are emissions to to relate permits and licences that site employment Relevant to date and up available are substances ozone-depleting to relate permits and licences that site employment Relevant to air to emissions relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the held on file these are substances, and ozone-depleting relevant to available made are at the site substances air and ozone-depleting emissions to address that Procedures personnel site employment for the potential has also considered The site air is maintained. emissions to sources of main point An inventory emissions fugitive (ODS) is maintained substances of ozone-depleting An inventory equipment of ODS containing maintenance the regular for available are records maintenance Regular required held on file, where are ODS servicing contractors of external records Competency indicate: etc.) matrix training (e.g.records, induction materials Training The employment site ensures air emissions quality data is made available to relevant internal and external stakeholders and external internal relevant to is made available emissions quality data air ensures site The employment appropriate where procedures, substances ozone-depleting and air to emissions understand, and to, access have Workers Key workers are aware of emissions to air and ozone-depleting substances permit/licence requirements, where applicable where requirements, permit/licence substances air and ozone-depleting of emissions to aware are workers Key 5.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 to air management emissions proactive or endorses promotes actively ❒ M anagement and maintenance) detection (including leak ODS management proactive or endorses promotes actively ❒ M anagement ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  with document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  checks 5.4 Document LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  …

Global Social Compliance Programme_24

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference or efforts to reduce emissions at source reduce emissions to or efforts being achieved and are stretching are targets Air quality improvement to air has been reducing emissions that value chain show the through stakeholders with appropriate Communications discussed requirements legal beyond emissions monitoring additional and proactive has performed site The employment requirements) legal phase-out of all ODS (beyond the complete has documented site The employment Reviews of air quality improvement targets are undertaken and are available and are undertaken are targets of air quality improvement Reviews available results are air emissions and quality testing/monitoring Regular equipment, of ODS-containing and maintenance ODS leak detection proactive has demonstrated site The employment requirements legal above recognised TCE, CCl4 in line with halons, phase-out use of specific types ODS, such as CFCs, in place to are Targets practice standard international ODSs and substituting of reducing, controlling achievement has made demonstrable site The employment targets air quality improvement exceeding or of meeting achievement has made demonstrable site The employment (normalised) limits) ecosystem local to the relation (in are sustainable to air emissions whether has identified site The employment to air to minimise emissions technologies abatement leading practice has implemented site The employment ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  …

25_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

… GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile No es Y Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification site waste disposal/treatment maintained disposal/treatment waste - site site and off - site site waste burning/or uncontrolled waste landfilling is undertaken waste burning/or uncontrolled waste o on - site Formal systems and processes in place to manage waste generation, storage, transportation and disposal as per the site EMS including waste minimisation audit minimisation waste EMS including and disposal as per the site transportation storage, generation, waste manage in place to and processes systems Formal Meet legal requirements legal Meet maintained held and compliance permits are - date up - to Relevant, undertaken are permits appropriate have contractors waste that checks Regular in place are streams waste for hazardous procedures Inventory/management/storage/transportation of on Records and consideration of waste hierarchy principles hierarchy waste of and consideration methods) disposal/treatment (suitability, contractors management waste of Evaluation

Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete

7. n 2: Level 8.  2. 3. wastes of 4. on handling and segregation provided and training awareness and employee is segregated waste and non - hazardous h azardous 5. 6. 6. Waste management 6. Waste level: each performance at requirements site Employment 1: Level 1. 9. opportunities avoidance/reduction/recycling/reuse waste identify to with suppliers 10. Engagement practice standard international recognised in line with streams waste of 11. Segregation stakeholders and external internal relevant to available with data and recycled generated of waste and measurement 12. Monitoring improvement continuous to drive on an annual basis at least reviewed are targets recycling and reduction 13. Waste (normalised) reduction waste 14. D emonstrable 3: Level facilities and disposal treatment waste of availability and environment operating within local is sustainable and volume disposal method 15. Waste waste from reduction/recycling/energy waste use and achieve material resource/virgin to minimise in place 16. L eading practices practice standard international recognised beyond targets reduction/recycling waste of stretching achievement 17. D emonstrable measures waste from avoidance/reduction/recycling/reuse/energy waste identify chain to the value down stakeholders with appropriate 18. Engagement and should not limit audit activities. as guidance are intended checks The following

Global Social Compliance Programme_26

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

no Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit m ent Manage

Audit O ut p uts Audit aste W ry a ry on

Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference h ering G at

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices Ev idence communications/meeting minutes regarding the management of waste are displayed for all workers to see workers for all are displayed waste of the management regarding minutes communications/meeting (e.g. on notice boards) programmes minimisation waste GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference •  •  Segregation and storage practices are in line with legal requirements are in line with legal practices storage and Segregation are being procedures management waste site to check whether activities management a number of waste Review implemented Policies and procedures regarding waste management is in place (e.g. written policies and procedures, employee employee policies and procedures, is in place (e.g. written management waste regarding and procedures Policies etc.) handbook, induction training, and disposal transportation, storage, generation, waste manage in place to are and processes systems Formal as per the site E M S as per the site compliance and management waste concerning and regulations of laws is aware M anagement workers to communicated is effectively management waste regarding and procedures Policies and regulations laws with applicable compliance ensure to resources the appropriate provide M anagement is maintained permits/licences contractor on waste checks regular undertake to workers key nominated have M anagement contractors management of waste methods and disposal/treatment the suitability has evaluated person A nominated opportunities avoidance/recycling/reuse waste identify to with suppliers engages site The employment targets recycling and reduction of waste annual reviews facilitate M anagement 6.1 Physical employment site inspection site employment 6.1 Physical LE V EL 1 ❒  characteristics and non-hazardous hazardous to according being segregated are ❒ Wastes their contents to applicable in containers being stored are ❒ Wastes condition in good are containers ❒ Waste ingress water rain prevent to covered are externally located areas storage and/or ❒ Containers labelled with their contents are of waste ❒ All containers characteristics and hazard labelled with their contents are waste of hazardous ❒ Containers materials waste or leaking of spillage to prevent condition in good are areas storage of waste ❒ Surfaces on-site landfilling activities not undertaken burning or uncontrolled ❒ Uncontrolled recycling off-site or for on-site and separated being identified are as being recycled reported materials ❒ Waste of liquid wastes containers to in close proximity available are etc.) (e.g. granules materials/equipment ❒ Spill response ❒  stored is being documentation waste where location the physical identify to ❒ Try of: evidence ❒ Check for 6.2 Employment site procedures and processes procedures site 6.2 Employment LE V EL 1 ❒  ❒  6.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  …

27_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile no Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts m ent Manage aste Gloss W on

a ry A pp endices h ering G at GSCP Reference Environmental Alert Notification Ev idence communications/meeting minutes regarding the management of waste are displayed for all workers to see workers for all are displayed waste of the management regarding minutes communications/meeting (e.g. on notice boards) programmes minimisation waste •  •  Segregation and storage practices are in line with legal requirements are in line with legal practices storage and Segregation are being procedures management waste site to check whether activities management a number of waste Review implemented Policies and procedures regarding waste management is in place (e.g. written policies and procedures, employee employee policies and procedures, is in place (e.g. written management waste regarding and procedures Policies etc.) handbook, induction training, and disposal transportation, storage, generation, waste manage in place to are and processes systems Formal as per the site E M S as per the site compliance and management waste concerning and regulations of laws is aware M anagement workers to communicated is effectively management waste regarding and procedures Policies and regulations laws with applicable compliance ensure to resources the appropriate provide M anagement is maintained permits/licences contractor on waste checks regular undertake to workers key nominated have M anagement contractors management of waste methods and disposal/treatment the suitability has evaluated person A nominated opportunities avoidance/recycling/reuse waste identify to with suppliers engages site The employment targets recycling and reduction of waste annual reviews facilitate M anagement 6.1 Physical employment site inspection site employment 6.1 Physical LE V EL 1 ❒  characteristics and non-hazardous hazardous to according being segregated are ❒ Wastes their contents to applicable in containers being stored are ❒ Wastes condition in good are containers ❒ Waste ingress water rain prevent to covered are externally located areas storage and/or ❒ Containers labelled with their contents are of waste ❒ All containers characteristics and hazard labelled with their contents are waste of hazardous ❒ Containers materials waste or leaking of spillage to prevent condition in good are areas storage of waste ❒ Surfaces on-site landfilling activities not undertaken burning or uncontrolled ❒ Uncontrolled recycling off-site or for on-site and separated being identified are as being recycled reported materials ❒ Waste of liquid wastes containers to in close proximity available are etc.) (e.g. granules materials/equipment ❒ Spill response ❒  stored is being documentation waste where location the physical identify to ❒ Try of: evidence ❒ Check for 6.2 Employment site procedures and processes procedures site 6.2 Employment LE V EL 1 ❒  ❒  6.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  …

Global Social Compliance Programme_28

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion

r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference workers receive training on waste handling, segregation and storage requirements; and requirements; storage and handling, segregation on waste training receive • workers and responsibilities roles management their waste to applicable training receive workers • key of waste contractors of waste have been opportunities avoidance/reduction/recycling/reuse waste that show with suppliers Communications discussed available are targets and recycling generated of wastes data M onitoring/measurement annually at least reviewed and are been documented have targets reduction/recycling Waste waste to identify facilities treatment/disposal of receiving capacity waste assess the future to undertaken are Reviews sustainability priorities and drive reduction are sustainable wastes volumes of its methods and the disposal whether has identified site The employment facilities) and disposal treatment waste availability of and environment operating to the local (in relation generated waste use and material to minimise virgin measures leading practice has implemented site Employment of energy generation the and/or recycling to relation in leading practices has implemented site The employment waste from being achieved and are stretching are targets reduction/recycling Waste down opportunities avoidance/reduction/recycling/reuse waste that show stakeholders with Communications been discussed chain have the value anagement understand the concept of sustainable waste disposal methods and whether current site waste waste site current and whether disposal methods waste of sustainable the concept understand M anagement is sustainable generation example, for to, relation in practices of leading implementation site or endorsing promoting is actively M anagement are that materials waste of site the percentage and increasing generation use and waste material minimising virgin waste from of energy the generation and/or recycled reduction/recycling waste to relation is in practice standard international recognised what understand M anagement those practices exceed that targets site set and have their sector/geography for applicable where permit/licence requirements, management of waste aware are workers Key at induction requirements storage and segregation on waste training receive Workers activities management waste training on specific receive responsibilities management with waste workers Key procedures inventory/management/storage/disposal waste hazardous and understand, access to, have Workers information relevant all contains and accurately completed is disposal/treatment waste of off-site Documentation and regulations laws applicable by as required requirement for the minimum legal on file retained is documentation Waste been undertaken permits/licences have appropriate have contractors waste that checks Regular relevant to available made in place and are are procedures Inventory/management/storage/transportation personnel site employment indicate: etc.) matrix training (e.g.records, induction materials Training been undertaken audits have minimisation Waste principles hierarchy waste applied the practical, and, where has considered site The employment methods and disposal/treatment the suitability determine to been undertaken have contractors Audits of waste ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  checks 6.4 Document LE V EL 1 available permits and licences are waste site employment ❒ Relevant ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  …

29_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification workers receive training on waste handling, segregation and storage requirements; and requirements; storage and handling, segregation on waste training receive • workers and responsibilities roles management their waste to applicable training receive workers • key of waste contractors of waste have been opportunities avoidance/reduction/recycling/reuse waste that show with suppliers Communications discussed available are targets and recycling generated of wastes data M onitoring/measurement annually at least reviewed and are been documented have targets reduction/recycling Waste waste to identify facilities treatment/disposal of receiving capacity waste assess the future to undertaken are Reviews sustainability priorities and drive reduction are sustainable wastes volumes of its methods and the disposal whether has identified site The employment facilities) and disposal treatment waste availability of and environment operating to the local (in relation generated waste use and material to minimise virgin measures leading practice has implemented site Employment of energy generation the and/or recycling to relation in leading practices has implemented site The employment waste from being achieved and are stretching are targets reduction/recycling Waste down opportunities avoidance/reduction/recycling/reuse waste that show stakeholders with Communications been discussed chain have the value anagement understand the concept of sustainable waste disposal methods and whether current site waste waste site current and whether disposal methods waste of sustainable the concept understand M anagement is sustainable generation example, for to, relation in practices of leading implementation site or endorsing promoting is actively M anagement are that materials waste of site the percentage and increasing generation use and waste material minimising virgin waste from of energy the generation and/or recycled reduction/recycling waste to relation is in practice standard international recognised what understand M anagement those practices exceed that targets site set and have their sector/geography for applicable where permit/licence requirements, management of waste aware are workers Key at induction requirements storage and segregation on waste training receive Workers activities management waste training on specific receive responsibilities management with waste workers Key procedures inventory/management/storage/disposal waste hazardous and understand, access to, have Workers information relevant all contains and accurately completed is disposal/treatment waste of off-site Documentation and regulations laws applicable by as required requirement for the minimum legal on file retained is documentation Waste been undertaken permits/licences have appropriate have contractors waste that checks Regular relevant to available made in place and are are procedures Inventory/management/storage/transportation personnel site employment indicate: etc.) matrix training (e.g.records, induction materials Training been undertaken audits have minimisation Waste principles hierarchy waste applied the practical, and, where has considered site The employment methods and disposal/treatment the suitability determine to been undertaken have contractors Audits of waste ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 3 ❒  ❒  ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  checks 6.4 Document LE V EL 1 available permits and licences are waste site employment ❒ Relevant ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  …

Global Social Compliance Programme_30

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

no No Audit R equest Audit es Y tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

S ubstances ardous GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Ha z

y y xecution E xecution Audit P otentiall and

Audit O ut p uts Audit ardous ry a ry Ha z / Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference P re v ention A pp endices P ollution on

h ering G at GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference with legal requirements with legal substances hazardous and potentially hazardous containing and pipework (including tanks) Bulk containers integrity condition and of sound good are in cause pollution to with the potential substances hazardous and potentially hazardous containing and pipework (including tanks) Bulk containers appropriate are labelled, where cause pollution to with the potential site at the employment chemicals and use of prohibited for the presence observation, Check, through being stored/used are chemicals where in areas available ( M SDS) are Sheets Data Safety M aterial up-to-date Relevant (e.g. followed management are being for pollution the potential prevent/reduce to established Procedures/control etc.) transportation storage, of substances, to ensure available and has been checked (e.g. equipment spill kits) is and pollution prevention response Emergency order working it is in appropriate that observed are the environment to No spills or leaks of sound integrity and are condition in good are containment/bunds Secondary substances hazardous potentially and prevention/hazardous to pollution in relation and procedures Policies handbook, employee (e.g. policies and procedures, written and implemented been established have management etc.) induction training, for pollution incidents reduce the potential to and pollution prevention in place for and processes systems Formal E M S as per the site azardous and potentially hazardous substance storage, use, handling, processing and/or disposal are in line disposal are use, handling, and/or processing storage, substance hazardous and potentially H azardous and groundwater impacts and groundwater employees relevant to all training is delivered response and prevention Pollution permits/legislation by applicable required to the authorities as notified are Incidents site EMS as per the for pollution incidents reduce the potential to and pollution prevention in place for and processes systems Formal Meet legal requirements legal Meet W HO ) H ealth O rganisation, World from agrichemicals (e.g. list for chemicals Compliance with prohibited maintained held and compliance permits are - date up - to Relevant, (MS D S) Sheets D ata Safety Material - date up - to with relevant together is maintained used and stored substances of hazardous An inventory soil water, air, for minimising potential substances, of all hazardous for the management/storage/transportation in place Specific procedures/controls Ev idence hazardous alternatives where possible where alternatives non - hazardous with substitute and risks associated minimise substances, hazardous of use the reduce to basis annual an on reviewed are Targets

❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 7.2 Employment LE V EL 1 ❒  ❒  7.1 Physical employment site inspection site employment 7.1 Physical LE V EL 1 ❒  Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete

6. 7. 2: Level 8. 9. deal with pollution incidents in place to team response emergency site d edicated for pollution incidents carried out drills are practice 10. Regular 11.  Where relevant, specific pollution prevention mechanisms are considered in agricultural production, including optimisation of agrichemicals input of agrichemicals production, including optimisation in agricultural considered are mechanisms prevention specific pollution relevant, 12. Where as appropriate risks, of associated use (normalised) and minimisation substances in hazardous reduction 13. D emonstrable 3: Level and policy in place pollution incident’target 14. ‘Zero conducted are inspections pollution prevention 15. D etailed substances alternative and non - toxic the use of non - hazardous 16. Promote practice standard international recognised beyond targets / substitution reduction substance hazardous of stretching achievement 17. D emonstrable use substance hazardous improve chain to the value down stakeholders with appropriate 18. Engagement and should not limit audit activities. as guidance are intended checks The following 2. 3. 4. 5.  7. Pollution prevention/hazardous and potentially hazardous substances hazardous and potentially prevention/hazardous 7. Pollution level: each performance at requirements site Employment 1: Level 1.

31_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem

s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile no No es Y Pre pa r a tion

Audit E xecution S ubstances GSCP Reference Environmental of Findings and Corrective Summary Actions ardous Ha z y y GSCP Reference Environmental Audit Checks Audit O ut p uts P otentiall and

Gloss ardous Ha z a ry / A pp endices GSCP Reference Environmental Alert Notification P re v ention P ollution on

h ering G at with legal requirements with legal substances hazardous and potentially hazardous containing and pipework (including tanks) Bulk containers integrity condition and of sound good are in cause pollution to with the potential substances hazardous and potentially hazardous containing and pipework (including tanks) Bulk containers appropriate are labelled, where cause pollution to with the potential site at the employment chemicals and use of prohibited for the presence observation, Check, through being stored/used are chemicals where in areas available ( M SDS) are Sheets Data Safety M aterial up-to-date Relevant (e.g. followed management are being for pollution the potential prevent/reduce to established Procedures/control etc.) transportation storage, of substances, to ensure available and has been checked (e.g. equipment spill kits) is and pollution prevention response Emergency order working it is in appropriate that observed are the environment to No spills or leaks of sound integrity and are condition in good are containment/bunds Secondary substances hazardous potentially and prevention/hazardous to pollution in relation and procedures Policies handbook, employee (e.g. policies and procedures, written and implemented been established have management etc.) induction training, for pollution incidents reduce the potential to and pollution prevention in place for and processes systems Formal E M S as per the site azardous and potentially hazardous substance storage, use, handling, processing and/or disposal are in line disposal are use, handling, and/or processing storage, substance hazardous and potentially H azardous and groundwater impacts and groundwater employees relevant to all training is delivered response and prevention Pollution permits/legislation by applicable required to the authorities as notified are Incidents site EMS as per the for pollution incidents reduce the potential to and pollution prevention in place for and processes systems Formal Meet legal requirements legal Meet W HO ) H ealth O rganisation, World from agrichemicals (e.g. list for chemicals Compliance with prohibited maintained held and compliance permits are - date up - to Relevant, (MS D S) Sheets D ata Safety Material - date up - to with relevant together is maintained used and stored substances of hazardous An inventory soil water, air, for minimising potential substances, of all hazardous for the management/storage/transportation in place Specific procedures/controls Ev idence hazardous alternatives where possible where alternatives non - hazardous with substitute and risks associated minimise substances, hazardous of use the reduce to basis annual an on reviewed are Targets

❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 7.2 Employment LE V EL 1 ❒  ❒  7.1 Physical employment site inspection site employment 7.1 Physical LE V EL 1 ❒  Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete

6. 7. 2: Level 8. 9. deal with pollution incidents in place to team response emergency site d edicated for pollution incidents carried out drills are practice 10. Regular 11.  Where relevant, specific pollution prevention mechanisms are considered in agricultural production, including optimisation of agrichemicals input of agrichemicals production, including optimisation in agricultural considered are mechanisms prevention specific pollution relevant, 12. Where as appropriate risks, of associated use (normalised) and minimisation substances in hazardous reduction 13. D emonstrable 3: Level and policy in place pollution incident’target 14. ‘Zero conducted are inspections pollution prevention 15. D etailed substances alternative and non - toxic the use of non - hazardous 16. Promote practice standard international recognised beyond targets / substitution reduction substance hazardous of stretching achievement 17. D emonstrable use substance hazardous improve chain to the value down stakeholders with appropriate 18. Engagement and should not limit audit activities. as guidance are intended checks The following 2. 3. 4. 5.  7. Pollution prevention/hazardous and potentially hazardous substances hazardous and potentially prevention/hazardous 7. Pollution level: each performance at requirements site Employment 1: Level 1.

Global Social Compliance Programme_32

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices workers receive training on pollution prevention and response; and and on pollution prevention training receive workers training appropriate received have team members response pollution GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference •  •  Where there is the potential for pollution to occur, the employment site has identified this potential this has identified site the employment to occur, for pollution is the potential there Where hazardous potentially and prevention/hazardous concerning pollution and regulations of laws is aware M anagement and compliance management substances W H O) H ealth Organisation, World from agrichemicals (e.g. for list chemicals of the prohibited is aware M anagement with this requirement and compliance management substances hazardous and potentially pollution prevention/hazardous regarding and processes Policies workers relevant to communicated is effectively site at the employment to occur for pollution the potential reduce to been implemented have M easures mechanisms in agricultural prevention of specific pollution the implementation promoting is actively M anagement input of agrichemicals including optimisation production, use (normalised) substances hazardous reduction in a and achieving in promoting engaged is actively M anagement as appropriate risks, of associated and minimisation substances alternative and non-toxic the use of non-hazardous promoting is actively M anagement cause pollution can activities and operations, and their site’s they, how understand Workers permit/licence substances hazardous and potentially of pollution prevention/hazardous aware are workers Key applicable where requirements, at induction substances hazardous and potentially on pollution prevention/hazardous training receive Workers prevention training on its specific receive of pollution for the prevention with responsibilities workers Relevant of a release in the event response and relevant substances hazardous and potentially pollution prevention/hazardous and understand, access to, have Workers procedures for pollution incidents carried out drills are practice Regular deal with pollution incidents is in place to team response emergency site A dedicated and potentially pollution prevention/hazardous to relate permits and licences that site employment Relevant date and up to available are substances hazardous to pollution relation in documentation maintain hold and/or to required is legally site the employment Where required for the retained on file is the documentation substances, hazardous and potentially prevention/hazardous period of time permits/legislation by applicable as required to the authorities been notified have incidents Pollution activities to the site’s related pollution scenarios all potential and documented has considered site The employment and operations minimising substances, of all hazardous for the management/storage/transportation Specific procedures/controls personnel site employment relevant to available made impacts are soil and groundwater water, for air, potential on-site used and stored substances of hazardous an inventory maintains site The employment made available ( M SDS) and these are Sheets Data Safety M aterial up-to-date relevant maintains site The employment the majority of employees. by understood in the language(s) employees to on the prohibited are they and whether used on-site chemicals and documented has considered site The employment list chemicals indicate: etc.) matrix training (e.g.records, induction materials Training anagement provide the appropriate resources to ensure compliance with applicable laws and regulations is maintained and regulations laws with applicable compliance ensure to resources the appropriate provide M anagement 7.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  LE V EL 3 ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  checks 7.4 Document LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  …

33_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification workers receive training on pollution prevention and response; and and on pollution prevention training receive workers training appropriate received have team members response pollution •  •  Where there is the potential for pollution to occur, the employment site has identified this potential this has identified site the employment to occur, for pollution is the potential there Where hazardous potentially and prevention/hazardous concerning pollution and regulations of laws is aware M anagement and compliance management substances W H O) H ealth Organisation, World from agrichemicals (e.g. for list chemicals of the prohibited is aware M anagement with this requirement and compliance management substances hazardous and potentially pollution prevention/hazardous regarding and processes Policies workers relevant to communicated is effectively site at the employment to occur for pollution the potential reduce to been implemented have M easures mechanisms in agricultural prevention of specific pollution the implementation promoting is actively M anagement input of agrichemicals including optimisation production, use (normalised) substances hazardous reduction in a and achieving in promoting engaged is actively M anagement as appropriate risks, of associated and minimisation substances alternative and non-toxic the use of non-hazardous promoting is actively M anagement cause pollution can activities and operations, and their site’s they, how understand Workers permit/licence substances hazardous and potentially of pollution prevention/hazardous aware are workers Key applicable where requirements, at induction substances hazardous and potentially on pollution prevention/hazardous training receive Workers prevention training on its specific receive of pollution for the prevention with responsibilities workers Relevant of a release in the event response and relevant substances hazardous and potentially pollution prevention/hazardous and understand, access to, have Workers procedures for pollution incidents carried out drills are practice Regular deal with pollution incidents is in place to team response emergency site A dedicated and potentially pollution prevention/hazardous to relate permits and licences that site employment Relevant date and up to available are substances hazardous to pollution relation in documentation maintain hold and/or to required is legally site the employment Where required for the retained on file is the documentation substances, hazardous and potentially prevention/hazardous period of time permits/legislation by applicable as required to the authorities been notified have incidents Pollution activities to the site’s related pollution scenarios all potential and documented has considered site The employment and operations minimising substances, of all hazardous for the management/storage/transportation Specific procedures/controls personnel site employment relevant to available made impacts are soil and groundwater water, for air, potential on-site used and stored substances of hazardous an inventory maintains site The employment made available ( M SDS) and these are Sheets Data Safety M aterial up-to-date relevant maintains site The employment the majority of employees. by understood in the language(s) employees to on the prohibited are they and whether used on-site chemicals and documented has considered site The employment list chemicals indicate: etc.) matrix training (e.g.records, induction materials Training anagement provide the appropriate resources to ensure compliance with applicable laws and regulations is maintained and regulations laws with applicable compliance ensure to resources the appropriate provide M anagement 7.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  LE V EL 3 ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  checks 7.4 Document LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  …

Global Social Compliance Programme_34

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ero pollution incident’ target and policy is in place has been documented pollution incident’target ero GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference Detailed pollution prevention inspections are documented and maintained. Inspections consider all areas consider all Inspections and maintained. are documented inspections pollution prevention Detailed exists. for pollution the potential where site of the employment available are that substances alternative and non-toxic non-hazardous has documented site The employment are being achieved and stretching are targets performance reduction/substitution substance H azardous to improve value chain the down stakeholders with appropriate engages site the employment show Communications use substance hazardous for major incidents reduce the potential to mechanisms leading practice has implemented site The employment etc.) (e.g. changes process in agricultural production this includies optimisation of agrichemicals input of agrichemicals this includies optimisation production in agricultural A ‘ Z Documented evidence that regular practice drills are carried out for pollution incidents carried out drills are practice regular that evidence Documented of associated use (normalised) and minimisation substances in hazardous a reduction demonstrates The employment as appropriate risks, reviews annually and reviewed are targets use performance alternative use and non-hazardous substance H azardous been documented have for pollution reduce the potential to mechanisms pollution prevention has implemented site The employment ❒  ❒  ❒  ❒  ❒  LE V EL 3 ❒  LE V EL 2 ❒  and closed out have been implemented practice drills from actions identified ❒ Improvement ❒  ❒  ❒ 

35_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile No es Y Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification Meet legal requirements legal Meet maintained held and compliance permits are - date up - to Relevant, on - site of activities undertaken the risks as needed and reflecting response, major incident for guidelines/training plan in place with detailed emergency Site required communities, as services and local authorities, emergency local to plan communicated response Emergency EMS as per the site response emergency manage in place to and processes systems Formal etc.) fires, major spills explosions, (e.g. and impacts of major incidents occurrence in potential Reduction reviews (QRA) Risk Assessment Quantitative Regular stakeholders relevant to reported Major incidents Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete

2. 3. 4. 2: Level 5. 6. 7. 8. 9. in place team response emergency site d edicated scenarios for all emergency carried out drills are practice 10. Regular 3: Level and policy in place major incident’ target 11. ‘Zero response procedures and emergency of major incidents of risks awareness to ensure community with local engagement 12. Proactive as relevant team, response the emergency by drill and has been contacted response emergency in site’s is involved community 13. L ocal changes e.g.reduce risk of major incidents process to mechanisms in place 14. L eading practice and should not limit audit activities. as guidance are intended checks The following ajor incident management 8. M ajor incident level: each performance at requirements site Employment 1: Level 1.

Global Social Compliance Programme_36

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

no Audit R equest Audit tion tion

r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit m ent Manage

Audit O ut p uts Audit I ncident ry a ry Major

on Gloss

GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference h ering G at A pp endices Ev idence GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference and procedures, employee handbook, induction training etc.) handbook, induction training employee and procedures, Confirm, through observation, whether substances used and/or activities undertaken at site have the potential potential have the site at activities undertaken used and/or substances whether observation, through Confirm, major incidents cause to requirements in line with legal disposal are use, handling,and/or processing storage, substance H azardous occurring from major incidents potential prevent to being segregated are substances hazardous Ensure cause a major incident to with the potential substances containing and pipework (including tanks) Bulk containers and of sound integrity condition in good are cause a major incident to with the potential substances containing and pipework (including tanks) Bulk containers appropriate labelled, where are followed being are for a major incident the potential prevent/reduce to established procedures Check whether etc.) activities of substances, (e.g. management order working it is in appropriate that ensure to and has been checked is available equipment response Emergency displayed are details) service contact (including site/emergency plan and arrangements response Emergency site the employment throughout available or are observed are the environment to No spills or leaks could that for a major incident potential is the whether there confirm and neighbouring properties/operations Review compliance finding) than a rather be an observation (this would site impact the employment and implemented been established have for a major incident the potential prevent/reduce to and procedures Policies etc.) training handbook, induction employee (e.g. policies and procedures, written (e.g. policies written and implemented been established have response emergency for and procedures Policies this potential compliance and management concerning major incident and regulations of laws is aware M anagement workers to communicated is effectively management major incident regarding and processes Policies and regulations laws with applicable compliance ensure to resources the appropriate provide M anagement is maintained of major incidents and severity occurrence the potential reduce to been implemented have M easures site the employment at and impacts occurrence potential reduction in the a and achieving in promoting engaged is actively M anagement of major incidents to reducing risk relation in practice mechanisms of leading the implementation promoting is actively M anagement of major incidents Where there is the potential for a major incident to occur, confirm whether the employment site has identified has identified site the employment whether confirm to occur, for a major incident is the potential there Where 8.1 Physical employment site inspection site employment 8.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 8.2 Employment LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  LE V EL 3 ❒  LE V EL 2 E M S as per the site for major incidents the potential prevent/reduce in place to are and processes systems ❒ Formal E M S as per the site response emergency in place for are and processes systems ❒ Formal 8.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  …

37_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile no Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts m ent Manage

I ncident Gloss a ry Major on

A pp endices GSCP Reference Environmental Alert Notification h ering G at Ev idence and procedures, employee handbook, induction training etc.) handbook, induction training employee and procedures, Confirm, through observation, whether substances used and/or activities undertaken at site have the potential potential have the site at activities undertaken used and/or substances whether observation, through Confirm, major incidents cause to requirements in line with legal disposal are use, handling,and/or processing storage, substance H azardous occurring from major incidents potential prevent to being segregated are substances hazardous Ensure cause a major incident to with the potential substances containing and pipework (including tanks) Bulk containers and of sound integrity condition in good are cause a major incident to with the potential substances containing and pipework (including tanks) Bulk containers appropriate labelled, where are followed being are for a major incident the potential prevent/reduce to established procedures Check whether etc.) activities of substances, (e.g. management order working it is in appropriate that ensure to and has been checked is available equipment response Emergency displayed are details) service contact (including site/emergency plan and arrangements response Emergency site the employment throughout available or are observed are the environment to No spills or leaks could that for a major incident potential is the whether there confirm and neighbouring properties/operations Review compliance finding) than a rather be an observation (this would site impact the employment and implemented been established have for a major incident the potential prevent/reduce to and procedures Policies etc.) training handbook, induction employee (e.g. policies and procedures, written (e.g. policies written and implemented been established have response emergency for and procedures Policies this potential compliance and management concerning major incident and regulations of laws is aware M anagement workers to communicated is effectively management major incident regarding and processes Policies and regulations laws with applicable compliance ensure to resources the appropriate provide M anagement is maintained of major incidents and severity occurrence the potential reduce to been implemented have M easures site the employment at and impacts occurrence potential reduction in the a and achieving in promoting engaged is actively M anagement of major incidents to reducing risk relation in practice mechanisms of leading the implementation promoting is actively M anagement of major incidents Where there is the potential for a major incident to occur, confirm whether the employment site has identified has identified site the employment whether confirm to occur, for a major incident is the potential there Where 8.1 Physical employment site inspection site employment 8.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 8.2 Employment LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  LE V EL 3 ❒  LE V EL 2 E M S as per the site for major incidents the potential prevent/reduce in place to are and processes systems ❒ Formal E M S as per the site response emergency in place for are and processes systems ❒ Formal 8.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  …

Global Social Compliance Programme_38

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ero major incident’ target and policy is in place has been documented major incident’ero target GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference workers receive training on major incident prevention and emergency response; and and emergency prevention on major incident training receive • workers training appropriate received have members team response • emergency Communications with the local community show that the risks of major incidents and the associated emergency emergency and the associated of major incidents the risks that community show with the local Communications been discussed have applicable, where procedures, response emergency the site by drills and has been contacted response emergency in site is involved community The local team response for major incidents reduce the potential to mechanisms leading practice has implemented site The employment etc.) (e.g. changes process and operations site employment relevant to available made are response procedures and emergency prevention M ajor incident personnel and is maintained on-site with activities undertaken associated the risks plan reflects emergency site The employment date up to services and local authorities, emergency to local response plan of the emergency communication Documented required as communities, Workers understand how they, and their site’s activities and operations, can cause major incidents can activities and operations, and their site’s they, how understand Workers applicable where permit/licence requirements, response and emergency of major incident aware are workers Key at induction response and emergency prevention on major incident training receive Workers prevention training on their specific receive of major incidents for the prevention with responsibilities workers Key response emergency and relevant response procedures and emergency prevention major incident and understand, access to, have Workers is in place team response emergency site A dedicated response and emergency prevention major incident to relate permits and licences that site employment Relevant date and up to available are prevention to the relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the on file retained is the documentation major incidents, to of or response activities the site’s to scenarios related all emergency and documented has considered site The employment indicate: etc.) matrix training (e.g.records, induction materials Training stakeholders relevant to been reported have M ajor incidents scenarios for all emergency carried out drills are practice regular that evidence Documented and closed out have been implemented practice drills from actions identified Improvement and documented are undertaken reviews (QRA) Risk Assessment Quantitative Regular A ‘ Z ❒  ❒  ❒  ❒  ❒  ❒  Interviews with key workers/other workers used to corroborate worker testimony with Document checks with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  checks 8.4 Document LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  LE V EL 3 ❒  …

39_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification ero major incident’ target and policy is in place has been documented major incident’ero target workers receive training on major incident prevention and emergency response; and and emergency prevention on major incident training receive • workers training appropriate received have members team response • emergency Communications with the local community show that the risks of major incidents and the associated emergency emergency and the associated of major incidents the risks that community show with the local Communications been discussed have applicable, where procedures, response emergency the site by drills and has been contacted response emergency in site is involved community The local team response for major incidents reduce the potential to mechanisms leading practice has implemented site The employment etc.) (e.g. changes process and operations site employment relevant to available made are response procedures and emergency prevention M ajor incident personnel and is maintained on-site with activities undertaken associated the risks plan reflects emergency site The employment date up to services and local authorities, emergency to local response plan of the emergency communication Documented required as communities, Workers understand how they, and their site’s activities and operations, can cause major incidents can activities and operations, and their site’s they, how understand Workers applicable where permit/licence requirements, response and emergency of major incident aware are workers Key at induction response and emergency prevention on major incident training receive Workers prevention training on their specific receive of major incidents for the prevention with responsibilities workers Key response emergency and relevant response procedures and emergency prevention major incident and understand, access to, have Workers is in place team response emergency site A dedicated response and emergency prevention major incident to relate permits and licences that site employment Relevant date and up to available are prevention to the relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the on file retained is the documentation major incidents, to of or response activities the site’s to scenarios related all emergency and documented has considered site The employment indicate: etc.) matrix training (e.g.records, induction materials Training stakeholders relevant to been reported have M ajor incidents scenarios for all emergency carried out drills are practice regular that evidence Documented and closed out have been implemented practice drills from actions identified Improvement and documented are undertaken reviews (QRA) Risk Assessment Quantitative Regular A ‘ Z ❒  ❒  ❒  ❒  ❒  ❒  Interviews with key workers/other workers used to corroborate worker testimony with Document checks with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  checks 8.4 Document LE V EL 1 ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  LE V EL 3 ❒  …

Global Social Compliance Programme_40

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

no No Audit R equest Audit es Y tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

P re v ention GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit P ollution G roundwater Audit O ut p uts Audit and

ry a ry oil /S Gloss L and GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference site sources of potential soil and groundwater impact soil and groundwater of potential sources - site A pp endices m inated onta C on

based (as appropriate) soil and groundwater risk assessment completed including: completed assessment risk soil and groundwater - based (as appropriate) h ering G at Ev idence GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference ot causing or knowingly permitting contamination of soil and groundwater of soil and contamination permitting or knowingly ot causing Confirm, through observation, whether substances used, wastes stored and/or activities undertaken at site have site at activities undertaken and/or stored wastes used, substances whether observation, through Confirm, to impact underlying soil and groundwater the potential of sound integrity and are condition in good are containment/bunds Secondary followed being are to soil and groundwater for impact the potential prevent/reduce to established Procedures etc.) activities of substances, (e.g. management order working it is in appropriate that ensure to and has been checked is available equipment response Emergency observed are the environment to No spills or leaks ground of unprotected is no staining There activities burning or burying of waste been subject to have site of the employment No areas activities impacting off-site for potential is the whether there confirm and neighbouring properties/operations Review compliance rather than a would be an observation (this site the employment onto migrating soil and groundwater finding) have been prevention pollution and groundwater land/soil contaminated to in relation and procedures Policies etc.) training, handbook, induction employee (e.g. policies and procedures, written and implemented established prevention pollution and groundwater land/soil contaminated to in place relation are and processes systems Formal E M S as per the site Bulk containers (including tanks), pipework containing substances with the potential to cause impact to the environment to the environment cause impact to with the potential substances containing pipework tanks), (including containers Bulk and of sound integrity condition good in are Meet legal requirements legal Meet maintained held and compliance permits are - date up - to Relevant, vicinity site’s in receptors setting/sensitive of site and awareness Understanding EMS as per the site soil and groundwater contaminated manage in place to and processes systems Formal desk Qualitative, impact soil and groundwater of potential sources on - site and historical current a. All potential off and historical current b. All potential and pathways c. Mapping of all receptors impact of risk soil and groundwater d. Assessment required: e.g. risk assessment, and as for soil and groundwater results following completed All actions Phase II investigation a. Focused performed contamination groundwater of soil and/or remediation and efficient b. Appropriate required as stakeholders, relevant to communicated is contamination soil and groundwater Any and policy in place target contamination’ Zero 9.1 Physical employment site inspection site employment 9.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 9.2 Employment LE V EL 1 ❒  ❒  Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete

2. 3. 4. n 6. 7. 8. 3: Level 9 . quality of soil and groundwater management 10. Proactive remediation to relation and in contamination groundwater soil and/or further/future to prevent techniques in place 11. L eading practice contamination groundwater soil and/or of potential awareness to ensure community in the local stakeholders with engagement 12. Proactive contamination groundwater of soil and and management to the prevention chain in relation the value down stakeholders with appropriate 13. Engagement and should not limit audit activities. as guidance are intended checks The following 9. Contaminated land/soil and groundwater pollution prevention and groundwater land/soil 9. Contaminated level: each performance at requirements site Employment 1: Level 1. 2: Level 5.

41_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile no No es Y Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions P re v ention GSCP Reference Environmental Audit Checks P ollution Audit O ut p uts G roundwater and

Gloss oil /S a ry L and A pp endices site sources of potential soil and groundwater impact soil and groundwater of potential sources - site GSCP Reference Environmental Alert Notification m inated onta C on based (as appropriate) soil and groundwater risk assessment completed including: completed assessment risk soil and groundwater - based (as appropriate) h ering G at Ev idence ot causing or knowingly permitting contamination of soil and groundwater of soil and contamination permitting or knowingly ot causing Confirm, through observation, whether substances used, wastes stored and/or activities undertaken at site have site at activities undertaken and/or stored wastes used, substances whether observation, through Confirm, to impact underlying soil and groundwater the potential of sound integrity and are condition in good are containment/bunds Secondary followed being are to soil and groundwater for impact the potential prevent/reduce to established Procedures etc.) activities of substances, (e.g. management order working it is in appropriate that ensure to and has been checked is available equipment response Emergency observed are the environment to No spills or leaks ground of unprotected is no staining There activities burning or burying of waste been subject to have site of the employment No areas activities impacting off-site for potential is the whether there confirm and neighbouring properties/operations Review compliance rather than a would be an observation (this site the employment onto migrating soil and groundwater finding) have been prevention pollution and groundwater land/soil contaminated to in relation and procedures Policies etc.) training, handbook, induction employee (e.g. policies and procedures, written and implemented established prevention pollution and groundwater land/soil contaminated to in place relation are and processes systems Formal E M S as per the site Bulk containers (including tanks), pipework containing substances with the potential to cause impact to the environment to the environment cause impact to with the potential substances containing pipework tanks), (including containers Bulk and of sound integrity condition good in are Meet legal requirements legal Meet maintained held and compliance permits are - date up - to Relevant, vicinity site’s in receptors setting/sensitive of site and awareness Understanding EMS as per the site soil and groundwater contaminated manage in place to and processes systems Formal desk Qualitative, impact soil and groundwater of potential sources on - site and historical current a. All potential off and historical current b. All potential and pathways c. Mapping of all receptors impact of risk soil and groundwater d. Assessment required: e.g. risk assessment, and as for soil and groundwater results following completed All actions Phase II investigation a. Focused performed contamination groundwater of soil and/or remediation and efficient b. Appropriate required as stakeholders, relevant to communicated is contamination soil and groundwater Any and policy in place target contamination’ Zero 9.1 Physical employment site inspection site employment 9.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 9.2 Employment LE V EL 1 ❒  ❒  Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete

2. 3. 4. n 6. 7. 8. 3: Level 9 . quality of soil and groundwater management 10. Proactive remediation to relation and in contamination groundwater soil and/or further/future to prevent techniques in place 11. L eading practice contamination groundwater soil and/or of potential awareness to ensure community in the local stakeholders with engagement 12. Proactive contamination groundwater of soil and and management to the prevention chain in relation the value down stakeholders with appropriate 13. Engagement and should not limit audit activities. as guidance are intended checks The following 9. Contaminated land/soil and groundwater pollution prevention and groundwater land/soil 9. Contaminated level: each performance at requirements site Employment 1: Level 1. 2: Level 5.

Global Social Compliance Programme_42

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss ero contamination’ target and policy target contamination’ ero GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices on-site and off-site current and historical sources of contamination; of sources and historical current and off-site on-site contamination; of by those sources impacts presented soil and groundwater the potential and hence identified; the contamination for and receptors all pathways quality soil and groundwater of risk to assessment an overall and Phase II investigation focussed contamination groundwater of soil and/or remediation and efficient appropriate GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference •  •  •  •  •  •  and/or groundwater contamination and in relation to remediation to relation and in contamination groundwater and/or of potential awareness to ensure community in the local stakeholders with in engaging proactive are M anagement contamination groundwater soil and/or to the prevention chain in relation the value down stakeholders with appropriate engage M anagement contamination of soil and groundwater and management groundwater can impact soil and activities and operations, and their site’s they, how understand Workers requirements, permit/licence pollution prevention and groundwater land/soil of contaminated aware are workers Key applicable where appropriate induction, where issues at on soil and groundwater training receive Workers receive responsibilities management pollution prevention and groundwater land/soil with contaminated workers Key required as specific training procedures, pollution prevention and groundwater land/soil contaminated and understand, access to, have Workers appropriate where currently not buried on-site are materials waste that confirm Workers historically not been buried on-site have materials waste that confirm Workers anagement are proactive in maintaining and improving soil and groundwater quality soil and groundwater and improving in maintaining proactive are M anagement soil further/future prevent to techniques practice of leading the implementation promotes actively M anagement anagement understands and are aware of site setting/sensitive receptors in site’s vicinity site’s in receptors setting/sensitive of site aware and are understands M anagement pollution and groundwater land/soil contaminated concerning and regulations of laws is aware M anagement compliance and prevention effectively are pollution prevention and groundwater land/soil contaminated regarding and processes Policies workers to communicated and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained currently not buried on-site are materials waste that confirms M anagement historically not been buried on-site have materials waste that confirms M anagement all potential account into take to date completed assessments the soil and groundwater that confirms M anagement namely soil and groundwater, of risk to sources risk assessment groundwater for soil and results following completed been have all actions that confirm M anagement including, as required: internal relevant to communicated is contamination soil and groundwater any ensures site The employment stakeholders and external a ‘ Z and promote implemented have M anagement anagement confirms soil and groundwater assessments, and actions resulting from the risk assessment, are completed are from the risk assessment, resulting and actions assessments, soil and groundwater confirms M anagement ❒  ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  9.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  activities and operations site from impact on soil and groundwater the potential understand ❒ M anagement of soil and groundwater permit contamination do not knowingly ❒ M anagement ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  LE V EL 3 ❒  …

43_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry ero contamination’ target and policy target contamination’ ero A pp endices GSCP Reference Environmental Alert Notification on-site and off-site current and historical sources of contamination; of sources and historical current and off-site on-site contamination; of by those sources impacts presented soil and groundwater the potential and hence identified; the contamination for and receptors all pathways quality soil and groundwater of risk to assessment an overall and Phase II investigation focussed contamination groundwater of soil and/or remediation and efficient appropriate •  •  •  •  •  •  and/or groundwater contamination and in relation to remediation to relation and in contamination groundwater and/or of potential awareness to ensure community in the local stakeholders with in engaging proactive are M anagement contamination groundwater soil and/or to the prevention chain in relation the value down stakeholders with appropriate engage M anagement contamination of soil and groundwater and management groundwater can impact soil and activities and operations, and their site’s they, how understand Workers requirements, permit/licence pollution prevention and groundwater land/soil of contaminated aware are workers Key applicable where appropriate induction, where issues at on soil and groundwater training receive Workers receive responsibilities management pollution prevention and groundwater land/soil with contaminated workers Key required as specific training procedures, pollution prevention and groundwater land/soil contaminated and understand, access to, have Workers appropriate where currently not buried on-site are materials waste that confirm Workers historically not been buried on-site have materials waste that confirm Workers anagement are proactive in maintaining and improving soil and groundwater quality soil and groundwater and improving in maintaining proactive are M anagement soil further/future prevent to techniques practice of leading the implementation promotes actively M anagement anagement understands and are aware of site setting/sensitive receptors in site’s vicinity site’s in receptors setting/sensitive of site aware and are understands M anagement pollution and groundwater land/soil contaminated concerning and regulations of laws is aware M anagement compliance and prevention effectively are pollution prevention and groundwater land/soil contaminated regarding and processes Policies workers to communicated and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained currently not buried on-site are materials waste that confirms M anagement historically not been buried on-site have materials waste that confirms M anagement all potential account into take to date completed assessments the soil and groundwater that confirms M anagement namely soil and groundwater, of risk to sources risk assessment groundwater for soil and results following completed been have all actions that confirm M anagement including, as required: internal relevant to communicated is contamination soil and groundwater any ensures site The employment stakeholders and external a ‘ Z and promote implemented have M anagement anagement confirms soil and groundwater assessments, and actions resulting from the risk assessment, are completed are from the risk assessment, resulting and actions assessments, soil and groundwater confirms M anagement ❒  ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  9.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  activities and operations site from impact on soil and groundwater the potential understand ❒ M anagement of soil and groundwater permit contamination do not knowingly ❒ M anagement ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  ❒  LE V EL 3 ❒  …

Global Social Compliance Programme_44

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ero contamination’ target and policy is maintained on-site and is available and is on-site and policy is maintained target contamination’ ero workers receive training on soil and groundwater issues and pollution prevention; and issues and pollution prevention; on soil and groundwater training receive workers pollution prevention and groundwater land/soil their contaminated to applicable training receive workers key and responsibilities roles management GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference •  •  Where the employment site is legally required to hold and/or maintain documentation in relation to contaminated contaminated to relation in documentation maintain hold and/or to required is legally site the employment Where period of time required for the retained on file is the documentation pollution prevention, and groundwater land/soil vicinity site’s in the receptors setting/sensitive the site has documented site The employment available are containment/bunds of inspections secondary Records documented are the environment to of spills or releases Records been documented have sources off-site impacts arising from soil and groundwater known Any site employment relevant to made available are the site impacts at soil and groundwater address that Procedures personnel indicate: etc.) matrix training (e.g.records, induction materials Training including, risk assessments where groundwater to soil and relating documentation maintains site The employment activities remediation results and monitoring Phase II investigations, focussed appropriate, groundwater soil and/or further/future to prevent techniques leading practice has implemented site The employment remediation to relation and in contamination that value chain show the community through and the local stakeholders with appropriate Communications been discussed have contamination of soil and groundwater and management the prevention Relevant employment site permits and licences that relate to contaminated land/soil and groundwater pollution and groundwater land/soil contaminated to relate permits and licences that site employment Relevant to date and up available are prevention A ‘ Z ❒  ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  LE V EL 3 ❒  ❒  9.4 Document checks 9.4 Document LE V EL 1 ❒  ❒  …

45_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile No es Y Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification o negative impact on designated protection areas or species protection impact on designated o negative Meet legal requirements relating to planning and development relating requirements legal Meet maintained held and compliance permits are - date up - to Relevant, EMS as per the site land use and biodiversity manage in place to and processes systems Formal recovery soil and biodiversity promote erosion and avoid soil fertility, soil to maintain management proactive production, In agricultural activities conservation and rehabilitation including deforestation, performance in land use and biodiversity improvement demonstrable appropriate, Where Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete 2. 3. n 5. 6. 3: Level 7. context ecosystem within local l and use is sustainable 8. organisations local relevant with partnership example for conservation, in biodiversity role l eadership 9. land management and leading practice biodiversity to promote mechanisms in place l eading practice boundaries site within and beyond performance, land use and biodiversity improve chain to the value down stakeholders with appropriate 10. Engagement practice standard international recognised beyond targets of stretching achievement 11. D emonstrable and should not limit audit activities. as guidance are intended checks The following 10. Land use and biodiversity level: each performance at requirements site Employment 1: Level 1. 2: Level 4.

Global Social Compliance Programme_46

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

no Audit R equest Audit tion tion

r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit y B iodi v ersit and

Audit O ut p uts Audit U se ry a ry L and on

Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference h ering G at A pp endices Ev idence GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference are minimised are are being procedures site land use and biodiversity whether to check activities a number of operational Review implemented and implemented been established have to land use management in relation and procedures Policies etc.) training handbook, induction employee (e.g. policies and procedures, written and implemented been established have management to biodiversity in relation and procedures Policies etc.) training handbook, induction employee (e.g. policies and procedures, written E M S as per the site to land use management in place relation are and processes systems Formal E M S as per the site management to biodiversity in place relation are and processes systems Formal be used can which the site of the land uses to is aware M anagement activities and operations site from impact on biodiversity the potential understand M anagement compliance and concerning land use and biodiversity and regulations of laws is aware M anagement Employment site operations and activities observed are in line with legal requirements relating to land use (including relating requirements legal are in line with observed and activities operations site Employment requirements) planning permission and development to land use or biodiversity impacts negative that to ensure activities or construction development current Review and land management to land use and biodiversity relation is in practice standard international recognised what understands M anagement those practices exceed that targets set and have their sector/geography for (including planning permission permit/licence requirements of land use and biodiversity aware are workers Key applicable where requirements), appropriate induction, where issues at on land use and biodiversity training receive Workers required training as specific receive responsibilities management with land use and biodiversity workers Key appropriate where procedures, land use and biodiversity and understand, access to, have Workers Policies and processes regarding land use and biodiversity are effectively communicated to workers to communicated effectively are land use and biodiversity regarding and processes Policies and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained in agricultural management proactive or endorses promotes actively management production In agriculture recovery soil and biodiversity promote erosion and avoid soil fertility, soil to maintain production performance in land use and biodiversity improvement appropriate, where demonstrates, site The employment activities conservation and rehabilitation including deforestation, context ecosystem land use within the local of sustainable the concept understands M anagement (e.g.by partnering with local conservation in biodiversity role a leadership demonstrates site The employment organisations) to biodiversity relation practice mechanisms in of leading the implementation promotes actively M anagement ❒  and processes procedures site 10.2 Employment LE V EL 1 ❒  ❒  LE V EL 2 ❒  ❒  10.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  10.1 Physical employment site inspection site employment 10.1 Physical LE V EL 1 ❒  ❒  ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 can impact land use and biodiversity activities and operations, and their site’s they, how understand ❒ Workers ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  LE V EL 3 ❒  ❒  ❒  …

47_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile no Pre pa r a tion

Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts y B iodi v ersit and

U se Gloss L and a ry on

A pp endices GSCP Reference Environmental Alert Notification h ering G at Ev idence are minimised are are being procedures site land use and biodiversity whether to check activities a number of operational Review implemented and implemented been established have to land use management in relation and procedures Policies etc.) training handbook, induction employee (e.g. policies and procedures, written and implemented been established have management to biodiversity in relation and procedures Policies etc.) training handbook, induction employee (e.g. policies and procedures, written E M S as per the site to land use management in place relation are and processes systems Formal E M S as per the site management to biodiversity in place relation are and processes systems Formal be used can which the site of the land uses to is aware M anagement activities and operations site from impact on biodiversity the potential understand M anagement compliance and concerning land use and biodiversity and regulations of laws is aware M anagement Employment site operations and activities observed are in line with legal requirements relating to land use (including relating requirements legal are in line with observed and activities operations site Employment requirements) planning permission and development to land use or biodiversity impacts negative that to ensure activities or construction development current Review and land management to land use and biodiversity relation is in practice standard international recognised what understands M anagement those practices exceed that targets set and have their sector/geography for (including planning permission permit/licence requirements of land use and biodiversity aware are workers Key applicable where requirements), appropriate induction, where issues at on land use and biodiversity training receive Workers required training as specific receive responsibilities management with land use and biodiversity workers Key appropriate where procedures, land use and biodiversity and understand, access to, have Workers Policies and processes regarding land use and biodiversity are effectively communicated to workers to communicated effectively are land use and biodiversity regarding and processes Policies and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained in agricultural management proactive or endorses promotes actively management production In agriculture recovery soil and biodiversity promote erosion and avoid soil fertility, soil to maintain production performance in land use and biodiversity improvement appropriate, where demonstrates, site The employment activities conservation and rehabilitation including deforestation, context ecosystem land use within the local of sustainable the concept understands M anagement (e.g.by partnering with local conservation in biodiversity role a leadership demonstrates site The employment organisations) to biodiversity relation practice mechanisms in of leading the implementation promotes actively M anagement ❒  and processes procedures site 10.2 Employment LE V EL 1 ❒  ❒  LE V EL 2 ❒  ❒  10.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  10.1 Physical employment site inspection site employment 10.1 Physical LE V EL 1 ❒  ❒  ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 can impact land use and biodiversity activities and operations, and their site’s they, how understand ❒ Workers ❒  ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  LE V EL 3 ❒  ❒  ❒  …

Global Social Compliance Programme_48

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion

r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices workers receive training on land use and biodiversity issues; and on land use and biodiversity training receive workers and responsibilities roles management their land use and biodiversity to applicable training receive workers key GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference •  •  and biodiversity, the documentation is retained on file for the required period of time required for the on file retained is the documentation and biodiversity, developments, (including planning of new the site issues at land use and biodiversity address that Procedures personnel site employment relevant to available made are etc.) changing processes construction, check buildings etc.), new changes, process (e.g. building extensions, on site changes been recent have If there and documented considered been have impacts on land use and biodiversity potential that ensure to indicate: etc.) matrix training (e.g.records, induction materials Training impact designated does not negatively site the employment that demonstrates that evidence is documented There or species areas protection performance in land use and biodiversity improvement has made demonstrable site The employment role in biodiversity taking a leading is site the employment that show organisations with local Communications conservation context) ecosystem local to the relation (in land use is sustainable whether has identified site The employment and land management biodiversity to promote mechanisms leading practice has implemented site The employment being achieved and are stretching are targets performance Land use and biodiversity performance land and biodiversity that value chain show the through stakeholders with appropriate Communications been discussed have Relevant employment site permits and licences that relate to land use and biodiversity (including planning land use and biodiversity to relate permits and licences that site employment Relevant date and up to available are requirements) and development permission/consent to land use relation in documentation maintain hold and/or to required is legally site the employment Where ❒  ❒  ❒  ❒  LE V EL 2 ❒  LE V EL 3 ❒  ❒  ❒  ❒  ❒  10.4 Document checks 10.4 Document LE V EL 1 ❒  ❒  …

49_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile No es Y Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry A pp endices GSCP Reference Environmental Alert Notification Meet legal requirements legal Meet maintained held and compliance permits are - date up - to Relevant, housekeeping) general noise, visual and impacts (including odour, and associated activities site from of nuisance levels and awareness Understanding EMS as per the site and complaints housekeeping) noise, visual and general nuisances (including odour, manage in place to and processes systems Formal stakeholders and external internal relevant to made available are data Impacts and complaints improvement continuous to drive on an annual basis reviewed are targets reduction Impacts and complaints complaints in nuisance impacts and reduction D emonstrable and policy in place target complaints’ Zero reduce impacts to community/stakeholders with local engagement Proactive Is this performance area applicable to the employment site? the employment to applicable area Is this performance Area. Performance the next to please proceed If no, table. the following If yes, please complete 2. 3. 2: Level 4. 5. 6. 7. 3: Level 8. ‘ 9. process changes reduction of impacts e.g. to ensure mechanisms in place 10. L eading practice practice standard international recognised beyond targets performance of stretching achievement 11. D emonstrable and should not limit audit activities. as guidance are intended checks The following 11. Nuisance level: each performance at requirements site Employment 1: Level 1.

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Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk s GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference t e

no Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit N uisance Audit O ut p uts Audit on

ry a ry Gloss ero complaints’ target and policy target complaints’ ero h ering G at GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference Ev idence A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference anagement actively promotes the implementation of leading practice mechanisms in relation to reducing impacts relation practice mechanisms in of leading the implementation promotes actively M anagement changes) (e.g. process through to nuisance management relation is in practice standard international recognised what understands M anagement those practices exceed that targets set and have their sector/geography for neighbours can impact surrounding activities and operations, and their site’s they, how understand Workers applicable where of nuisance permit/licence requirements, aware are workers Key appropriate induction, where on nuisance issues at training receive Workers required training as specific receive responsibilities management with nuisance and complaints workers Key appropriate where nuisance procedures, and understand, access to, have Workers Confirm, through observation, whether activities undertaken at site, and resulting normal emissions) have resulting normal emissions) site, and at activities undertaken whether observation, through Confirm, neighbours to surrounding cause nuisance to the potential cause nuisance to the potential have or land that water air, no emissions to are There site to the employment adjacent receptors off-site any sensitive are there whether observation, through Confirm, (e.g. schools, housing, etc.) perimeter the site at not noted are site the employment Emissions from followed being are areas to surrounding for impacts the potential prevent/reduce to established Procedures etc.) activities of waste, (e.g. management order working it is in appropriate that ensure to and has been checked is available equipment response Emergency standard is of an acceptable site the employment across housekeeping General observed are the environment to No spills or leaks (e.g. written and implemented been established have to nuisance management in relation and procedures Policies etc.) handbook, induction training, employee policies and procedures, noise, visual and general nuisances (including odour, manage in place to are and processes systems Formal E M S as per the site housekeeping) E M S nuisances as per the site on-site arising from complaints manage in place to are and processes systems Formal impacts activities and associated site from nuisance levels of potential aware and are understand M anagement housekeeping) noise, visual and general (including odour, anagement is aware of laws and regulations concerning nuisance and compliance concerning nuisance and and regulations of laws is aware M anagement workers to communicated effectively nuisance are regarding and processes Policies site the employment by received are that of complaints is aware M anagement and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained and external internal relevant to is made available data impacts and complaints ensures site The employment communities and local stakeholders in nuisance impacts and complaints improvement appropriate, where demonstrates, site The employment a ‘ Z and promote implemented have M anagement anagement are proactively driving continuous improvement through reviewing complaints targets on an annual basis targets complaints reviewing through improvement continuous driving proactively are M anagement ❒  ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  11.1 Physical employment site inspection site employment 11.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 11.2 Employment LE V EL 1 ❒  ❒  ❒  11.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  LE V EL 3 ❒  …

51_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S … GSCP Reference Environmental Supplementary Audit Information ystem s t e Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile no Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts N uisance on

Gloss a ry ero complaints’ target and policy target complaints’ ero h ering G at A pp endices GSCP Reference Environmental Alert Notification Ev idence anagement actively promotes the implementation of leading practice mechanisms in relation to reducing impacts relation practice mechanisms in of leading the implementation promotes actively M anagement changes) (e.g. process through to nuisance management relation is in practice standard international recognised what understands M anagement those practices exceed that targets set and have their sector/geography for neighbours can impact surrounding activities and operations, and their site’s they, how understand Workers applicable where of nuisance permit/licence requirements, aware are workers Key appropriate induction, where on nuisance issues at training receive Workers required training as specific receive responsibilities management with nuisance and complaints workers Key appropriate where nuisance procedures, and understand, access to, have Workers Confirm, through observation, whether activities undertaken at site, and resulting normal emissions) have resulting normal emissions) site, and at activities undertaken whether observation, through Confirm, neighbours to surrounding cause nuisance to the potential cause nuisance to the potential have or land that water air, no emissions to are There site to the employment adjacent receptors off-site any sensitive are there whether observation, through Confirm, (e.g. schools, housing, etc.) perimeter the site at not noted are site the employment Emissions from followed being are areas to surrounding for impacts the potential prevent/reduce to established Procedures etc.) activities of waste, (e.g. management order working it is in appropriate that ensure to and has been checked is available equipment response Emergency standard is of an acceptable site the employment across housekeeping General observed are the environment to No spills or leaks (e.g. written and implemented been established have to nuisance management in relation and procedures Policies etc.) handbook, induction training, employee policies and procedures, noise, visual and general nuisances (including odour, manage in place to are and processes systems Formal E M S as per the site housekeeping) E M S nuisances as per the site on-site arising from complaints manage in place to are and processes systems Formal impacts activities and associated site from nuisance levels of potential aware and are understand M anagement housekeeping) noise, visual and general (including odour, anagement is aware of laws and regulations concerning nuisance and compliance concerning nuisance and and regulations of laws is aware M anagement workers to communicated effectively nuisance are regarding and processes Policies site the employment by received are that of complaints is aware M anagement and regulations laws with applicable compliance that ensure to resources the appropriate provide M anagement is maintained and external internal relevant to is made available data impacts and complaints ensures site The employment communities and local stakeholders in nuisance impacts and complaints improvement appropriate, where demonstrates, site The employment a ‘ Z and promote implemented have M anagement anagement are proactively driving continuous improvement through reviewing complaints targets on an annual basis targets complaints reviewing through improvement continuous driving proactively are M anagement ❒  ❒  with Document checks testimony worker corroborate used to workers workers/other with key Interviews the following: confirm They interviews. and management LE V EL 1 ❒  ❒  ❒  ❒  ❒  11.1 Physical employment site inspection site employment 11.1 Physical LE V EL 1 ❒  ❒  ❒  ❒  ❒  ❒  ❒  ❒  and processes procedures site 11.2 Employment LE V EL 1 ❒  ❒  ❒  11.3 Interviews the following: confirm with management Interviews LE V EL 1 ❒  ❒  ❒  ❒  ❒  LE V EL 2 ❒  ❒  ❒  LE V EL 3 ❒  …

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Appendix 3: GSCP Reference Environmental Audit Checks

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry Gloss GSCP Reference Environmental Audit Checks Audit Checks Environmental GSCP Reference

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ero complaints’ target and policy is maintained on-site and is available on-site and policy is maintained target complaints’ ero workers receive training on nuisance issues; and training receive workers and responsibilities roles management their nuisance and complaints to applicable training receive workers key GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference •  •  Where the employment site is legally required to hold and/or maintain documentation in relation to nuisance relation in documentation maintain hold and/or to required is legally site the employment Where and complaints, the documentation is retained on file for the required period of time required for the on file retained is the documentation and complaints, personnel site employment relevant to made available are the site nuisance impacts at address that Procedures indicate: etc.) matrix training (e.g.records, induction materials Training performance in nuisance impacts and complaints improvement has made demonstrable site The employment nuisance impact management to promote mechanisms leading practice has implemented site The employment being achieved and are stretching are targets performance Nuisance impacts and complaints nuisance that value chain show the community through and the local stakeholders with appropriate Communications been discussed issues have impacts and complaints Relevant employment site permits and licences that relate to nuisance are available and up to date and up to available nuisance are to relate permits and licences that site employment Relevant register complaints date an up to maintains site The employment A ‘ Z ❒  ❒  ❒  LE V EL 2 ❒  LE V EL 3 ❒  ❒  ❒  11.4 Document checks 11.4 Document LE V EL 1 ❒  ❒  ❒  …

53_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction R isk Assessment S Appendix 4

GSCP Reference GSCP Reference Environmental Supplementary Audit Information Environmental ystem Audit R equest Alert Notification GSCP Reference Environmental Pre-Audit Employment Site Profile

Where a ‘critical’ non-compliance Pre pa r a

is identified: tion

Where a ‘critical’ non-compliance is identified, the auditor Please note that if an auditor believes they might be at risk Audit E xecution should follow the escalation policies of the audit requestor. as a result of communicating a critical non-compliance, GSCP Reference Environmental of Findings and Corrective Summary Actions Wherever possible, the auditor should inform the audit the audit team should wait until it is removed from that requestor as soon as a ‘critical’ non-compliance is identified. situation before issuing the alert notification. If the audit requestor is on site, the auditor should Auditors should prioritise the welfare of workers when communicate the critical non-compliance immediately. This

deciding how to inform employment site management of any GSCP Reference Environmental Audit Checks will enable the audit requestor and the employment site to critical non-compliance. Auditors should follow the escalation

work together to plan an appropriate and timely resolution Audit O ut p uts policies of the audit requestor to minimise any risk to workers. to the issue.

Examples of critical non-compliances include

• An environmental aspect which represents imminent risk • Auditors denied access or obstructed from conducted from Gloss of serious or significant impact to the environment (e.g. conducting a proper audit

major damage to a local ecosystem, closure of a potable a ry • Non-operation of critical abatement equipment e.g. air water abstraction point, known on-site or off-site impact emission scrubber, incineration unit etc. to soil, groundwater or surface water). GSCP Reference Environmental Alert Notification

• Evidence of the deliberate provision of false information A pp endices • Relevant inventory/register not established in relation to to auditors or regulators so as to disguise non-compliances a particular Performance Area, which has the potential with permit/licence/consent requirements. to result in non-compliance with permit/licence/consent requirements or which results in mis-management of • Performance or monitoring data manipulated or environmental matters with the potential for significant misreported to intentionally mislead regulators. impact to the environment. • A major non-compliance from a previous audit that has • Site currently under threat of prosecution, fine and/or not been addressed or in relation to which no significant enforcement in relation to an environmental issue, e.g. the improvement has been made by the time of a follow up site has identified that permit/licence/consent/exemption is audit and which has increased the level of environmental required, but not obtained it. risk, e.g. of causing incidents. • An attempt to pervert the course of the audit through • Site knowingly utilises illegal/unlicensed external third fraud, coercion, deception or interference. parties in relation to environmental matters (e.g. waste removal/disposal). • A systemic violation of a legal requirement that has attracted (or could likely attract) regulator intervention (e.g. continued illegal disposal of waste materials, either on-site or off-site).

Global Social Compliance Programme_01

Appendix 4: GSCP Reference Environmental Alert Notification

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem Reference Alert Notification GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

1. Key information isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference Employment site and Audit Information

Name of the audited company:

Supplier name: Audit R equest Audit Employment site name:

tion tion Country:

Audit date: r a Pre pa

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference Date of alert:

Lead auditor:

Issue area(s): GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference

xecution E xecution Audit

2. Details of critical non-compliance(s)

Critical non-compliances should be presented in a consistent format, with sufficient detail concerning the issue(s) and its context to enable useful remediation discussions to begin. A table should be completed for each issue found. Audit O ut p uts Audit Critical Non-compliance

ry a ry Legislation or environmental topic: GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss Description of critical non-compliance:

Auditor findings (description,

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference extent of issue, direct consequences of the issue, etc):

A pp endices Documentary, interview and other evidence found:

Management response:

Proposed corrective actions: GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

02_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction R isk Assessment S

Appendix 5 ystem

GSCP Reference GSCP Reference Environmental Supplementary Audit Information Audit R equest Environmental Audit Report GSCP Reference Environmental Pre-Audit Employment Site Profile

This tool forms part of the GSCP set of reference tools for a site in the supply chain to demonstrate continuous designed to provide a common interpretation of local and improvement in its environmental performance from basic Pre pa r a international environmental standards and requirements and compliance to leading-edge performance (across three environmental reference codes (if available and applicable). defined ‘levels’ for eleven different performance areas). The Environmental Reference Requirements reflect a tion common understanding of good environmental practice and The reference tools on Environmental Audit Process and are applicable to all raw material processing, agricultural, Methodology are based on the GSCP Environmental manufacturing and logistics sites in the supply chain. The Reference Requirements but can be adopted and tailored to Audit E xecution Environmental Reference Requirements provide a model other codes of environmental practice. GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks

The context, findings, issues and actions Audit O ut p uts against each area of the audit standard used should be reported to the audit

requestor Gloss

The report should include: For each environmental Performance Area, the report should: a ry

• a summary of the auditors’ evaluation of the employment • describe the current situation including which of the GSCP GSCP Reference Environmental Alert Notification site’s performance against each of the 11 Performance Environmental Reference Requirements the site is currently A pp endices Areas; meeting; • identified non-compliances which indicate that the • provide evidence and information to substantiate the findings; employment site is not meeting Level 1 of the GSCP • for each non-compliance or observation, provide a: Environmental Reference Requirements; / description of the non-compliance or observation and • observations and good practices. its frequency; / evidence found to substantiate it; / classification to applicable law, code of conduct, etc; / if required by the audit requestor, recommended corrective action with a timeframe for completion and responsibility.

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem The report should include photos of the employment site Auditors may feel the need to separately report to the audit such as*: requestor in the event that, for example, the auditor has: • outside general overview; • information that is too sensitive for the audit report itself; • inside general overview • concerns which cannot be substantiated through evidence

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference and/or interviews; • key activities and processes that have potential environmental isk Assessment S Assessment R isk impact; • commentary/insight on the attitude of management GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

towards the non-compliances or where management was • waste handling and storage areas; obstructive to the audit process; • hazardous substance storage areas; • concerns about the possibility of falsified records. • areas of potential impact to soil and groundwater including The process for reporting such information should be agreed staining and distressed vegetation; between the audit requestor and the auditor in advance of Audit R equest Audit • bulk storage tanks and secondary containment; the audit. • wastewater treatment areas; This type of reporting may not be appropriate where the

tion tion audit requestor is the employment site itself. • abatement equipment; • good practices where these can be photographed; r a Pre pa • non-compliances where these can be photographed. Unless agreed by all parties in writing, the audit organisation will not distribute the report to any entities except the audit

GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference requestor. However, the audit requestor should share the report with the employment site/customer/supplier as soon as possible in order to facilitate co-operation on continuous GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference improvement. xecution E xecution Audit Audit O ut p uts Audit ry a ry GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

*Photographs should only be taken with the permission of the employment site as they may contain or reveal confidential information.

02_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

of

ations 3 v ystem N u m ber O bser GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile 5 (4) M inor z ero if

m pliances co - Pre pa r a 5 (2) M ajor non

indicate

of

tion P lease of legal compliances identified) compliances of legal 1 (0) N u m ber Critical (Please indicate in brackets the number in brackets (Please indicate Audit E xecution

GSCP Reference Environmental of Findings and Corrective Summary Actions

rating

R eference GSCP Reference Environmental Audit Checks L e v el Audit O ut p uts <>. against applicable legal requirements and the GSCP Environmental Reference Reference and the GSCP Environmental requirements legal applicable against <> evel 1, L evel ot achieved Auditor level rating level Auditor Not achieved Level 1 Level Not achieved ( N evel 3) 2, L evel L evel 1, L evel m ents R equire on behalf of m ental E n v iron GSCP Gloss y a ry <>, on GSCP Reference Environmental Alert Notification A pp endices A rea m ance P erfor m ental E n v iron Example Performance Area Performance Example Environmental management systems management Environmental G H Gs use, transport Energy use Water Wastewater/effluent air Emissions to management Waste hazardous and potentially prevention/hazardous Pollution substances management M ajor incident pollution prevention and groundwater land/soil Contaminated Land use and biodiversity Nuisance <>. strengths and also areas key visit, highlighting during the site identified performance <> <

Global Social Compliance Programme_03

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem 2. Reference Audit Report

2.1 General information GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk

GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference 1.0 Employment site contact Name:

details: Address:

Country:

Audit R equest Audit Telephone:

Fax/email: tion tion GPS cordinates:

Is this site in an Export Processing Zone (EPZ)*? Yes ❒ No ❒ r a Pre pa 1.1 Audit date(s):

1.2 Report issue date: GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

1.3 Audit type: Initial Full Audit Announced Follow-up Partial Audit Semi-announced

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Unannounced xecution E xecution Audit 1.4 Audit conducted by: Auditing Company (please provide name below)

Retailer Brand Owner Purchaser NGO Union Audit O ut p uts Audit Multiple parties. If yes, please list. ry a ry 1.5 Audit personnel Name: Name: (please specify the names Title: Title: GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

and titles of the auditors and worker interviewers Name: Name: who conducted the audit) Title: Title:

1.6 Time in and time out: In: Out:

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference 1.7 Previous audit details (if any): • Audited conducted by: A pp endices

• Audit date:

• Audit type:

GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference …

* “Industrial zones with special incentives set up to attract foreign investors, in which imported materials undergo some degree of processing before being re-exported” (ILO, 2007)

04_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

… ystem • Audited conducted by: GSCP Reference Environmental Supplementary Audit Information

• Audit date: Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile

• Audit type:

• Audited conducted by: Pre pa r a • Audit date: tion • Audit type:

1.8 Supplier name: Audit E xecution

1.9 Main employment site contact: Name:

Position: GSCP Reference Environmental of Findings and Corrective Summary Actions

Telephone: GSCP Reference Environmental Audit Checks 1.10 Name and job title of Name:

employment site representative Title: Audit O ut p uts who signed the summary of findings and corrective actions

1.11 Audits results reviewed by Yes No employment site management?

1.12 Audit report author: Gloss 1.13 Audit report reviewer:

1.14 General remarks: a ry GSCP Reference Environmental Alert Notification A pp endices

Global Social Compliance Programme_05

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem 2.2 Employment site information 2.2.1 Production systems and processes GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

2.1.1 Industry sector: isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

2.1.2 Principal products:

2.1.3 Main export markets:

2.1.4 Main production processes

Audit R equest Audit (e.g. Stitching, labelling, injection, moulding, baking, harvesting, dyeing etc.): tion tion 2.1.5 Main production equipment:

2.1.6 Main raw materials used: r a Pre pa

2.1.7 List of hazardous chemicals used employment site: GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference 2.2.2 Audit overview and history xecution E xecution Audit

2.2.1 Applicable environment-related code of conduct, if appropriate

2.2.2 Was a perimeter survey undertaken? Yes No If Yes, please detail the results Audit O ut p uts Audit

ry a ry 2.2.3 Were any alert notifications issued as part of this audit? Yes No If yes, how many? GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

06_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S

2.3 Reporting template

The audit report includes ‘Findings’ and ‘Evidence’ columns as per the example below for each of the 11 Performance Areas against which the audit was conducted. For follow-up audits, the report issued should be an updated version of the original ystem report, with all new issues and updates to previous issues clearly highlighted. An example of how to include follow-up information in the audit report template is shown below. GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Finding Evidence (Summary of requirement, plus description of the finding, (A description of the evidence observed and related to the details of the management position, any management audit check guidelines. Please indicate the type of evidence involvement and element of the law that has been violated) listed e.g. worker interview, documentary, observational)

e.g. Waste Management Documentary

Site was not in possession of appropriate waste permit. No permit available. Pre pa r a Management Interview Site management not aware of requirement. tion Follow up 01/06/09 – Follow-up 01/06/09 – Site obtained relevant permit from local authority. Documentary

Copy of permit sent to auditor. Audit E xecution

Follow up 01/06/09 – New Issue Follow up 01/06/09 – New issue

Waste management Management Interviews GSCP Reference Environmental of Findings and Corrective Summary Actions Site management has not communicated requirements of Management reported that it has scheduled a half day permit to relevant site personnel. awareness raising session on requirements of the new waste

permit. GSCP Reference Environmental Audit Checks Audit O ut p uts

The tables below present the findings of the audit against The Audit Report records whether the non-compliance each of the GSCP Environmental Reference Requirement. At identified is a non-compliance with specific legal requirements. Level 1 non-compliances are categorised into Critical, Major and Minor non-compliances, together with an indication Minor as to where these represent non-compliances with legal Gloss • basic environmental management structure and defined requirements. in case legal requirements do not exist in the management responsibilities are in place, however, this is site’s country of operations, these reference requirements a ry not documented; can be used as reference and also as parameters against which non compliances can be identified. • site has identified and is managing its potentially significant GSCP Reference Environmental Alert Notification aspects and impacts but has not documented this process/ A pp endices For Level 2 and Level 3, the tables state whether a particular the results; requirement has been ‘met’ or ‘not met’. There is then a summary of good practices identified. Each section is • relevant inventory/register established in relation to a completed with an overall summary statement in relation to particular Performance Area, but not actively maintained; which Level the auditor believes the site has achieved. • an occasional or isolated compliance issue e.g. missing records/documentation in relation to permit/consent/ Definitions and examples of non-compliances: licence requirements; • the site has a mechanism to remain up to date with applicable A non-compliance is a specific breach of the standard or local legal requirements, but has not documented this code against which the employment site was audited. process; In relation to Level 1 Requirements, a non-compliance is • an issue which presents a risk to the environment (low risk) categorised as a: (either on-site or the surrounding areas); • minor non-compliance; • site has a procedure to ensure that external third parties • major non-compliance; or utilised by the site for environmental matters (e.g. waste • critical non-compliance. removal/disposal) are appropriately licensed, but has not documented this process;

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction nvironmental Audit Report Audit Report nvironmental ystem E • occasional or isolated instances of missing monitoring/ • site currently under threat of prosecution, fine and/or performance data (that is not a legal requirement). enforcement in relation to an environmental issue; nvironmental Self Assessment Questionnaire Questionnaire Self Assessment nvironmental

E • an attempt to pervert the course of the audit through

Reference Reference Major P fraud, coercion, deception or interference;

GSC • basic management structure/defined management • a systemic violation of a legal requirement that has attracted

Reference Reference responsibilities not in place, either in relation to overall isk Assessment S Assessment R isk P (or could likely attract) regu lator intervention (e.g. continued environmental management or particular Performance

GSC illegal disposal of waste materials, either on-site or off-site);

Area; • auditors denied access or obstructed from conducted from nformation nformation I • site has identified that it has potentially significant

rofile rofile conducting a proper audit; P environmental aspects/impacts, but has not acted on this information; • non-operation of critical abatement equipment e.g. air emission scrubber, incineration unit, etc; • site is not aware of its legal requirements in relation to a Audit R equest Audit particular performance area; • evidence of the deliberate provision of false information mployment Site Site mployment

E to auditors or regulators so as to disguise non-compliances • site has no mechanism for remaining up to date with with permit/licence/consent requirements; tion tion applicable legal requirements;

re-Audit re-Audit • performance or monitoring data manipulated or P • sit e not aware of relevant permit/licence/consent/exemption misreported to intentionally mislead regulators;

nvironmental Supplementary Audit Supplementary nvironmental requirements; E r a Pre pa • a major non-compliance from a previous audit that has not • breaches of legislation or permit/licence/consent been addressed or for which no significant improvement nvironmental nvironmental requirements which represents risk of moderate harm to E has been made by the time of a follow up audit, and Reference Reference

P the environment e.g. exceedance of wastewater discharge which has increased the level of environmental risk, e.g. of

GSC limits, exceedance of air emission limit concentration, etc; causing incidents;

Reference Reference

P • a systemic breach or violation of a legal requirement; • site knowingly utilises illegal/unlicensed external third GSC • a breach of a legal requirement or environmental permit/ parties in relation to environmental matters (e.g. waste xecution E xecution Audit licence/consent which is considered likely to attract removal/disposal). regulator intervention; Critical non-compliances should trigger an alert notification • site has not confirmed that all external third parties utilised [see Section 4.5]. by the site for environmental matters (e.g. waste removal/ • An Observation disposal) are appropriately licensed;

indings and Corrective Actions Actions indings and Corrective / a possible issue which could develop into a non- F • relevant inventory/register not established in relation to a compliance if action is not taken by the Employment Audit O ut p uts Audit

nvironmental Audit Checks Checks Audit nvironmental particular Performance Area;

E Site (i.e. a potential non-compliance). • consumption/generation data not collected in relation to / an issue, on which the auditor has some evidence to

ry a ry a particular Performance Area that is relevant to the site; indicate that it may be present, but is not confirmed by Reference Reference

P more than one data point. • site has not provided identified and/or provided training GSC Gloss / an opportunity for improvement e.g. how the

to employees on environmental matters which represent a

nvironmental Summary of nvironmental employment site can meet the requirements of the E serious or significant impact to the environment. next performance level. Critical • Good Practice otification otification N Reference Reference P • an environmental aspect which represents imminent risk / an innovative or novel approach to managing GSC A pp endices of serious or significant impact to the environment (e.g. environmental issues in relation to a particular major damage to a local ecosystem, closure of a potable Performance Area. water abstraction point, known on-site or off-site impact to soil, groundwater or surface water); Level 2 and Level 3 findings nvironmental Alert nvironmental E • sit e has identified that a permit/licence/consent/exemption is The GSCP Environmental Reference Requirements at levels required, but has not obtained it; 2 and 3 are intended to drive performance improvement. As such, the auditor should record only whether the Employment Reference Reference

P • relevant inventory/register not established in relation to Site has met or not met a particular Requirement, as well

GSC a particular Performance Area, which has the potential as observations and examples of good practice. Where the to result in non-compliance with permit/licence/consent auditor identifies that a Requirement is not met, they should requirements or which results in mis-management of provide a short description as to why. environmental matters with the potential for significant impact to the environment;

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S …

ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related Pre pa r a tion

Audit E xecution m s ste o rma n ce areas Sy GSCP Reference Environmental of Findings and Corrective Summary Actions Finding GSCP Reference Environmental Audit Checks that has been violated) that Audit O ut p uts m ent Manage eport

R of the finding and element of the law of the law of the finding and element Summary of requirement, plus description plus description Summary of requirement, Gloss m ental E n v iron 1.0 a ry ❒ GSCP Reference Environmental Alert Notification Observation? A pp endices by perf by u d it R ep o rt ❒ egal L egal Issue? ❒ M inor ❒ M ajor if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one Critical LE V EL 1 3. R efere n ce A

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem … GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Audit R equest Audit (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related tion tion r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference et ❒ ❒ ❒ ❒ ❒ ❒

N ot M xecution E xecution Audit et ❒ ❒ ❒ ❒ ❒ ❒ M

Audit O ut p uts Audit

ry a ry GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices Requirement GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference adequate training; documentation and its control; and its documentation training; adequate audit and inspections; and measurement, checking: monitoring Review.  management environmental Policy; environmental objectives setting risk assessment, planning: environmental and targets; procedures; operational and operation: implementation •  •  •  •  •  LE V EL 2 documented, (E M S) is established, System M anagement Environmental reviewed/improved and continually maintained implemented, The E M S includes: available is made performance on environmental Information stakeholders and external internal appropriate to definition) for detailed section the guidance to (please refer LE V EL 3 leading practice drive to strategy looking environmental Forward Environmental management and environmental performance targets targets performance and environmental management Environmental ecosystem, and local the environment sustain or improve designed to are or global when appropriate Proactive engagement with relevant stakeholders to achieve significant significant to achieve stakeholders relevant with engagement Proactive improvement performance Where relevant, commitment to voluntary standards voluntary to commitment relevant, Where …

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a tion Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Level 3 2 ❒ Level 1 ❒ Level ❒ Level 1 not achieved ❒ Level Gloss a ry GSCP Reference Environmental Alert Notification A pp endices

Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide systems: management environmental for achieved level Summary: overall … template the per as presented findings the with here replicate and above from tables the copy please then audit, follow-up a to relates report this If auditor: to Note 5. on page

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related and related to the audit check guidelines. to and related tion tion ) r a Pre pa H G s (G Observation? G ases GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference et Finding ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ Level 3 2 ❒ Level 1 ❒ Level ❒ Level 1 not achieved ❒ Level N ot M xecution E xecution Audit G reen h ouse that has been violated) that and eport

et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element Summary of requirement, plus description plus description Summary of requirement, Audit O ut p uts Audit , T ransport ,

y U se y

ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

2.0 E nerg 2.0 Observation?

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type Energy consumption level is sustainable within availability availability within is sustainable level consumption Energy of local energy resources energy of local emonstrable achievement of stretching energy and fuel efficiency and fuel efficiency energy of stretching achievement D emonstrable standard international recognised beyond and G H emission targets practice •  •  ❒ Please tick one column and also note column and also note Please tick one Critical LE V EL 1 Energy consumption and greenhouse gas emissions (including and greenhouse consumption Energy internal appropriate to made available emissions) are vehicle on-site stakeholders and external targets and G H emission reduction use targets energy Renewable on an annual basis least at established/reviewed (normalised) are improvement continuous drive to refer (normalised; please in energy reduction Demonstrable for further definition) the guidance section to reviewed which are emissions reduction, vehicle include on-site Targets improvement continuous drive on an annual basis to Formal systems and processes in place to manage and audit energy and audit energy manage in place to and processes systems Formal E M S use and G H emissions as per the site LE V EL 2 LE V EL 3 gas (G H G) reduce greenhouse to mechanisms in place Leading practice to the guidance section) refer please further definition (for intensity G H intensity with lower sources Use of energy Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement reduce G H emissions to ways identifying system in business Carbon accounting combinations efficient environmentally of the most Specification fleet distribution for types, fuels and technologies of vehicle reviewed are targets reduction vehicle emission and Fuel consumption fleet for the entire improvement continuous drive on an annual basis to identified practice of good Examples measure identified) of the good practice a short description (please provide Gases (G H G): and Greenhouse use, transport energy for achieved level Summary: overall

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ Level 3 2 ❒ Level 1 ❒ Level ❒ Level 1 not achieved ❒ Level N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M

Gloss

a ry GSCP Reference Environmental Alert Notification A pp endices

Requirement Energy consumption level is sustainable within availability availability within is sustainable level consumption Energy of local energy resources energy of local emonstrable achievement of stretching energy and fuel efficiency and fuel efficiency energy of stretching achievement D emonstrable standard international recognised beyond and G H emission targets practice •  •  Energy consumption and greenhouse gas emissions (including and greenhouse consumption Energy internal appropriate to made available emissions) are vehicle on-site stakeholders and external targets and G H emission reduction use targets energy Renewable on an annual basis least at established/reviewed (normalised) are improvement continuous drive to refer (normalised; please in energy reduction Demonstrable for further definition) the guidance section to reviewed which are emissions reduction, vehicle include on-site Targets improvement continuous drive on an annual basis to Formal systems and processes in place to manage and audit energy and audit energy manage in place to and processes systems Formal E M S use and G H emissions as per the site LE V EL 2 LE V EL 3 gas (G H G) reduce greenhouse to mechanisms in place Leading practice to the guidance section) refer please further definition (for intensity G H intensity with lower sources Use of energy Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement reduce G H emissions to ways identifying system in business Carbon accounting combinations efficient environmentally of the most Specification fleet distribution for types, fuels and technologies of vehicle reviewed are targets reduction vehicle emission and Fuel consumption fleet for the entire improvement continuous drive on an annual basis to identified practice of good Examples measure identified) of the good practice a short description (please provide Gases (G H G): and Greenhouse use, transport energy for achieved level Summary: overall …

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒

N ot M xecution E xecution Audit that has been violated) that er U s e t er eport et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element 3.0 Wa 3.0 Summary of requirement, plus description plus description Summary of requirement,

Audit O ut p uts Audit

ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Observation? Level 3 2 ❒ Level ❒ Level 1 ❒ Level 1 not achieved ❒ Level

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one Critical LE V EL 1 LE V EL 2 and audit water manage in place to and processes systems Formal E M S as per the site consumption LE V EL 3 within local is sustainable level consumption water relevant, Where area catchment limits and water ecosystem Water consumption data are made available to relevant internal internal relevant to available made are data consumption Water stakeholders and external water sources of alternative relevant, of and use, if Investigation impact ecosystem with lower Water consumption efficiency targets are reviewed on an annual basis reviewed are targets efficiency consumption Water improvement continuous drive to beyond targets efficiency water of stretching achievement Demonstrable practice standard international recognised Demonstrable achievement of water efficiency targets (normalised) targets efficiency of water achievement Demonstrable re-use, efficiency mechanisms in place, including water Leading practice and recycling recovery to improve water efficiency water improve to Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide use: water for achieved level Summary: overall

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M

Gloss a ry GSCP Reference Environmental Alert Notification Level 3 ❒ Level 2 1 ❒ Level ❒ Level 1 not achieved ❒ Level A pp endices

Requirement LE V EL 2 and audit water manage in place to and processes systems Formal E M S as per the site consumption LE V EL 3 within local is sustainable level consumption water relevant, Where area catchment limits and water ecosystem Water consumption data are made available to relevant internal internal relevant to available made are data consumption Water stakeholders and external water sources of alternative relevant, of and use, if Investigation impact ecosystem with lower Water consumption efficiency targets are reviewed on an annual basis reviewed are targets efficiency consumption Water improvement continuous drive to beyond targets efficiency water of stretching achievement Demonstrable practice standard international recognised Demonstrable achievement of water efficiency targets (normalised) targets efficiency of water achievement Demonstrable re-use, efficiency mechanisms in place, including water Leading practice and recycling recovery to improve water efficiency water improve to Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide use: water for achieved level Summary: overall …

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒

N ot M xecution E xecution Audit / E ffluent / that has been violated) that eport et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element Summary of requirement, plus description plus description Summary of requirement, astewater 4.0 W 4.0 Audit O ut p uts Audit

ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Observation?

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one Critical LE V EL 1 LE V EL 2 effluent wastewater manage in place to and processes systems Formal E M S as per the site LE V EL 3 are sustainable volume quality and discharge effluent Wastewater in the context of local receptors and ecosystem limits and ecosystem receptors of local in the context Basic on-site wastewater treatment in place to achieve improvements in improvements achieve in place to treatment wastewater on-site Basic system treatment wastewater to off-site quality or connection wastewater Leading practice wastewater treatment in place treatment wastewater Leading practice Regular wastewater quality testing/ monitoring is undertaken to ensure to ensure is undertaken quality testing/ monitoring wastewater Regular E M S site’s limits and as per the effluent with permitted compliance ongoing Leading practice mechanisms in place to improve quality of wastewater wastewater quality of to improve mechanisms in place Leading practice water of grey including reuse environment, local to discharged Wastewater quality data are made available to relevant internal and internal relevant to made available are quality data Wastewater stakeholders external Demonstrable achievement of stretching wastewater effluent quality effluent wastewater of stretching achievement Demonstrable (normalised) beyond targets reduction and volume improvement practice standard international recognised Wastewater quality and volume improvement targets are reviewed reviewed are targets improvement quality and volume Wastewater improvement continuous drive on an annual basis to Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement to improve wastewater effluent quality effluent wastewater improve to Demonstrable improvement in wastewater quality in wastewater improvement Demonstrable Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 2 ❒ Level 1 ❒ Level ❒ Level 1 not achieved ❒ Level wastewater/effluent: for achieved level Summary: overall

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M

Gloss a ry GSCP Reference Environmental Alert Notification A pp endices

Requirement LE V EL 2 effluent wastewater manage in place to and processes systems Formal E M S as per the site LE V EL 3 are sustainable volume quality and discharge effluent Wastewater in the context of local receptors and ecosystem limits and ecosystem receptors of local in the context Basic on-site wastewater treatment in place to achieve improvements in improvements achieve in place to treatment wastewater on-site Basic system treatment wastewater to off-site quality or connection wastewater Leading practice wastewater treatment in place treatment wastewater Leading practice Regular wastewater quality testing/ monitoring is undertaken to ensure to ensure is undertaken quality testing/ monitoring wastewater Regular E M S site’s limits and as per the effluent with permitted compliance ongoing Leading practice mechanisms in place to improve quality of wastewater wastewater quality of to improve mechanisms in place Leading practice water of grey including reuse environment, local to discharged Wastewater quality data are made available to relevant internal and internal relevant to made available are quality data Wastewater stakeholders external Demonstrable achievement of stretching wastewater effluent quality effluent wastewater of stretching achievement Demonstrable (normalised) beyond targets reduction and volume improvement practice standard international recognised Wastewater quality and volume improvement targets are reviewed reviewed are targets improvement quality and volume Wastewater improvement continuous drive on an annual basis to Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement to improve wastewater effluent quality effluent wastewater improve to Demonstrable improvement in wastewater quality in wastewater improvement Demonstrable Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 2 ❒ Level ❒ Level 1 ❒ Level 1 not achieved ❒ Level wastewater/effluent: for achieved level Summary: overall …

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ o air air o

N ot M xecution E xecution Audit t that has been violated) that eport et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M 5.1 General of the finding and element of the law of the law of the finding and element Summary of requirement, plus description plus description Summary of requirement, 5.0 E mi ss ion s 5.0 Audit O ut p uts Audit

ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Observation?

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one Critical LE V EL 1 as per the site E M S as per the site LE V EL 2 air emissions to manage in place to and processes systems Formal LE V EL 3 limits ecosystem within local sustainable air are Emissions to Regular air emissions quality testing/monitoring is undertaken is undertaken air emissions quality testing/monitoring Regular limits with permitted compliance ongoing ensure to Leading practice abatement technologies in place to minimise emissions technologies in place abatement Leading practice at source reduce emissions to air or efforts to Air emissions quality data are made available to relevant internal internal relevant to made available are Air emissions quality data stakeholders and external Demonstrable achievement of stretching air quality improvement targets targets improvement quality air stretching of achievement Demonstrable practice standard international recognised beyond Air quality improvement targets are reviewed on an annual basis reviewed are targets Air quality improvement improvement continuous drive to Engagement with appropriate stakeholders down the value chain to chain to the value down stakeholders with appropriate Engagement air emissions to reduce Demonstrable reduction in emissions to air (normalised) in emissions reduction Demonstrable Additional and proactive emissions monitoring performed performed emissions monitoring Additional and proactive Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 ❒ Level 2 1 ❒ Level ❒ Level 1 not achieved ❒ Level general: air, emissions to for achieved level Summary: overall

18_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M

Gloss a ry GSCP Reference Environmental Alert Notification A pp endices

Requirement as per the site E M S as per the site LE V EL 2 air emissions to manage in place to and processes systems Formal LE V EL 3 limits ecosystem within local sustainable air are Emissions to Regular air emissions quality testing/monitoring is undertaken is undertaken air emissions quality testing/monitoring Regular limits with permitted compliance ongoing ensure to Leading practice abatement technologies in place to minimise emissions technologies in place abatement Leading practice at source reduce emissions to air or efforts to Air emissions quality data are made available to relevant internal internal relevant to made available are Air emissions quality data stakeholders and external Demonstrable achievement of stretching air quality improvement targets targets improvement quality air stretching of achievement Demonstrable practice standard international recognised beyond Air quality improvement targets are reviewed on an annual basis reviewed are targets Air quality improvement improvement continuous drive to Engagement with appropriate stakeholders down the value chain to chain to the value down stakeholders with appropriate Engagement air emissions to reduce Demonstrable reduction in emissions to air (normalised) in emissions reduction Demonstrable Additional and proactive emissions monitoring performed performed emissions monitoring Additional and proactive Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 2 ❒ Level ❒ Level 1 ❒ Level 1 not achieved ❒ Level general: air, emissions to for achieved level Summary: overall …

Global Social Compliance Programme_19

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding et ❒ ❒ ❒ ❒ o air air o

N ot M xecution E xecution Audit t that has been violated) that eport et R ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element Summary of requirement, plus description plus description Summary of requirement, 5.0 E mi ss ion s 5.0 Audit O ut p uts Audit 5.2 Ozone Depleting Substances (ODS) Substances Depleting 5.2 Ozone ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Observation?

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one Critical LE V EL 1 LE V EL 2 of ODS-containing and maintenance ODS leak detection Proactive equipment LE V EL 3 requirements) legal phase-out of all ODS (beyond Complete Targets in place to phase-out use of specific types of ODS, such as CFCs, phase-out use of specific types ODS, such as CFCs, in place to Targets practice standard international CCl4 in line with recognised halons, TCE, identified practice of good Examples measure identified) of the good practice a short description (please provide 3 2 ❒ Level 1 ❒ Level ❒ Level 1 not achieved (ODS): ❒ Level Substances Depleting Ozone for achieved level Summary: overall Demonstrable reduction, control and substitution of ODS and substitution control reduction, Demonstrable

20_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ M Gloss a ry GSCP Reference Environmental Alert Notification A pp endices

Requirement LE V EL 2 of ODS-containing and maintenance ODS leak detection Proactive equipment LE V EL 3 requirements) legal phase-out of all ODS (beyond Complete Targets in place to phase-out use of specific types of ODS, such as CFCs, phase-out use of specific types ODS, such as CFCs, in place to Targets practice standard international CCl4 in line with recognised halons, TCE, identified practice of good Examples measure identified) of the good practice a short description (please provide 3 2 ❒ Level 1 ❒ Level ❒ Level 1 not achieved (ODS): ❒ Level Substances Depleting Ozone for achieved level Summary: overall Demonstrable reduction, control and substitution of ODS and substitution control reduction, Demonstrable …

Global Social Compliance Programme_21

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒

N ot M g emen t xecution E xecution Audit that has been violated) that eport et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element Summary of requirement, plus description plus description Summary of requirement, e mana e st Wa 6.0 Audit O ut p uts Audit

ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Observation?

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one Critical LE V EL 1 LE V EL 2 generation, waste manage in place to and processes systems Formal E M S, including and disposal as per the site transportation, storage, principles hierarchy waste of consideration and audit minimisation waste on an annual at least reviewed are targets recycling and reduction Waste improvement. continuous drive basis to Evaluation of waste management contractors (suitability, disposal/ (suitability, contractors management waste of Evaluation methods) treatment (normalised) reduction waste Demonstrable Engagement with suppliers to identify waste avoidance/ reduction/ avoidance/ waste identify to with suppliers Engagement opportunities recycling/ reuse LE V EL 3 operating within local is sustainable and volume disposal method Waste and disposal facilities treatment of waste and availability environment Segregation of waste streams in line with recognised international international recognised in line with streams waste of Segregation practice standard use material resource/virgin to minimise in place Leading practices waste from reduction/recycling/energy waste and achieve onitoring and measurement of waste generated and recycled, with and recycled, generated of waste and measurement M onitoring stakeholders and external internal relevant to available data reduction/recycling waste of stretching achievement Demonstrable practice standard international recognised beyond targets to identify waste avoidance/reduction/recycling/reuse/energy from avoidance/reduction/recycling/reuse/energy waste identify to measures waste Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 ❒ Level 2 1 ❒ Level ❒ Level 1 not achieved ❒ Level management: waste for achieved level Summary: overall

22_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M

Gloss a ry GSCP Reference Environmental Alert Notification A pp endices

Requirement LE V EL 2 generation, waste manage in place to and processes systems Formal E M S, including and disposal as per the site transportation, storage, principles hierarchy waste of consideration and audit minimisation waste on an annual at least reviewed are targets recycling and reduction Waste improvement. continuous drive basis to Evaluation of waste management contractors (suitability, disposal/ (suitability, contractors management waste of Evaluation methods) treatment (normalised) reduction waste Demonstrable Engagement with suppliers to identify waste avoidance/ reduction/ avoidance/ waste identify to with suppliers Engagement opportunities recycling/ reuse LE V EL 3 operating within local is sustainable and volume disposal method Waste and disposal facilities treatment of waste and availability environment Segregation of waste streams in line with recognised international international recognised in line with streams waste of Segregation practice standard use material resource/virgin to minimise in place Leading practices waste from reduction/recycling/energy waste and achieve onitoring and measurement of waste generated and recycled, with and recycled, generated of waste and measurement M onitoring stakeholders and external internal relevant to available data reduction/recycling waste of stretching achievement Demonstrable practice standard international recognised beyond targets to identify waste avoidance/reduction/recycling/reuse/energy from avoidance/reduction/recycling/reuse/energy waste identify to measures waste Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 2 ❒ Level ❒ Level 1 ❒ Level 1 not achieved ❒ Level management: waste for achieved level Summary: overall …

Global Social Compliance Programme_23

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion S ubstances r a Pre pa ardous Ha z Observation? y y GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒

N ot M xecution E xecution Audit P otentiall that has been violated) that and

eport et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element Summary of requirement, plus description plus description Summary of requirement, ardous

Ha z Audit O ut p uts Audit / /

ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss P re v ention

Observation?

7.0 P ollution 7.0 GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one ero pollution incident’ target and policy in place pollution incident’target ero Critical LE V EL 1 LE V EL 2 pollution prevention in place for and processes systems Formal E M S as per the site for pollution incidents the potential reduce and to use (normalised) substances in hazardous reduction Demonstrable and minimisation of associated risks, as appropriate risks, of associated and minimisation Dedicated site emergency response team in place to deal with pollution in place to team response emergency site Dedicated incidents LE V EL 3 ‘ Z conducted are inspections pollution prevention Detailed Regular practice drills are carried out for pollution incidents carried out drills are practice Regular Promote the use of non-hazardous and non-toxic alternative substances alternative and non-toxic the use of non-hazardous Promote Targets are reviewed on an annual basis to reduce the use of hazardous the use of hazardous reduce on an annual basis to reviewed are Targets with non-hazardous and substitute risks minimise associated substances, possible where alternatives Demonstrable achievement of stretching hazardous substance reduction/ substance hazardous of stretching achievement Demonstrable practice standard international recognised beyond targets substitution Where relevant, specific pollution prevention mechanisms are considered considered are mechanisms prevention specific pollution relevant, Where input of agrichemicals optimisation including production, in agricultural Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement to improve hazardous substance use substance hazardous improve to Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide substances: hazardous and potentially pollution prevention/hazardous for achieved level Summary: overall 3 2 ❒ Level ❒ Level 1 ❒ Level 1 not achieved ❒ Level

24_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M

Gloss a ry GSCP Reference Environmental Alert Notification A pp endices

Requirement ero pollution incident’ target and policy in place pollution incident’target ero LE V EL 2 pollution prevention in place for and processes systems Formal E M S as per the site for pollution incidents the potential reduce and to use (normalised) substances in hazardous reduction Demonstrable and minimisation of associated risks, as appropriate risks, of associated and minimisation Dedicated site emergency response team in place to deal with pollution in place to team response emergency site Dedicated incidents LE V EL 3 ‘ Z conducted are inspections pollution prevention Detailed Regular practice drills are carried out for pollution incidents carried out drills are practice Regular Promote the use of non-hazardous and non-toxic alternative substances alternative and non-toxic the use of non-hazardous Promote Targets are reviewed on an annual basis to reduce the use of hazardous the use of hazardous reduce on an annual basis to reviewed are Targets with non-hazardous and substitute risks minimise associated substances, possible where alternatives Demonstrable achievement of stretching hazardous substance reduction/ substance hazardous of stretching achievement Demonstrable practice standard international recognised beyond targets substitution Where relevant, specific pollution prevention mechanisms are considered considered are mechanisms prevention specific pollution relevant, Where input of agrichemicals optimisation including production, in agricultural Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement to improve hazardous substance use substance hazardous improve to Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide substances: hazardous and potentially pollution prevention/hazardous for achieved level Summary: overall 3 ❒ Level 2 1 ❒ Level ❒ Level 1 not achieved ❒ Level …

Global Social Compliance Programme_25

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

g emen t GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒

N ot M xecution E xecution Audit mana that has been violated) that eport et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element Summary of requirement, plus description plus description Summary of requirement, or in c i d en t j or Audit O ut p uts Audit 8.0 M a 8.0 ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Observation?

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one ero major incident’ target and policy in place major incident’ero target Critical LE V EL 1 LE V EL 2 response emergency manage in place to and processes systems Formal E M S as per the site LE V EL 3 Z Proactive engagement with local community to ensure awareness awareness to ensure community with local engagement Proactive procedures response and emergency of major incidents of risks Reduction in potential occurrence and impacts of major incidents and impacts of major incidents occurrence in potential Reduction etc.) major spills fires, (e.g. explosions, Local community is involved in site’s emergency response drill and has response emergency in site’s is involved community Local as relevant team, response the emergency by been contacted Regular Quantitative Risk Assessment (QRA) reviews (QRA) Risk Assessment Quantitative Regular Leading practice mechanisms in place to reduce risk of major incidents reduce risk of major incidents to mechanisms in place Leading practice e.g. changes process ajor incidents reported to relevant stakeholders relevant to reported M ajor incidents Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 ❒ Level 2 1 ❒ Level ❒ Level 1 not achieved ❒ Level management: major incident for achieved level Summary: overall Dedicated site emergency response team in place team response emergency site Dedicated Regular practice drills are carried out for all emergency scenarios for all emergency carried out drills are practice Regular

26_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M Gloss a ry GSCP Reference Environmental Alert Notification A pp endices

Requirement ero major incident’ target and policy in place major incident’ero target LE V EL 2 response emergency manage in place to and processes systems Formal E M S as per the site LE V EL 3 Z Proactive engagement with local community to ensure awareness awareness to ensure community with local engagement Proactive procedures response and emergency of major incidents of risks Reduction in potential occurrence and impacts of major incidents and impacts of major incidents occurrence in potential Reduction etc.) major spills fires, (e.g. explosions, Local community is involved in site’s emergency response drill and has response emergency in site’s is involved community Local as relevant team, response the emergency by been contacted Regular Quantitative Risk Assessment (QRA) reviews (QRA) Risk Assessment Quantitative Regular Leading practice mechanisms in place to reduce risk of major incidents reduce risk of major incidents to mechanisms in place Leading practice e.g. changes process ajor incidents reported to relevant stakeholders relevant to reported M ajor incidents Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 2 ❒ Level 1 ❒ Level ❒ Level 1 not achieved ❒ Level management: major incident for achieved level Summary: overall Dedicated site emergency response team in place team response emergency site Dedicated Regular practice drills are carried out for all emergency scenarios for all emergency carried out drills are practice Regular …

Global Social Compliance Programme_27

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion

P re v ention r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference P ollution

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒

N ot M xecution E xecution Audit that has been violated) that eport G roundwater et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element and Summary of requirement, plus description plus description Summary of requirement,

oil /S

Audit O ut p uts Audit

land

ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Observation? m inated onta site sources of potential soil of potential sources - site 9.0 C 9.0

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type Appropriate and efficient remediation of soil and/or groundwater groundwater of soil and/or remediation and efficient Appropriate performed contamination All potential current and historical off and historical current All potential impact and groundwater site sources of potential soil of potential sources on - site and historical current All potential impact and groundwater Mapping of all receptors and pathways Mapping of all receptors a. Focused Phase II investigation a. Focused b.  a.  b.  c.  d. Assessment of risk of soil and groundwater impact of risk soil and groundwater d. Assessment ❒ Please tick one column and also note column and also note Please tick one ero contamination’ target and policy in place target contamination’ ero Critical LE V EL 1 LE V EL 2 soil contaminated manage in place to and processes systems Formal E M S as per the site and groundwater risk for soil and groundwater results following completed All actions e.g.assessment, and as required: Qualitative, desk-based (as appropriate) soil and groundwater risk soil and groundwater (as appropriate) desk-based Qualitative, including: completed assessment Any soil and groundwater contamination is communicated to relevant relevant to communicated is contamination soil and groundwater Any as required stakeholders, LE V EL 3 ‘ Z quality of soil and groundwater management Proactive Leading practice techniques in place to prevent further/future soil further/future to prevent techniques in place Leading practice remediation to relation and in contamination groundwater and/or Proactive engagement with stakeholders in the local community to community in the local stakeholders with engagement Proactive contamination groundwater soil and/or of potential awareness ensure Engagement with appropriate stakeholders down the value chain in the value down stakeholders with appropriate Engagement groundwater of soil and and management to the prevention relation contamination Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 ❒ Level 2 1 ❒ Level ❒ Level 1 not achieved ❒ Level pollution prevention: and groundwater land/soil contaminated for achieved level Summary: overall

28_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M

Gloss a ry GSCP Reference Environmental Alert Notification A pp endices site sources of potential soil of potential sources - site

Requirement Appropriate and efficient remediation of soil and/or groundwater groundwater of soil and/or remediation and efficient Appropriate performed contamination All potential current and historical off and historical current All potential impact and groundwater site sources of potential soil of potential sources on - site and historical current All potential impact and groundwater Mapping of all receptors and pathways Mapping of all receptors a. Focused Phase II investigation a. Focused b.  a.  b.  c.  d. Assessment of risk of soil and groundwater impact of risk soil and groundwater d. Assessment ero contamination’ target and policy in place target contamination’ ero LE V EL 2 soil contaminated manage in place to and processes systems Formal E M S as per the site and groundwater risk for soil and groundwater results following completed All actions e.g.assessment, and as required: Qualitative, desk-based (as appropriate) soil and groundwater risk soil and groundwater (as appropriate) desk-based Qualitative, including: completed assessment Any soil and groundwater contamination is communicated to relevant relevant to communicated is contamination soil and groundwater Any as required stakeholders, LE V EL 3 ‘ Z quality of soil and groundwater management Proactive Leading practice techniques in place to prevent further/future soil further/future to prevent techniques in place Leading practice remediation to relation and in contamination groundwater and/or Proactive engagement with stakeholders in the local community to community in the local stakeholders with engagement Proactive contamination groundwater soil and/or of potential awareness ensure Engagement with appropriate stakeholders down the value chain in the value down stakeholders with appropriate Engagement groundwater of soil and and management to the prevention relation contamination Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide 3 2 ❒ Level 1 ❒ Level ❒ Level 1 not achieved ❒ Level pollution prevention: and groundwater land/soil contaminated for achieved level Summary: overall …

Global Social Compliance Programme_29

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒

N ot M xecution E xecution Audit y B iodi v ersit that has been violated) that eport and

et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element U se Summary of requirement, plus description plus description Summary of requirement, Audit O ut p uts Audit 10.0 L and 10.0

Level 3 2 ❒ Level ❒ Level 1 ❒ Level 1 not achieved ❒ Level

ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Observation?

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one Critical LE V EL 1 LE V EL 2 land use and manage in place to and processes systems Formal E M S as per the site biodiversity LE V EL 3 context ecosystem within local Land use is sustainable In agricultural production, proactive management to maintain soil to maintain management proactive production, In agricultural recovery soil and biodiversity and promote soil erosion avoid fertility, partnership example for conservation, in biodiversity role Leadership organisations local with relevant Where appropriate, demonstrable improvement in land use and improvement demonstrable appropriate, Where rehabilitation including deforestation, performance biodiversity activities and conservation biodiversity to promote mechanisms in place Leading practice land management and leading practice to improve land use and biodiversity performance, within and beyond within and beyond performance, land use and biodiversity improve to boundaries site Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement Demonstrable achievement of stretching targets beyond recognised recognised beyond targets of stretching achievement Demonstrable practice standard international Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide land use and biodiversity: for achieved level Summary: overall

30_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M

Level 3 ❒ Level 2 1 ❒ Level ❒ Level 1 not achieved ❒ Level Gloss

a ry GSCP Reference Environmental Alert Notification A pp endices

Requirement LE V EL 2 land use and manage in place to and processes systems Formal E M S as per the site biodiversity LE V EL 3 context ecosystem within local Land use is sustainable In agricultural production, proactive management to maintain soil to maintain management proactive production, In agricultural recovery soil and biodiversity and promote soil erosion avoid fertility, partnership example for conservation, in biodiversity role Leadership organisations local with relevant Where appropriate, demonstrable improvement in land use and improvement demonstrable appropriate, Where rehabilitation including deforestation, performance biodiversity activities and conservation biodiversity to promote mechanisms in place Leading practice land management and leading practice to improve land use and biodiversity performance, within and beyond within and beyond performance, land use and biodiversity improve to boundaries site Engagement with appropriate stakeholders down the value chain the value down stakeholders with appropriate Engagement Demonstrable achievement of stretching targets beyond recognised recognised beyond targets of stretching achievement Demonstrable practice standard international Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide land use and biodiversity: for achieved level Summary: overall …

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem …

GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Evidence Evidence listed e.g. worker interview, interview, e.g. worker listed documentary, observational) documentary, Audit R equest Audit Please indicate the type of evidence the type of evidence Please indicate (A description of the evidence observed evidence observed of the (A description (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines. to and related and related to the audit check guidelines) to and related tion tion r a Pre pa Observation? GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference Finding s et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒

N ot M xecution E xecution Audit an c e that has been violated) that eport et R ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M of the finding and element of the law of the law of the finding and element Summary of requirement, plus description plus description Summary of requirement, 11.0 Nu i s 11.0

Audit O ut p uts Audit ry a ry ❒ GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Observation? Level 3 2 ❒ Level ❒ Level 1 ❒ Level 1 not achieved ❒ Level

GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices ❒ egal L egal Issue? Requirement ❒ M inor ❒ M ajor GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference if it is a legal issue? if it is a legal Non-Compliance Type Non-Compliance Type ❒ Please tick one column and also note column and also note Please tick one ero complaints’ target and policy in place target complaints’ ero Critical LE V EL 2 nuisances (including manage in place to and processes systems Formal as per and complaints housekeeping) noise, visual and general odour, E M S the site LE V EL 3 Z Proactive engagement with local community/ stakeholders to reduce to stakeholders community/ with local engagement Proactive impacts LE V EL 1 Impacts and complaints data are made available to relevant internal internal relevant to made available are data Impacts and complaints stakeholders and external Leading practice mechanisms in place to ensure reduction of impacts to ensure mechanisms in place Leading practice e.g. changes process Impacts and complaints reduction targets are reviewed on an annual reviewed are targets reduction Impacts and complaints improvement continuous drive basis to Demonstrable achievement of stretching performance targets beyond beyond targets performance of stretching achievement Demonstrable practice standard international recognised Demonstrable reduction in nuisance impacts and complaints in nuisance impacts and reduction Demonstrable Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide nuisances: for achieved level Summary: overall

32_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S ystem GSCP Reference Environmental Supplementary Audit Information Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Evidence (A description of the evidence observed evidence observed of the (A description and related to the audit check guidelines) to and related Pre pa r a tion Audit E xecution Observation? GSCP Reference Environmental of Findings and Corrective Summary Actions et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ N ot M GSCP Reference Environmental Audit Checks Audit O ut p uts et ❒ ❒ ❒ ❒ ❒ ❒ ❒ ❒ M

Gloss a ry GSCP Reference Environmental Alert Notification Level 3 ❒ Level 2 1 ❒ Level ❒ Level 1 not achieved ❒ Level A pp endices

Requirement ero complaints’ target and policy in place target complaints’ ero LE V EL 2 nuisances (including manage in place to and processes systems Formal as per and complaints housekeeping) noise, visual and general odour, E M S the site LE V EL 3 Z Proactive engagement with local community/ stakeholders to reduce to stakeholders community/ with local engagement Proactive impacts Impacts and complaints data are made available to relevant internal internal relevant to made available are data Impacts and complaints stakeholders and external Leading practice mechanisms in place to ensure reduction of impacts to ensure mechanisms in place Leading practice e.g. changes process Impacts and complaints reduction targets are reviewed on an annual reviewed are targets reduction Impacts and complaints improvement continuous drive basis to Demonstrable achievement of stretching performance targets beyond beyond targets performance of stretching achievement Demonstrable practice standard international recognised Demonstrable reduction in nuisance impacts and complaints in nuisance impacts and reduction Demonstrable Examples of good practice identified identified practice of good Examples measure identified) of the good practice a short description (please provide nuisances: for achieved level Summary: overall …

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Appendix 5: GSCP Reference Environmental Audit Report

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem 4. On-Site Pictures

Auditors should include relevant photos that were taken as part of the audit in this section of the audit report. Relevant photos GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

may include general pictures of the employment site – such as pictures of the employment site or pictures of the production isk Assessment S Assessment R isk floor, or they may be specific to the details of the audit report – such as a picture of a non-compliance, observation or best

GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference practice.

The suggested photos below are examples, and the auditor should include all relevant photos. Audit R equest Audit Photo Photo Photo tion tion

Outside view of employment site buildings Employment site entrance Processes r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

Photo Photo Photo GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit

Waste skips Chemical storage cupboard Above ground storage tank Audit O ut p uts Audit

ry a ry Photo Photo Photo GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Non-compliance 1 Observation 1 Best Practice 1 GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference A pp endices

Photo Photo Photo GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

34_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 6 R isk Assessment S GSCP Reference

Environmental GSCP Reference Environmental Supplementary Audit Information Supplementary ystem Audit R equest Audit Information GSCP Reference Environmental Pre-Audit Employment Site Profile

This tool forms part of the GSCP set of reference tools continuous improvement in its environmental performance designed to provide a common interpretation of local and from basic compliance to leading-edge performance (across Pre pa r a international environmental standards and requirements three defined ‘levels’ for eleven different performance and environmental reference codes (if available and areas). applicable). The Environmental Reference Requirements tion reflect a common understanding of good environmental practice and are applicable to all raw material processing, The reference tools on Environmental Audit Process and agricultural, manufacturing and logistics sites in the supply Methodology are based on the GSCP Environmental Audit E xecution chain. The Environmental Reference Requirements provide Reference Requirements but can be adopted and tailored to a model for a site in the supply chain to demonstrate other codes of environmental practice. GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks Audit O ut p uts Supplementary Audit Report

Auditors may feel the need to produce a separate, Supplementary reports may be appropriate: supplementary report for the audit requestor containing: • if workers appear to be under undue pressure from Gloss • information too sensitive for the audit report; management on the day of audit;

• concerns which cannot be substantiated through evidence • if management was obstructive or reluctant to accept a ry and/or interviews; findings and the need for remediation;

• attitude of management towards the non-compliances or • where the auditor has concerns about the possibility of GSCP Reference Environmental Alert Notification A pp endices the audit process as a whole. falsified records; • where sensitive issues could not be discussed during the closing meeting because of a potential risk to workers’ wellbeing.

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Appendix 6: GSCP Reference Environmental Supplementary Audit Information

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction

ystem Reference environmental supplementary audit information GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference

Related Area of Concern Evidence / Observations Environmental (Description of the issue, who was involved or effected (a description of the evidence Standard or legal and its potential consequences) observed) isk Assessment S Assessment R isk requirement GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

A pp endices GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference

02_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 7 R isk Assessment S GSCP Reference

Summary of GSCP Reference Environmental Supplementary Audit Information Environmental Findings ystem Audit R equest and Corrective Actions GSCP Reference Environmental Pre-Audit Employment Site Profile

This tool forms part of the GSCP set of reference tools The reference tools on Environmental Audit Process and Pre pa r a designed to provide a common interpretation of local and Methodology are based on the GSCP Environmental international environmental standards and requirements and Reference Requirements but can be adopted and tailored to environmental reference codes (if available and applicable). other codes of environmental practice. tion The Environmental Reference Requirements reflect a The reference Summary of Environmental Findings and common understanding of good environmental practice and Corrective Actions has been designed to provide a structure are applicable to all raw material processing, agricultural, to the audit team’s findings and help the audit team develop Audit E xecution manufacturing and logistics sites in the supply chain. The

a corrective action plan and structure a closing meeting. GSCP Reference Environmental of Findings and Corrective Summary Actions Environmental Reference Requirements provide a model for a site in the supply chain to demonstrate continuous improvement in its environmental performance from basic compliance to leading-edge performance (across three defined ‘levels’ for eleven different performance areas). GSCP Reference Environmental Audit Checks Audit O ut p uts A note on Corrective Actions

Audit requestors (companies and/or individuals) may take a However, reference is made here to both ‘findings Gloss number of different approaches with respect to corrective and corrective actions’ on the understanding that the actions, for example: identification of corrective actions may be required. a ry • require auditors solely to identify corrective actions and The Summary of Findings and Corrective Actions template

require the employment site to develop the corrective includes: GSCP Reference Environmental Alert Notification action plan following the audit; or A pp endices • audit findings: Summary of non compliances, good • require auditors to identify evidence-based findings and practice, and evidence found; work with the employment site to develop a corrective • classification of non compliances; action plan; or • reference to the applicable code of conduct and/or law • require auditors to identify evidence-based findings, which has been contravened; develop the appropriate corrective action and agree with the employment site on their follow-up. • recommended corrective actions: Auditors suggestion on how the audit findings can be resolved; • person/party responsible for corrective action;

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eport R Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions udit A Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ssessment Questionnaire Questionnaire ssessment A elf S ystem

ference Environmental Environmental ference • verification method: The Summary of Findings and Corrective Actions should: e R P / a desk-based follow up may be used to verify corrective • be clearly described and written in both English and the GSC actions for minor non-compliances but provide language spoken by the employment site management; less assurance than a follow-up audit. Desk-based • be distributed as follows: verification should check corrective actions through e

R photos, copies of certificates, invoices, etc. submitted / a signed copy for the employment site manager; formation formation isk Assessment S Assessment R isk P n I by the employment site. Desk-based follow-up cannot / a signed copy retained by the auditor together with GSC Environmental ference

udit be used where actions need to be verified through other audit documentation; A worker testimony; / a hard or soft copy to the audit requestor. / follow-up audits are recommended for critical or

ite Profile Profile ite major non-compliances or when corrective actions can S be evaluated only through interviews and extensive upplementary upplementary NB: Where employment site representatives are unwilling to S

Audit R equest Audit documentation reviews (see section 5.4 of the sign an English language copy of the Summary of Findings reference audit process); and Corrective Actions, the auditor should still sign their • timescale for completion: The amount of time required for English language copy and should indicate that they have

udit Employment udit Employment witnessed the representative’s signature on the copy signed tion tion

A the issue to be closed. The time allocated for corrective actions to be completed should be appropriate, realistic by management. and timely. e R r a Pre pa P GSC Environmental ference

e ctions R A P GSC Pre- Environmental ference xecution E xecution Audit orrective orrective C hecks hecks C udit A indings and F Audit O ut p uts Audit ummary of S ference Environmental Environmental ference ry a ry e R P GSC Gloss

otification otification N e lert R A A pp endices P GSC Environmental ference ference Environmental Environmental ference e R P GSC

02_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S Reference Summary of Environmental GSCP Reference Environmental Supplementary Audit Information

Findings and Corrective Actions ystem

1. Employment site and auditor details Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Employment site name: Audit requestor: Pre pa r a Employment site address: Auditor name and organisation: tion Audit E xecution

Employment site representative (name and position): Audit date: GSCP Reference Environmental of Findings and Corrective Summary Actions

Time in:

Time out: GSCP Reference Environmental Audit Checks Audit O ut p uts Gloss a ry GSCP Reference Environmental Alert Notification A pp endices

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Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference completion Timescale for for Timescale isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

method erification erification V Audit R equest Audit tion tion responsible Person / party Person r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit actions Suggested corrective corrective Suggested Audit O ut p uts Audit ry a ry eference eference R GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss Performance Performance area (in GSCP area Environmental Environmental

Requirements) A pp endices M inor) of non- compliance compliance Classification Classification GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference ajor, M ajor, (Critical,

GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference Audit Findings (non compliance)

2. Details of non-compliances and corrective actions and corrective of non-compliances 2. Details review: and document and management, with employees interviews observation, based upon on - site The audit findings are

04_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S GSCP Reference Environmental Supplementary Audit Information ystem completion completion Timescale for for Timescale Timescale forTimescale (where required) (where Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile method erification erification erification erification V required) V method (where (where method Pre pa r a tion responsible Person / party Person responsible Person / party Person (where required) (where Audit E xecution GSCP Reference Environmental of Findings and Corrective Summary Actions GSCP Reference Environmental Audit Checks actions Audit O ut p uts Suggested corrective corrective Suggested Suggested corrective corrective Suggested actions (where applicable) actions (where Gloss a ry eference eference R Performance Performance area (in GSCP area Environmental Environmental Requirements) eference eference GSCP Reference Environmental Alert Notification R A pp endices Performance Performance area (in GSCP area Environmental Environmental Requirements) M inor) of non- compliance compliance Classification Classification ajor, M ajor, (Critical,

Audit findings (observation) Audit Findings (non compliance)

2. Details of non-compliances and corrective actions and corrective of non-compliances 2. Details review: and document and management, with employees interviews observation, based upon on - site The audit findings are of observations 3. Details

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Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

Environmental Audit Process & Methodology Reference Tools - november 2010 introduction ystem GSCP Reference Environmental Audit Report Audit Report Environmental GSCP Reference Date isk Assessment S Assessment R isk GSCP Reference Environmental Self Assessment Questionnaire Questionnaire Self Assessment Environmental GSCP Reference

Audit R equest Audit tion tion signature r a Pre pa GSCP Reference Environmental Supplementary Audit Information Audit Information Supplementary Environmental GSCP Reference Employment site representative representative site Employment

GSCP Reference Environmental Pre-Audit Employment Site Profile Profile Site Employment Pre-Audit Environmental GSCP Reference xecution E xecution Audit Audit O ut p uts Audit ry a ry GSCP Reference Environmental Audit Checks Checks Audit Environmental Reference GSCP Gloss

Comments A pp endices GSCP Reference Environmental Summary of Findings and Corrective Actions Actions Summary Findings and Corrective of Environmental GSCP Reference GSCP Reference Environmental Alert Notification Alert Notification Environmental GSCP Reference 4. Employment site comments or dispute of findings or dispute comments site 4. Employment Where an agreement cannot be reached between employment site management and auditors regarding findings and/orcorrective below: in the box outline the disagreements actions, employmentsites can

06_Global Social Compliance Programme GSCP Reference Environmental Self Assessment Questionnaire GSCP Reference Environmental Audit Report introduction

Appendix 7: GSCP Reference Environmental Summary of Findings and Corrective Actions

Environmental Audit Process & Methodology Reference Tools - november 2010 R isk Assessment S GSCP Reference Environmental Supplementary Audit Information ystem Date Date Audit R equest GSCP Reference Environmental Pre-Audit Employment Site Profile Pre pa r a site representative site No Signature - employment - employment Signature signature tion es Y Audit E xecution Employment site representative representative site Employment GSCP Reference Environmental of Findings and Corrective Summary Actions

GSCP Reference Environmental Audit Checks Audit O ut p uts

and position Employment site representative name representative site Employment Gloss a ry GSCP Reference Environmental Alert Notification A pp endices Comments Date Signature – auditor Signature (Please provide names, positions and contact details of additional managers): details contact names, positions and (Please provide 4. Employment site comments or dispute of findings or dispute comments site 4. Employment Where an agreement cannot be reached between employment site management and auditors regarding findings and/orcorrective below: in the box outline the disagreements actions, employmentsites can actions corrective of findings and 5. Acceptance agreed: were discussed and actions corrective findings and and the above has been undertaken A closing meeting all actions listed? complete to the authority have above Representative site Does the employment decisions on these points? take authority to who would have the necessary If No,

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