Supplier name: Allene Overseas Pvt Ltd. Site country: India Site name: Allene Overseas Pvt Ltd. Parent Company name (of the site): Allene Overseas Pvt Ltd. SMETA Audit Type: 2–Pillar 4–Pillar Date of Audit 02 March 2017

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 1

Audit Company Name: Report Owner (payee) : Intertek Allene Overseas Pvt Ltd.

Sedex Company Reference: ZC :3594033 (only available on Sedex System)

Sedex Site Reference: ZS : 3596595 (only available on Sedex System)

Audit Conducted By

Commercial Purchaser

NGO Retailer

Trade Union Brand Owner

Multi–stakeholder Combined Audit (select all that apply)

Auditor Reference Number: Not applicable (If applicable)

SMETA Declaration

I declare that the audit underpinning the following report was conducted in accordance with SMETA Best Practice Guidance and SMETA Measurement Criteria.

Any exceptions to this must be recorded here (e.g. different sample size):

Auditor Name(s) (please list all including all interviewers): Lead auditor: Parul Jaglan Team auditor: Soni Khatri Interviewers: Parul Jaglan

Date: 02/03/2017

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 2

Non–Compliance Table

Area of Non –Conformity (Only check box when there is a non–conformity, Record the number and only in the box/es where the non–conformity of issues by line*: Issue can be found) (please click on the issue title to go direct to the appropriate audit results by clause) Additional NC Obs GE ETI Base Elements Local Law Code (i.e. not part of ETI code )

0 Management systems and code 01 00 00 implementation

1 Employment Freely Chosen 00 00 00

2 Freedom of Association 04 00 00

3 Safety and Hygienic Conditions 00 00 00

4 Child Labour 00 00 00

5 Wages and Benefits 00 00 00

6 Working Hours 00 00 00

7 Discrimination 00 00 00

8 Regular Employment 00 00 00

8A Sub–Contracting and 00 00 00 Homeworking

9 Harsh or Inhumane Treatment 00 00 00

10A Entitlement to Work 00 00 00

10B2 Environment 2–Pillar NA NA NA

10B4 Environment 4–Pillar 00 00 00

10C Business Ethics 00 00

*Please note the table above records the total number of Non compliances (NC), Observations (Obs) and Good Examples (GE). This gives the reviewer an indication of problem areas but does not detail severities of each issue – Reviewers need to check audit results by clause.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 3

Summary of Findings

Summary of main findings: (positive and negative) (Please give a short summary of the main findings per clause)

Audit process: This Annual audit was conducted by Intertek India Pvt. Ltd. 02 Auditor has assessed on one day and 01 auditor in 01 day the facility’s operations. The scope of this audit was based on 4 Pillar SMETA guidelines

Overview of opening meeting, facility management responses:- Auditor entered the facility at 09:40 am on 02 March 2017 and conducted an opening meeting with facility management according to the ETI Base Code. Mr. Vipul Goel – Director, Mr. Manish Sharma- HR Executive and Mr. Vivek Goel – Factory Manager were present in the meeting and they assured full co-operation to this audit.

Site summary :

• 10 attendance records and payroll records for January 2017 (Current month), 10 attendance records and payroll records for September 2016 (Random month) and 10 attendance records and payroll records for March 2016 (Random month) were reviewed in this audit.

• A total of 83 employees are currently working in the facility, which included 75 production employees and 08 non production employees. Out of 83 employees, 68 are male and 15 are female employees. Facility has hired 82 employees on company roll and 01 employee from 01 contractor (G.K Group Security) for security processes. Further the facility had not engaged any foreign nationals.

• Manufacturers and Exporters of stainless steel utensils.

• Overall responsibility for meeting the standards is taken by Mr. Vipul Goel – Director.

• Facility has 06 days a week working in one shift. Details are given below:

• Facility is running in One (01) shift, Six (6) days a week. Details are given below:

• General Shift - A : 09:00 am to 05:30 pm Lunch Break : 30 minutes break (1:00 pm to 1:30 pm) Tea Break : 3:15 pm to 3:30 pm Weekly Holiday : Sunday

• Salary for all employees are fixed on monthly rate and paid once in a month accordingly as per law. Salary to all these employees is paid through Cash by 7 th of every month.

• The age of young work found on the day of audit is 27 years old.

• No union exits at this facility.

• 10 employees were selected for interview and same number of time records and wage records were verified.

• Employees were satisfied with their work and management.

• Facility providing one day weekly off to their employees.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 4

• They also said they were able to make suggestions to their supervisors and team leaders and sometimes they had seen these suggestions used.

• Time records were available for the period February 2016 to January 2017 and three months (1 current, 02 random months) were selected for review.

• Regular working hours & no Overtime hours performed for any of the sample selected month.

• Weekly off day is provided to all employees.

Summary of Findings (Positive and negative)

Positive Observations: Management approach towards this audit was very positive and they assured necessary steps to improve labor standard in their facility.

Negative Observations: Non-compliances were observed in the areas of “Management systems and code implementation” and “Safety and Hygienic Conditions” In other areas no non compliances were observed. Details are given below:

1. Based from facility tour it was noted that, facility has not amended that approved layout plan as per the current floor plan. As per current layout facility has storage area on second floor however facility has installed plating section in place of storage area. 2. Based from facility tour it was noted that drinking water points situated within 6 meters of toilets on ground, first and second floor. 3. Based from facility tour, chemical containers were found stored without secondary containment / MSDS and labelling in plating section on second floor and in open terrace area. 4. Based from facility tour, 04 employees in polishing section on second floor were found working without using ear plugs. Further facility has provided ear plugs to all the employees. 5. Based from facility tour, it was noted that emergency evacuation map posted on second floor was not found as per the actual floor plan.

Observation : Nil

Good Examples: Nil

Auditor Notes: None Observed

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 5

Audit Details

Audit Details

A: Report #: IDA-16076-01

B: Time in and time out Day 1 Day 2 Time in: Not Day 3 Time in: Not (SMETA Best Practice Guidance and Time in: 09:40 am applicable applicable Measurement Criteria recommends 9.00–17.00 Time Out: 05:30 pm Day 2 Time out: Not Day 3 Time out: Not hrs. if any different please state why in the applicable applicable SMETA declaration )

C: Number of Auditor Days Used: 02 Auditors in a 01 day – 1.5 Man day (number of auditor x number of days)

D: Audit type: Full Initial Periodic Full Follow-up Partial Follow-Up Partial Other - Define

E: Was the audit announced? (AAG Announced recommends a window of three weeks for semi– Semi – announced: Window detail: 28/02/2017 to 27/3/2017 announced, this gives optimum results) Unannounced

F: Was the Sedex SAQ available for Yes review? No

If No , why not? NA (Examples would be, site has not completed SAQ, site has not been asked to complete the SAQ.)

G: Any conflicting information SAQ/Pre- Yes Audit Info to Audit findings? No If Yes , please capture detail in appropriate audit by clause : NA

H: Auditor name(s) and role(s): Parul Jaglan / Soni Khatri – Lead Auditor / Auditor

I: Report written by: Soni Khatri

J: Report reviewed by: Meeta Pednekar

K: Report issue date: 09 March 17

L: Supplier name: Allene Overseas Pvt Ltd.

M: Site name: Allene Overseas Pvt Ltd.

N: Site country: India

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 6

O: Site contact and job title: Mr. Vipul Goel - Director

P: Site address: Plot No- 27, Hsiidc, Epip, Kundli Industrial Area, Sonipat, Haryana, (Please include full address) India

Site phone: 0130-6543888 / 6544788, 9811366501

Site fax: NA

Site e–mail: [email protected]

Q: Applicable business and other legally Factory License No – SPT- ONLINE-11 for employing 148 required licence numbers: employees, Valid till – 31/12/2017 for example, business license no, and TIN No- 06503016671 liability insurance

R: Products/Activities at site, for example, Manufacturing of Stainless Steel Utensils. garment manufacture, electricals, toys, grower

S: Audit results reviewed with site Yes management?

T: Who signed and agreed CAPR Mr. Vipul Goel - Director (Name and job title)

U: Did the person who signed the CAPR Yes have authority to implement changes?

V: Present at closing meeting (Please state Mr. Vipul Goel – Director name and position, including any Mr. Vivek Goel – Factory Manager workers/union reps/worker reps): Ms. Parul Jaglan – Senior Auditor Ms. Soni Khatri - Auditor

W: What form of worker representation / Union (name) union is there on site? Worker Committee Other (specify) None

X: Are any workers covered by Collective Yes No Bargaining Agreement (CBA)

Y: Previous audit date: Not Applicable

Z: Previous audit type: SMETA 2-pillar SMETA 4-pillar Other

Full Initial

Periodic

Full Follow-Up Audit

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 7

Partial Follow- Up

Partial Other*

*If other, please define: Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 8

Audit Scope/Actual Results

Criteria Local Law Actual at the Is this part of (Please state legal Site a Collective requirement) (Record site Bargaining results against Agreement? the law)

A: Standard/Contracted work hours: 48 hours/week 48 hours/week Yes (Maximum legal and actual required working hours No excluding overtime, please state if possible per day, week and month)

B: Legal Overtime hours: 02 hours per day, 12 No overtime Yes (Maximum legal and actual overtime hours, please state if hours per week & 50 performed No possible per day, week and month) hours per quarter

C: Legal age of employment: 14 years completed 27 years (Minimum legal and actual minimum age at site)

D: Legal minimum wage for standard/contracted The Minimum Wage in INR 8100 .00 Yes hours: Haryana with effect from per month No (Minimum legal and actual minimum wage at site, please 01st July 2016 to till is Unskilled state if possible per hr, day, week and month) as below:

Unskilled –INR – INR 8474 .00 8,070.44 / per month per month • Semi- Semi skilled Skilled – A INR – 8,473.96 / per month; • Semi- INR 9350 .00 Skilled – B INR – per month 8,897.65 / per month; • Skilled Skilled – A - INR 9,342.53 / per month •

Skilled – B - INR 9,809.66 / per month; • Highly Skilled – INR 10,300.14 / per month

E: Legal minimum overtime wage: 200% of normal rate 200% of normal Yes (Minimum legal and actual minimum overtime wage at site, (Basic + Dearness rate (Basic + No please state if possible per hr ,day, week and month) allowance) of wages. Dearness allowance) of wages.(As per policy)

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 9

Audit Scope (Please select the code and additional requirements that were audited against during this audit)

2–Pillar Audit

10B4: Environment 4–Pillar

10C: Business Ethics

All groups of workers are included in the scope of this audit such as; Direct employees, Casual and agency workers, Workers employed by service providers such as security and catering staff as well as workers supplied by other contractors.

Note: The main focus of this ethical audit is on the ETI Base Code and local law. The additional elements will not be audited in such depth or scope, but the audit process will still highlight any specific issues.

This report provides a summary of the findings and other applicable information found/gathered during the social audit conducted on the above date only and does not officially confirm or certify compliance with any legal regulations or industry standards. The social audit process requires that information be gathered and considered from records review, worker interviews, management interviews and visual observation. More information is gathered during the social audit process than is provided here. The audit process is a sampling exercise only and does not guarantee that the audited site prior, during or post–audit, are in full compliance with the Code being audited against. The provisions of this Code constitute minimum and not maximum standards and this Code should not be used to prevent companies from exceeding these standards. Companies applying this Code are expected to comply with national and other applicable laws and where the provisions of law and this Code address the same subject, to apply that provision which affords the greater protection. The ownership of this report remains with the party who has paid for the audit. Release permission must be provided by the owner prior to release to any third parties.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 10

Audit Overview

Audit Overview

Management Worker Representatives

Audit attendance Senior management Worker Committee Union representatives representatives

A: Present at the opening meeting? Yes No Yes No Yes No

B: Present at the audit? Yes No Yes No Yes No

C: Present at the closing meeting? Yes No Yes No Yes No

D: If Worker Representatives were not Worker Representatives were busy in production activities. present please explain reasons why (only complete if no worker reps present)

E: If Union Representatives were not No union exists in the facility at present. present please explain reasons why: (only complete if no union reps present )

F: Site description: The audited facility " Allene Overseas Pvt. Ltd.." is a private limited (Include size, location and age of site. Also facility located Plot No-27, HSIDC Industrial area , Phase-IV, sector -57, include structure and number of buildings) Kundli, Sonepat, Haryana . The facility has started their operation in the existing location May 2011

The total plot area of the facility is 1800 Sq metres and total production area 3500 square meters.

All the production processes were carried out in one Building as detailed below -

Production Remark, if Description Building no any

Ground Floor Raw material store,, Pressing , None Cutting , Beading, Spinning

Mezzanine - Office, Store. None

Packing , & Checking First Floor None

Second Floor Polishing, Painting, chemical storage None

Is this a shared No None building?

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 11

G: Site function: Agent Factory Processing/Manufacturer Finished Product Supplier Grower Homeworker Labour Provider Pack House Primary Producer Service Provider Sub–Contractor

H: Month(s) of peak season: constant production throughout the year (if applicable)

I: Process overview: (Include products being produced, main operations, number of production lines, main equipment used)

Facility is engaged into Manufacturers and Exporters of Stainless steel utensils.

Main equipment’s/machineries used by facility are Press machines, Circle cutting Machine, Punching Machine, Polishing and Injection moulding machine.

The main production process flow chart is listed below:

For Steel utensils :- Raw material – Pressing - Circle cutting – Cutting and Bidding – Inspection– polishing/ buffing – Packing - Dispatch.

J: Attitude of workers: (Include their attitude to management, workplace and the interview process. Both positive and negative information should be included) Note: Do not document any information that could put workers at risk

Total 10 employees were selected for interview. All employees were found favourable with the management and facility environment. No negative information was noted. Overall they displayed a positive attitude towards the management and the workplace .

K: Attitude of workers committee/union reps: (Include their attitude to management, workplace and the interview process. Both positive and negative information should be included) Note: Do not document any information that could put workers at risk

Members from works committee looked very positive towards the management and no negative information reported.

L: Attitude of managers: (Include attitude to audit, and audit process. Both positive and negative information should be included)

The facility management showed a positive attitude to this audit during the whole process. All documentation requested for review was provided timely. Locked areas encountered during the audit were unlocked timely. At the end of the audit, all the non-compliances were accepted by the facility. No negative information reported.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 12

Key Information

Key Information (click on the key information title to go to appropriate section of the report)

A: Do all workers (including migrant workers) Yes have contracts of employment/employment No agreements? (Go to clause 8 – Regular Employment)

B: Are maximum standard/contracted Yes working hours clearly defined in No contract/employment agreements? (Go to clause 8 – Regular Employment)

C: Were appropriate records available to Yes verify hours of work and wages? No (Go to clause 5 – Living Wage)

D: Were any inconsistencies found? Yes Poor record keeping (if yes describe nature) No Isolated incident (Go to Wages Table) Repeated occurrence

E: For the lowest paid production workers, Wages found: Please indicate the breakdown of workforce are wages paid for standard/contracted according to earnings: hours (excluding overtime) below or above the legal minimum? Below legal ____% of workforce earning under min wage (Go to clause 5 – Living Wage) min 20% of workforce earning min wage Meet 80% of workforce earning above min wage Above

F: % of piece rate workers: None (if applicable)

G: Do the standard/contracted hours stated Yes in a contract/employment agreement exceed No the law or 48 hours per week? (Go to clause 6 – Working hours)

H: If yes, what are the standard/contracted NIL hrs/week Approx. NIL% of ALL workers on these contacted hours per week as stated in the hours contract/employment agreement? (Go to clause 6 – Working hours)

I: Combined hours (standard/contracted plus Yes overtime = total hours) over 60 per week No found? (Go to Working Hours Analysis)

J: Are workers provided with 1 day off in Yes every 7-day-period, or 2 in 14-day-period No (where the law allows)? If ‘No’, please explain:

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 13

K: Are the correct legal overtime premiums Yes paid? No (Go to Wages Table) N/A – there is no legal requirement to OT premium 200 % No O vertime performed

L: Please state what actual OT is paid. Please give details of overtime premium as a % of standard wages: (As a percentage of the workers standard rate) 0% (Go to Working Hours Analysis) 1% – 115% 116% – 124% 125% – 199% 200%+ Please give details: Workers are paid OT as per 200% rate. No overtime performed

M: Is there any night production work at the Yes site? No

N: % of workers living in site provided No accommodation (if applicable):

O: Age of youngest worker found: 27 years (Go to clause 4 – Child labour)

P: Workers under 18 subject to hazardous Yes work assignments? No (Go to clause 3 – Health and Safety)

% of under 18’s at this site (of total workers) NIL %

Q: What form of worker representation/union Union (name) is there on site? Worker Committee (Go to clause 2 – Freedom of Association) Other (specify) None

R: Is it a legal requirement to have a union? Yes (Go to clause 2 – Freedom of Association) No

S: Is It a legal requirement to have a workers Yes committee? No (Go to clause 2 – Freedom of Association)

T: Is there any other form of effective Yes worker/management communication No channel? (Other than union/worker committee) Describe: Facility has provided suggestion box, where employees are (Go to clause 2 – Freedom of Association) free to express their problems / suggestions / complaints for any grievances. While interviewing, all employees reported that they are free to approach the management for any problem

U: Are there any External Processes? Sub–Contracting (Go to clause 8A – Sub–contracting and Home Homeworking working) Other External Process No external processes

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 14

Management Systems

Management Systems:

A: Nationality of Management Indian

B: Gender breakdown of Management + Male: 98 % Supervisors (Include as one combined group) Female: 2 %

C: Majority nationality of workers Indian

D: Number of workers leaving in last 12 03% months as a % of average total number of workers on site over the year (annual worker turnover)

E: Were accurate records shown at the first Yes request? No

F: If No , why not? Not Applicable

G: In the last 12 months, has the site been Yes subject to any fines/prosecutions for non– No compliance to any regulations? Please describe: The site has not been subjected to any fines /prosecutions for non-compliance to any regulations for the last 12 Months.

H: Do policies and/or procedures exist that Yes reduce the risk of forced labour, child labour, No discrimination, harassment & abuse? Please describe: Facility has developed policies and procedures on force labour, child labour, discrimination, harassment & abuse. These policies are displayed at notice board in local language (Hindi) and communicated to all employees.

I: If Yes , is there evidence (an indication) of Facility has developed policies and procedures on force labour, effective implementation? Please give Prevention of child labour, Anti- discrimination, harassment & abuse. details. These policies are implemented effectively in the entire facility. These policies are displayed at notice board in local language (Hindi) and communicated to all employees. All employees were aware about these policies and procedures.

J: Have managers and workers received Yes training in the standards for forced labour, No child labour, discrimination, harassment & Please describe: Training records shows that all managers and abuse? workers have received training on force labour, child labour, discrimination, harassment & abuse.

K: If Yes , is there evidence (an indication) Training records including interaction with management / employees that training has been effective e.g. training shows and confirms that training given to all managers and workers records etc.? Please give details was effective.

L: Are there published, anonymous and/or Yes

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 15

open channels available for reporting any No violations of Labour standards and H&S or Please describe: Facility has provided suggestion boxes for any any other grievances to a 3 rd party? compliant/suggestion.

M: If Yes , are workers aware of these Yes. Workers are aware of suggestion boxes for any channels? Please give details. compliant/suggestion.

N: Have health and safety risks been Yes identified e.g. through internal audits, formal No risk analysis process, worker involvement Please describe: Facilities have Health and Safety Committee and etc.? have regular meetings with its members. Last meeting was held on 27/1/2017

O: If Yes , has effective action been taken to It was noted through the review of records that facility has conducted reduce or eliminate these risks? the occupational health & safety risk assessment, further the facility has provided the health & safety trainings to their employees based on the risk identified

P: Are accidents recorded? Yes No Please describe: All accidents are recorded in accident register. However records show no accident until date.

Q: Has the auditor made a simple calculation Yes to compare capacity with workers’ work load No in order to identify possible unrecorded work Please describe: Auditors have verified Production records. hours?

R: Does the site have all required land rights Factory License No – SPT- ONLINE-11 for employing 148 employees, licenses and permissions (see SMETA Valid till – 31/12/2017 Measurement Criteria )?

S; Does the site have any internationally None recognised system certifications e.g. ISO 9000, 14000, OHSAS 18000, SA8000 (or other social audits). Please detail (Number and date).

T: Is there a Human Resources Yes manager/department? No If Yes, please detail. Please describe: Facility has HR Department.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 16

Worker Analysis

Worker Analysis

Local Migrant Total Home Permanent Temporary Agency Permanent Temporary Agency workers

Worker numbers – 67 00 01 00 00 00 00 68 male

Worker numbers – 15 00 00 00 00 00 00 15 female

Total 82 00 01 00 00 00 00 83

Number of Workers 09 00 01 00 00 00 00 10 interviewed

Contractors: (Individuals supplying workers to site with the workers paid by contractors, not by site) Yes A: Any contractors on site? No

B: If Yes , how many workers supplied by 01 employee from 01 contractor (G.K Group Security) for security contractors processes

C: Are all contractor workers paid according Yes to law? No

If Yes , Please give evidence for contractor Employee interaction and review of records workers being paid according to law:

Migrant Workers: (Please see SMETA Best Practice Guidance and Measurement Criteria for definitions of migrant workers) D: Originating Not Applicable as there is no such employees employed. Locations/Countries:

E: Type of work undertaken by Not Applicable as there is no such employees employed. migrant workers :

F: Were migrant workers Yes recruited through an agency? No If yes, please give details. Please describe: Not Applicable as there is no such employees employed.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 17

Not Applicable as there is no such employees employed.

If Yes , is there a contract with Not Applicable as there is no such employees employed. the agency? Provide details of agencies and contractual arrangements including any fees lodged during the recruitment process.

G: Does the site have a system Yes for checking labour standards of No agencies? Please describe: Not Applicable as there is no such employees employed. If yes, please give details.

H: Percentage of migrant Not Applicable as there is no such employees employed. workers in company provided accommodation:

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 18

Audit Results by Clause 0: Management systems and Code Implementation 0: Managements system and Code Implementation (click here to return to NC Table)

0.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code. 0.2 Suppliers shall appoint a senior member of management who shall be responsible for compliance with the Code. 0.3 Suppliers are expected to communicate this Code to all employees. 0.4 Suppliers should communicate this code to their own suppliers and, where reasonably practicable, extend the principles of this Ethical Code through their supply chain.

Current Systems and Evidence Ex amined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: • Mr. Vipul Goel - Director is responsible to ensure compliance with local law and ETI base code requirements. • Facility has displayed copy of ETI Base Code of Conduct in local language in notice board area. • Facility has obtained factory license. Factory License SPT- ONLINE-11 for employing 148 employees, Valid till – 31/12/2017. • Based from review of records and interaction with management facility has communicated the ETI base code to their suppliers and sub-contractors and obtained a commitment from them to comply with this code requirement.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

Statutory legal documents including Factory license, building plan, building stability certificate, social insurance registration and other documents as applicable were reviewed.

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI/Additional Elements NC against Local Law observed: Review of records Based from facility tour it was noted that, facility has not amended that approved layout plan as per the current floor plan.

As per current layout facility has storage area on second floor however facility has installed plating section in place of storage area.

Local law: In accordance with The Punjab Factory Rules 1952 as applicable to Haryana Rule 3A: [Framed U/S 6 of the Act] Approval of Plans, 2) No addition/alteration or extension in the existing factory building shall be made unless plans in respect of such additions,

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 19

alterations or extensions are approved by the Chief Inspector

ETI requirement: Not Applicable

Recommended corrective action: It is recommended to the facility to amend the building layout plan as per the current layout implemented in the facility.

Action by: Mr. Vipul Goel - Director Timescale: 90 days Verification Method : Desktop

Observation :

Description of observation : Obj ective evidence None Observed observed:

Local law or ETI requirement: Not Applicable Not Applicable

Comments:

Not Applicable

Good Examples observed:

Description of Good Example (GE): Objective evidence observed: None Observed

Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 20

1: Employment is Freely Chosen 1: Employment is Freely Chosen (Click here to return to NC–table)

ETI 1.1 There is no forced, bonded or involuntary prison labour. 1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: • There was no presence of forced / bonded or prison labor at the work place. • Employees are not required to lodge any deposits, identity papers with the facility before or after joining the services. • Employees are free to leave at the end of their shift and there is no compulsion to work overtime. • Employees are free to leave their employer after one month of notice.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): Hiring policy of the facility, personnel files, application form and bio data.

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI NC against Local Law : observed: None Observed Not Applicable

Local law and/or ETI requirement Not Applicable

Recommended corrective action: Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 21

Observation :

Description of observation : Objective evidence None Observed observed: Not Applicable Local law or ETI requirement: Not Applicable

Comments: Not Applicable

Good Examples observed :

Description of Good Example (GE): Objective evidence observed: Not Applicable Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 22

2: Freedom of Association and Right to Collective Bargaining are Respected 2: Freedom of Association and Right to Collective Bargaining are Respected (Click here to return to NC–table) (Click here to return to Key Information)

ETI 2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain collectively. 2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities. 2.3 Workers’ representatives are not discriminated against and have access to carry out their representative functions in the workplace. 2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer facilitates does not hinder, the development of parallel means for independent and free association and bargaining.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems .

Current systems: • At present, there was no union / trade union in the facility. • Facility has formed works committee to address workers issues and minutes of meeting records were available. • Suggestion box was displayed and all employees were free to express their suggestions and complaints if any. • Employees have the right to join any union or form trade unions of their own choice and to bargain collectively. • There is no evidence of suppression of worker’s rights.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): • Policy of freedom of association and collective bargaining. Facility has works committee to discuss and resolve the workers issues and last meeting was conducted on 12/1/2017.

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI NC against Local Law : observed: None Observed Not Applicable

Local law and/or ETI requirement Not Applicable

Recommended corrective action: Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 23

Observation :

Description of observation : Objective evidence None Observed observed:

Local law or ETI requirement: Not Applicable Not Applicable

Comments: Not Applicable

A: Name of union and union No union exist. Is there evidence of free elections? representative, if applicable: Yes No N/A

B: If no union what is parallel means of Works committee Is there evidence of free elections? consultation with workers e.g. worker Yes No N/A committees?

C: Were worker representatives/union Yes No representatives interviewed If Yes , please state how many: 01

D: State any evidence that Employees were aware about the workers committee and its purpose. union/workers committee is effective? Committee members take participation to address their issues. During Specify date of last meeting; topics covered; interview, all of them reported that they are free to approach how minutes were communicated etc. management for any concern. The last meeting conducted was on 12/1/2017.

E: Are any workers covered by Yes No Collective Bargaining Agreement (CBA)

F: If Yes what percentage by trade _Nil___% workers covered by _Nil___% workers covered by Union Union/worker representation Union CBA CBA

G: If Yes , does the Collective Yes Bargaining Agreement (CBA) include No rates of pay Not applicable

Good Examples observed :

Description of Good Example (GE): Objective evidence None Observed observed:

Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 24

3: Working Conditions are Safe and Hygienic 3: Working Conditions are Safe and Hygienic (Click here to return to NC–table) (Click here to return to Key Information)

ETI 3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment. 3.2 Workers shall receive regular and recorded Health & Safety training, and such training shall be repeated for new or reassigned workers. 3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall be provided. 3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers. 3.5 The company observing the code shall assign responsibility for Health & Safety to a senior management representative.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the sys tems .

Current systems: 1.General Health and Safety management • Mr. Vipul Goel - Director is assigned with the responsibility to ensure a healthy and safe work environment. • Potable water was freely available in all areas and test certificates were up-to-date. • Last Drinking water test was conducted on 23/11/2016 • Sufficient toilets segregated by gender were available at all times to workers • Ventilation, temperature and lighting were adequate for the production processes. • Minutes of meetings show that there are monthly meetings between the Health &Safety committee (workers) and the Health & Safety manager, and each point is acted on.

2. Fire Safety • All the Exits and fire exits from each work area were clearly marked • Evacuation diagrams were posted in all areas and understood by all workers interviewed. • Mock drill conducted on 18/1/2017 • Fire-fighting training provided on 18/1/2017 to 09 participants through external body. • No Objection Certificate” issued from local fire department. Valid Till : 31/3/2017 • Facility has sufficient fire safety equipment’s. There were total 26 fire extinguishers, 09 fire alarm, 33 emergency lights, 13 smoke detectors, 3 Hydrant Points, 07 hose reels, 08 Modular sprinkler throughout the facility at all production floors.

3. Electrical safety • All electrical equipment was maintained in good condition such as sockets, plugs, switches and main fuse boards. • There were competent electricians at the site and their training certificates were available for review.

4. Chemical safety

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 25

• All chemicals were correctly labelled. • Material Safety Data Sheets were available and there were hazard diagrams on any chemicals which needed careful handling. • Workers in the chemical store confirmed that they had been trained on correct handling procedures as well as what to do in an emergency.

5. Medical services • There were adequate first aid kits (28 first aid box) in each production area and they were well stocked. • Factory had trained 10 employees in first aid treatment through St. John Ambulance.Dated:15/7/2016.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

• Health and safety policy • Health and safety manual • Health and safety committee minutes • Training records and certificates • Fire equipment maintenance records • Fire drill records • Trained first aider register • Accident reports • Chemical list and MSDS for each chemical • Potable water testing certificates

•

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 26

Non –compliance:

1. Description of non -complian ce: Objective evidence NC against ETI NC against Local Law observed: During facility tour. Based from facility tour it was noted that drinking water points situated within 6 meters of toilets on ground, first and second floor. Photo - 1

Local Law In accordance with the Factories Act 1948 Section 18 (2) chapter (iii) drinking water points shall not be situated within 6 meter of any washing place, urinals, latrine, spittoons, open drain, carrying sullage or effluent or any other source of contamination.

ETI requirement: 3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

Recommended corrective action: It is recommended to the factory to locate drinking water points located on 1st floor minimum 6 meter away from toilets.

Action by: Mr. Vipul Goel - Director Timescale: 60 days Verification Method : Desktop

______

2. Description of non-compliance: NC against ETI NC against Local Law

Based from facility tour, chemical containers were found stored without secondary Objective evidence containment / MSDS and labelling in plating section on second floor and in open observed: terrace area. During facility tour.

Local Law In accordance with Punjab Factory Rules 1952 as applicable to Haryana, Rule 67- Photo No-2 K[Framed U/S 41-B & 112 of the Act] Disclosure of information to workers (1) The occupier of a factory carrying on a hazardous process shall supply to all workers the following information in relation to handling of hazardous materials o substances in the manufacture, transportation, storage and other processes (c) location and availability of all Material Safety Data Sheets as provided in rule 67-J; (d) physical and health hazards arising from the exposure to or handling of substances; (e) measures taken by the occupier to ensure safety and control of physical and health hazards; (f) measure to be taken by the workers to ensure safe holding, storage and transportation of hazardous substances; (g) personal protective equipment required to be used by workers employed in hazardous process or dangerous operations; (h) meaning of various labels and markings used in

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 27

the containers of hazardous substances (j) measure to be taken by the workers in case of any spillage of leakage of an hazardous substance; and (3) The booklets, leaflets and the cautionary notices displayed in the factory will be in the language understood by the majority of the workers and also explained to them.

ETI requirement: 3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

Recommended corrective action: It is recommended to the facility to provide secondary containment / labelling to all the chemical containers / to post MSDS in language understood by the majority.

Action by: Mr. Vipul Goel - Director Timescale: 30 days Verification Method : Desktop ______

3. Description of non-compliance: NC against ETI NC against Local Law Objective evidence observed: Based from facility tour, 04 employees in polishing section on second floor were found During facility tour. working without using ear plugs. Photo -3 Further facility has provided ear plugs to all the employees.

Local Law In accordance with Punjab Factory Rules 1952 as applicable to Haryana, Rule 67- K[Framed U/S 41-B & 112 of the Act] Disclosure of information to workers (1) The occupier of a factory carrying on a hazardous process shall supply to all workers the following information in relation to handling of hazardous materials o substances in the manufacture, transportation, storage and other processes (c) location and availability of all Material Safety Data Sheets as provided in rule 67-J; (d) physical and health hazards arising from the exposure to or handling of substances; (e) measures taken by the occupier to ensure safety and control of physical and health hazards; (f) measure to be taken by the workers to ensure safe holding, storage and transportation of hazardous substances; (g) personal protective equipment required to be used by workers employed in hazardous process or dangerous operations; (h) meaning of various labels and markings used in the containers of hazardous substances (j) measure to be taken by the workers in case of any spillage of leakage of an hazardous substance; and (3) The booklets, leaflets and the cautionary notices displayed in the factory will be in the language understood by the majority of the workers and also explained to them.

ETI requirement: 3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 28

Recommended corrective action: It is recommended to the facility to ensure that all employees use ear plugs during all working hours.

Action by: Mr. Vipul Goel - Director Timescale: 30 days Verification Method : Desktop

4. Description of non-compliance: Objective evidence NC against ETI NC against Local Law observed: During facility tour. Based from facility tour, it was noted that emergency evacuation map posted on second floor was not found as per the actual floor plan.

Local Law In accordance with the Factories Act 1948, Section 38 (1) In every factory, all practicable measures shall be taken to prevent outbreak of fire and its spread, both internally and externally, and to provide and maintain (a) safe means of escape for all persons in the event of a fire, and (b) the necessary equipment and facilities for extinguishing fire. (2) Effective measures shall be taken to ensure that in every factory all the workers are familiar with the means of escape in case of fire and have been adequately trained in the routine to be followed in such cases.

ETI requirement: 3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environment.

Recommended corrective action: It is recommended to the facility to post emergency evacuation map as per the current floor plan.

Action by: Mr. Vipul Goel - Director Timescale: 30 days Verification Method : Desktop

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 29

Observation :

Description of observation : Objective evidence None Observed observed:

Local law or ETI requirement: Not Applicable Not Applicable

Recommended corrective action: Not Applicable

Good Examples observed :

Description of Good Example (GE): Objective Evidence Observed: None Observed Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 30

4: Child Labour Shall Not Be Used (Click here to return to NC–table) (Click here to return to Key Information)

ETI 4.1 There shall be no new recruitment of child labour. 4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the transition of any child found to be performing child labour to enable her or him to attend and remain in quality education until no longer a child. 4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions. 4.4 These policies and procedures shall conform to the provisions of the relevant ILO Standards.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: • Mr. Vipul Goel - Director to ensure that no child is employed in the facility. • Age proof records are maintained in personal file of the employees. No employee employed without age verification. • There was no evidence of child labor or young labor throughout the facility.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): • Recruitment policies • Employment contracts • Age proof documents were maintained in the form of copies of Pan card, Voter Cards, Adhar Cards, School leaving certificates and Dental Certificates.

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI NC against Local Law observed: Not Applicable None Observed

Local law and/or ETI requirement: Not Applicable

Recommended corrective action: Not Applicable

Observation :

Description of observation : Objective evidence None Observed observed: Local law or ETI requirement:

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 31

Not Applicable

Comments: Not Applicable

Good Examples observed :

Description of Good Example (GE): Objective Evidence Observed: None Observed Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 32

Wages are paid 5: Living Wages are Paid (Click here to return to NC–table) (Click here to return to Key information)

ETI 5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and to provide some discretionary income. 5.2 All workers shall be provided with written and understandable information about their employment conditions in respect to wages before they enter employment and about the particulars of their wages for the pay period concerned each time that they are paid. 5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages not provided for by national law be permitted without the expressed permission of the worker concerned. All disciplinary measures should be recorded.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: • Mr. Vipul Goel - Director is responsible to ensure all employees are paid as per applicable legal minimum wages with all legal benefits on time. • Employees are paid as per applicable legal minimum wages. • Facility has not engaged any employee on piece rate. All employees are employed on monthly salary. • All employees are paid on monthly basis on or before 7 th of every month. All employees are provided pay slips. • Social security benefit (provident fund, employee state insurance and Labour welfare fund) were provided to all eligible employees. • Holiday and leave benefits are also provided as per legal requirements. • Deductions from wages as a disciplinary measure and any other illegal deductions are not permitted as per the facility rules. . Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): • Latest legal minimum wages notification issued by state government • 10 payroll records of January 2017 (Current month) and 10 payroll records of September 2016 (random month), & 10 payroll records of March 2016 in (random month) were reviewed in this audit. • Social insurance receipt records. • Annual bonus and annual leave records

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 33

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI NC against Local Law observed: None Observed Not Applicable

Local law and/or ETI requirement: Not Applicable

Recommended corrective action: Not Applicable

Observation :

Description of observation : Objective evidence None Observed observed:

Local law or ETI requirement: Not Applicable Not Applicable

Comments: Not Applicable

Good Examples observed :

Description of Good Example (GE): Objective Evidence Observed: None Observed Not Applicable Wages analysis

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 34

Wages analysis: (Click here to return to Key Information)

A: Sample Size Checked 10 samples from January 2017 - Current month (State number of worker records checked and from 10 samples from September 2016 – Random month which weeks/months – should be current, peak and 10 samples from March 2016 – Random month random/low. Please see SMETA Best Practice Guidance and Measurement Criteria)

B: Are there different legal minimum wage Yes If yes, please give details: grades? If Yes , please specify all. No The Minimum Wage in Haryana with effect from 01st July 2016 to till is as below:

Unskilled –INR – 8,070.44 / per month • Semi-Skilled – A INR – 8,473.96 / per month; • Semi-Skilled – B INR – 8,897.65 / per month; • Skilled – A - INR 9,342.53 / per month • Skilled – B - INR 9,809.66 / per month; • Highly Skilled – INR 10,300.14 / per month

C: If there are different legal minimum grades, Yes If No , please give details: are all workers graded correctly? No Not Applicable N/A

D: What deductions are required by law e.g. Provident Fund (PF), Employee State Insurance (ESI) and social insurance? Please state all types: Labour Welfare Fund (LWF)

E: Have all of these deductions been made? Yes If Yes , Please list all deductions that have been Please list all deductions that have/have not No made: been made. Provident Fund (PF), Employee State Insurance (ESI), Labour Welfare Fund (LWF)

If No , please give details on any deductions which have not been made: Not Applicable

F: Industry norm for this region: In accordance with Minimum Wages Act 1948, Section 12 (please include time period e.g. hour/week/month)

Wages table

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 35

Wages table (Click here to return to Key information)

Process Operator Process Operator Process Operator Worker Type (Lowest paid) (Average paid) (Highest paid)

Select from individual worker records one worker from, lowest, average and highest wages and populate the boxes. Ensure comparison is made for same pay period and only uses full–time workers. See SMETA Best Practice Guidance and Measurement Criteria for completing this:

A: Pay period: January 2017 January 2017 January 2017 (State month selected)

B: Anonymous Employee Helper Packer Operator Reference/Dept.

C: Employee Gender Female Male Male

D: Contracted/Standard 176 hours / month 224 hours / month 208 hours / month working hours: (excluding OT – please include time period e.g. hour/week/month)

E: Contracted /Standard INR 5749 month INR 8446 / month INR 8643 / month work pay rate: (excluding OT – please include time period e.g. hour/week/month)

F: Standard day overtime – Nil Nil Nil hours: (please include time period e.g. hour/week/month)

G: Standard day overtime – Nil Nil Nil wage: (please include time period e.g. hour/week/month)

H: Rest day overtime – Nil Nil Nil hours: (please include time period e.g. hour/week/month)

I: Rest day overtime – wage: Nil Nil Nil (please include time period e.g. hour/week/month)

J: Statutory Holiday overtime Nil Nil Nil – hours: (please include time period e.g.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 36

hour/week/month)

K: Statutory holiday OT – Nil Nil Nil wages: (please include time period e.g. hour/week/month)

L: Total overtime hours: Nil Nil Nil (please include time period e.g. hour/week/month)

M: Incentives/Bonus/ Nil Nil Nil Allowances etc.: (please include time period e.g. hour/week/month)

N: Gross wages: INR 5749 month INR 8446 / month INR 8643 / month (please include time period e.g. hour/week/month)

O: Social insurance and INR 801 per month INR 1172 per month INR 1198 per month other deductions; please list (PF-690 , ESI-101,LWF - (PF-1014 , ESI- 148, (PF-1037 , ESI- 151 , which and amount. 10 ) LWF - 10) LWF-10)

P: Actual wage paid after INR 4948/ month INR 7274/ Month INR 7445 / month deduction: (please include time period e.g. hour/week/month)

Comments: (Please state here any specific reasons/circumstances that explain the lowest and highest gross wages)

The above data is based on the records provided during the audit. Further, the wages depend on the skill sets.

Q: Is there a defined living wage: Yes This is not normally minimum legal No wage. If answered Yes please state Please specify amount/time period: Facility did not define any living wages. amount and source of info: At present facility is following the applicable minimum wages as notified by Please see SMETA Best Practice the State Government and paying accordingly. Guidance and Measurement Criteria.

R: Are workers paid in a timely Yes manner in line with local law? No

S: Is there evidence that equal rates Yes are being paid for equal work: No Details: It was noted during interview with employees that all employees with same skill are paid the same wages and no discrimination noted.

T: How are workers paid: Cash Cheque Bank Transfer- 100 percent Other If other explain: No

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 37

6: Working Hours are not Excessive 6: Working Hours are not Excessive (Click here to return to NC–table) (Click here to return to Key Information)

ETI 6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below, whichever affords the greater protection for workers. Sub–clauses 6.2 to 6.6 are based on international labour standards.

6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.

6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay.

6.4 The total hours worked in any 7 day period shall not exceed 60 hours, except where covered by clause 6.5 below.

6.5 Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all of the following are met: – this is allowed by national law; – this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce; – appropriate safeguards are taken to protect the workers’ health and safety; and – The employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.

6.6 Workers shall be provided with at least one day off in every 7 day period or, where allowed by national law, 2 days off in every 14 day period.

Current Systems and Evidence E xamined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: • Mr. Vipul Goel - Director is responsible for ensuring compliance with regular and overtime hours as per law. • Based from facility tour, working hours including breaks and weekly rest day are displayed on notice board. • The facility has Electronic system (Show Card) to record all the employees IN/OUT time. • Based from the review of time records, employees are observed to be working 08 hours per day 48 hours per week. Overtime is voluntary. • Based from record review and interview with employees 01 day of week off is provided to all employees.

Working hours analysis as follows,

• For January 2017 (Current Month), the average working hours of 10 selected samples were 40.8 hours/week.). • For September 2016 (Random Month), the average working hours of 10 selected samples were 45.6

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 38

hours/week • For March 2016 (Random Month), the average working hours of 10 selected samples were 45.8 hours/week. Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): • Facility Policy. • In/Out time records and Salary register for 10 selected samples for 03 Random months. • Interaction with management and Employees. • Facility working hours details.

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI NC against Local Law observed: None Observed Not Applicable

Local law and/or ETI requirement: Not Applicable

Recommended corrective action: Not Applicable

Observation :

Description of observation : Objective evidence None Observed observed:

Local law or ETI requirement: Not Applicable Not Applicable

Comments: Not Applicable

Good Examples observed :

Description of Good Example (GE): Objective Evidence Observed: None Observed Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 39

Working

Working hours analysis Please include time period e.g. hour/week/month (Go back to Key information)

Systems & Processes

A. What timekeeping systems are Electronic recording system for all company employees used: time card etc.

B: Sample Size Checked 10 samples from January 2017 - Current month (State number of worker records 10 samples from September 2016 – Random month checked and from which 10 samples from March 2016 – Random month weeks/months and type – should be current, peak and random/low: See SMETA Best Practice Guidance and Measurement Criteria )

C: Do ALL workers have Yes If NO, state which type of workers do NOT have contracts/employment agreements? No contracts/employment agreements:

D: Are standard/contracted working Yes If NO, please state which type of workers do NOT have hours defined in all No standard hours defined in contracts/employment contracts/employment agreements? agreements.

E: Are there any other types of Yes If YES, Please complete as appropriate: contracts/employment agreements No used? 0 hrs Part time Variable hrs Other

If “Other”, Please define:

Standard/Contracted Hours worked

F: Do standard/contracted standard Yes If YES give details and comparison (local law/48 hrs hours ever exceed the law or 48 No week) hours per week?

G: What are the actual Highest hours: January 2017 (Current month) – 48 hours / week standard/contracted hours worked in September 2016 (Random month) – 48 hours / week. sample (State per week/month) March 2016 (Random month) - 48 hours / week.

Lowest hours: January 2017 (Current month) – 36 hours / week

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 40

September 2016 (Random month) – 24 hours / week. March 2016 (Random month) - 16 hours / week.

H: Any local waivers/local law or Yes If YES, Please give details permissions which allow No averaging/annualised hours for this site?

Overtime Hours

I: Actual overtime hours worked in Highest OT No Overtime performed sample (State per day/week/month) hours:

Lowest OT No Overtime performed hours:

J: Range of overtime hours over all No Overtime performed workers/or as large a sample as possible. (State per week/month and details)

K: Approximate percentage of No Overtime performed workers on highest overtime hours

L: Is overtime voluntary? Yes Please detail evidence e.g. Wording of No contract/employment agreement/handbook/worker Conflicting interviews/refusal arrangements: Information Interaction with employees

Overtime Premiums

M: Is overtime paid at a premium? Yes Please give details of normal day overtime premium as a No % of standard wages:

0% 1 – 116 – 125 – 150 – 200%+ 115% 124% 149% 199%

Any other comments: No Overtime performed Facility had a policy to compensate all OT hours at 200% of regular rate of wages

N: ETI Code requires a prevailing No standard to give greatest worker Consolidated pay (May be standard wages above minimum legal wage, with protection. no/low overtime premium) If a site pays less than 125% OT Collective Bargaining agreements premium and this is allowed under Other local law, are there other Not Applicable considerations? Please complete the Please explain any checked boxes in N above e.g. detail of consolidated

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 41

boxes where relevant. Multi select is pay CBA or Other. possible. Not Applicable

Rest Days

O: Are workers provided with 1 day Yes Maximum number of days worked without a day off (in off in every 7–day–period, or 2 in 14– No sample): day–period (where the law allows)? 06 Days

Total Hours

P: Range of total hours: Highest total January 2017 (Current month) – 48 hours / week (Quote highest and lowest please include hours time period e.g. hour/week/month) September 2016 (Random month) – 48 hours / week. March 2016 (Random month) - 48 hours / week.

Lowest total January 2017 (Current month) – 36 hours / week hours September 2016 (Random month) – 24 hours / week. March 2016 (Random month) - 16 hours / week.

R: If more than 60 total hours per Overtime is voluntary week and this is legally allowed, are Onsite Collective bargaining allows 60+ hours/week there other considerations? Please Safeguards are in place to protect worker’s health and safety complete the boxes where relevant. Site can demonstrate exceptional circumstances Multi select is possible. Other reasons Not applicable

Please explain any checked boxes in R above

Not applicable

Comments: (please state here any specific reasons/circumstances that explain the highest working hours)

The working hours depend on the production work load.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 42

7: No Discrimination is practiced 7: No Discrimination is Practiced (Click here to return to NC–table)

ETI 7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union membership or political affiliation.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: a) Mr. Vipul Goel – Director is responsible to check discrimination issue in the facility b) No discrimination reported / observed in hiring, compensation, promotion and termination based on race, caste, national origin, religion, age, disability, gender, marital status and sexual orientation. c) All employees have fairly equal opportunity for training and overtime work in their respective departments.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): a) Anti-discrimination policy

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI NC against Local Law observed: None Observed Not Applicable

Local law and/or ETI requirement: Not Applicable

Recommended corrective action: Not Applicable

Observation :

Description of observation : Objective evidence None Observed observed:

Local law or ETI requirement: Not Applicable Not Applicable

Comments: Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 43

Good Examples observed :

Description of Good Example (GE): Objective Evidence None Observed Observed:

Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 44

8: Regular Employment Is Provided 8: Regular Employment Is Provided (Click here to return to NC–table) (Click here to return to Key Information)

ETI 8.1 To every extent possible work performed must be on the basis of recognised employment relationship established through national law and practice. 8.2 Obligations to employees under labour or social security laws and regulations arising from the regular employment relationship shall not be avoided through the use of labour–only contracting, sub–contracting, or home–working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed–term contracts of employment.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: a) Mr. Vipul Goel – Director is responsible to ensure compliance with this code requirement. b) Employment contracts (appointment letters) were available and maintained for all 10 sampled employees in their individual personnel records. c) Facility does not follow and believe in fixed term employment.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): a) Personnel records b) Employment contracts

Non –compliance:

1. Description of non –co mpliance: Objective evidence NC against ETI NC against Local Law observed: None Observed Not Applicable

Local law and/or ETI requirement: Not Applicable

Recommended corrective action: Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 45

Observation :

Description of observation : Objective evidence None Observed observed: Local law or ETI requirement: Not Applicable Not Applicable

Comments: Not Applicable

Good Examples observed :

Description of Good Example (GE): Objective Evidence Observed: None Observed Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 46

8A: Sub–Contracting and Homeworking: 8A: Sub –Contracting and Homeworking (Click here to return to NC–table) (Click here to return to Key Information)

8A.1. There should be no sub–contracting unless previously agreed with the main client. 8A.2. Systems and processes should be in place to manage sub–contracting, homeworking and external processing. Note to auditor on homeworking: Report on whether it is direct or via agents. How many workers, relationship with site and what control systems are in place.

Cu rrent Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems .

Current systems: No sub-contracting process done by facility. No home workers used by the facility.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate):

1) Management & worker interaction 2) In / out materials records 3) Production records

If any processes are sub–contracted – please populate below boxes Process Subcontracted Process 1 Process 2 Name of factory Address

Process Subcontracted Process 3 Process 4 Name of factory Address

Process Subcontracted Process 5 Process 6 Name of factory Address

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 47

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI/Additional Elements NC against Local Law observed: None Observed Not Applicable

Local law and/or ETI /Additional Elements requirement: Not Applicable

Recommended corrective action: Not Applicable

Observation :

Description of observation : Objective evidence None Observed observed:

Local law or ETI/Additional elements requirement: Not Applicable Not Applicable

Comments: Not Applicable

Good Examples observed :

Description of Good Example (GE): Objective Evidence Observed: None Observed Not Applicable

Summary of sub–contracting – if applicable Summary of sub –contracting – if applicable

A: If sub–contractors are used, is Yes there evidence this has been agreed No with the main client? If Yes , summarise details: not applicable

B: Number of sub– Not applicable as no subcontractor used. All production is done in-house. contractors/agents used

C: Is there a site policy on sub– Yes contracting? No If yes, summarise details: Not applicable as no subcontractor used. All

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 48

production are done in-house.

D: What checks are in place to Not applicable as no subcontractor used. All production are done in-house. ensure no child labour is being used and work is safe?

E: What processes are sub– Not applicable as no subcontractor used. All production are done in-house. contracted?

Summary of homeworking – if applicable

F: If homeworking is being used, is Yes there evidence this has been agreed No with the main client? If Yes , summarise details: Not applicable

G: Number of homeworkers Male: None Female: None Total: None

H: Are homeworkers employed direct Directly or through agents? Through Agents Not applicable

I: If through agents, number of Not applicable agents

J: Is there a site policy on Yes homeworking? No Not applicable

K: How does site ensure worker Not applicable hours and pay meet local laws for homeworkers?

L: What processes are carried out by Not applicable homeworkers?

M: Are written agreements in place Yes for homeworkers that include regular No employment? Not applicable

N: Are full records available at the Yes site? No Not applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 49

9: No Harsh or Inhumane Treatment is allowed 9: No Harsh or Inhumane Treatment is Allowed (Click here to return to NC–table)

ETI 9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other forms of intimidation shall be prohibited.

Current Systems and Evidence Exa mined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: a) There is no evidence of harsh or inhumane treatment of employees. b) All employees are treated with respect and dignity. c) Facility’s disciplinary policies are explained to all employees and all employees are well aware about their rights. d) No evidence of physical abuse, sexual or any other harassment / verbal abuse is observed / reported. e) Facility formed Anti-Harassment committee to discuss and resolve the issues and last meeting was conducted on 14/12/2016

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): Disciplinary policies

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI NC against Local Law observed: None Observed Not Applicable

Local law and/or ETI requirement: Not Applicable

Recommended corrective action: Not Applicable

Observation :

Description of observation : Objective eviden ce None Observed observed:

Local law or ETI requirement: Not Applicable Not Applicable

Comments:

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 50

Not Applicable

Good Examples observed :

Description of Good Example (GE): Objective Evidence None Observed Observed:

Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 51

10 A: Entitlement to Work and Immigration 10. Other Issue areas: 10 A: Entitlement to Work and Immi gration (Click here to return to NC–table)

Additional Elements 10A1 Only workers with a legal right to work shall be employed or used by the supplier. 10A2 All workers, including employment agency staff, must be validated by the supplier for their legal right to work by reviewing original documentation. 10A3 Employment agencies must only supply workers registered with them. 10A4 The supplier shall implement processes to enable adequate control over agencies with regards the above points and related legislation.

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: 1. The facility has not engaged any immigrant employees in the facility. 2. Based from the review of employee attendance records and employee’s interview, the facility has not employed any foreign nationals. 3. Based from the review of employee personal files, all the employees are holding the legal rights to work Facility has hired 1 employee through 01contractor G. K Group Security.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): Recruitment policies

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI/Additional Elements NC against Local Law observed: Not Applicable None observed

Local law and/or ETI /Additional Elements requirement: Not Applicable

Recommended corrective action: Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 52

Observation :

Description of observation : Objective evidence None Observed observed:

Local law or ETI/Additional Elements requirement: Not Applicable Not Applicable

Comments: Not Applicable

Good examples observed :

Description of Good Example (GE): Objective Evidence Observed: None observed Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 53

10B4: Environment 4–Pillar 10. Other issue areas 10 B4: Environment 4–Pillar (Click here to return to NC–table) To be completed for a 4–Pillar SMETA Audit and remove the previous page which is 10B2 environment 2 pillar

B.4. Compliance Requirements 10B4.1 Suppliers as a minimum must meet the requirements of local and national laws related to environmental standards. 10B4.2.Where it is a legal requirement, suppliers must be able to demonstrate that they have the relevant valid permits including for use and disposal of resources e.g. water, waste etc. 10B4.3. The supplier shall be aware of their end client’s environmental standards/code requirements and have a system in place to monitor their performance against these. B4. Guidance for Observations 10B4.4. Suppliers should have completed the appropriate section of the SAQ and made it available to the auditor. 10B4.5. Suppliers should have an environmental policy, covering their environmental impact, which is communicated to all appropriate parties, including its own suppliers. 10B4.6. Suppliers shall be aware of the significant environmental impact of their site and its processes. 10B4.7. The site should measure its impacts, including continuous recording and regular reviews of use and discharge of natural resources e.g. energy use, water use (see 4–pillar audit report and audit checks for details). 10B4.8. Suppliers shall seek to make continuous improvements in their environmental performance. 10B4.9. Suppliers shall have available for review any environmental certifications or any environmental management systems documentation 10B4.10. Suppliers should have a nominated individual responsible for co–ordinating the site’s efforts to improve environmental performance. 10B.4.11. Has the site recently been subject to (or pending) any fines/prosecutions for noncompliance to environmental regulations.

Note for auditors and readers. This environment section is intended to take not more than 0.25 auditor days. It is an assessment only and the main requirement is to establish whether a site is meeting applicable environmental laws and/or has any certifications or environmental management systems in place. Following this assessment the client/supplier may decide a full environmental audit is required (see also best practice guidance/environment and guidance for auditor)

Current Systems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: • Mr. Vipul Goel - Directoris responsible for all environmental issues. • Facility is aware of the legal environmental requirements • Facility has conducted necessary air emission testing as required by law on 25/5/2016. • Facility had conducted necessary noise testing as required by law on 25/5/2016 • Facility had conducted necessary air quality testing as required by law on 25/5/2016. • Air & water pollution consent and hazardous storage permission valid up to 31/3/2017

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): • Environmental policy • Air emission testing report like air ambient monitoring report

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 54

Non –compliance:

1. Description of non –compliance: Objective evidence NC against ETI/Additional Elements NC against Local observed: None Observed Not Applicable

Local law and/or ETI/Additional Elements requirement: Not Applicable

Recommended corrective action: Not Applicable

Observ ation :

Description of observation : Objective evidence None Observed observed:

Local law or ETI/Additional elements requirements: Not Applicable Not Applicable

Comments: Not Applicable

Good examples observed :

Description of Good Example (GE): Objective Evidence None Observed Observed:

Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 55

Environmental Analysis (Site declaration only – this has not been verified by auditor. Please state units in all cases below.)

A; Responsible for Environmental issues (Name and Mr. Vipul Goel - Director Position):

B: Does the site have a recognised environmental Yes No system certification such as ISO 14000 or equivalent? Details: No Please detail.

C: Does the site have an Environmental policy? Yes No (For guidance, please see Measurement criteria ) Details : Yes

Does the site have a Biodiversity policy? Yes No (For guidance, please see Measurement criteria ) Details : No

E: Is there any other sustainability systems present such Yes No as Chain of Custody, Forest Stewardship Council Details: No (FSC), Marine Stewardship Council (MSC) etc.? Please detail. (For guidance, please see Measurement criteria )

F: Have all legally required permits been shown? Yes No Please detail. Details: Yes Air & water pollution consent and hazardous storage permission valid up to 31/3/2017

G: Is there a documentation process to record Yes No hazardous chemicals used in the manufacturing N/A process? Details : Yes

H: Is there a system for managing client’s requirements Yes No and legislation in the destination countries regarding Details: Yes environmental and chemical issues?

Usage/Discharge analysis

Criteria Current year: Please state period: Previous Year: Please state period: 01-01-2017 to till date 01-01-2016 to 31.12.2016

Electricity Usage: 30.06 32.98 Kw/hrs

Renewable Energy Usage: Under Planning for Solar Setup - Kw/hrs

Gas Usage: 1.47 Kgs 1.39 kgs Kw/hrs

Has site completed any carbon No No Footprint Analysis?

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 56

If Yes , please state result

Not Applicable
Not Applicable

Water Sources: • Local Authority • Local Authority Please list all sources e.g. lake, river, and local water authority.

Water Volume Used:
480KL
6.08 KL (m³)

Water Discharged: KL : KL : Please list all receiving waters/recipients.

Water Volume Discharged: - 380 Kilo Ltr. - 6.08 kilo Ltr. (m³)

Water Volume Recycled: -NIL -- NIL (m³)

Total waste Produced - 5-6 bags daily - 5-6 bags daily (please state units)

Total hazardous waste Produced: - 4-Tube Light 1-CFL - 38 Tube Light -6 CFL (please state units)

Waste to Recycling: -NIL -NIL (please state units)

Waste to Landfill: - 5-6 bags daily - 5-6 bags daily (please state units)

Total Product Produced - 1,08,000(Varies from product to - 7,62,000(Varies from product (please state units) product) to product)

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 57

10C: Business Ethics – 4–Pillar Audit 10C: Business Ethics – 4-Pillar Audit (Click here to return to NC–table) To be completed for a 4–Pillar SMETA Audit

10C. Guidance for “Ob servations” 10C.1. Suppliers should have completed the appropriate section of the SAQ and have made it available to the auditor. 10C.2. The supplier should have received and acknowledged– preferably in writing – the Business Ethics policy of the auditor/audit company. 10C.3. Suppliers shall seek to conduct their business ethically without bribery, corruption, or any type of fraudulent Business Practice. 10C.4. Suppliers shall be aware of any applicable laws, their end client’s Business Ethics standards/code requirements and have a system in place to monitor their performance against these. 10C.5. Supplier should have a Business Ethics policy concerning bribery, corruption, or unethical Business Practice. This should be clearly communicated to all relevant parties. 10C.6. Suppliers should have a designated person responsible for implementing standards concerning Business Ethics 10C.7. Suppliers should have a transparent system in place for confidentially reporting, and dealing with unethical Business Ethics without fear of reprisals towards the reporter 10C.8. Suppliers should ensure that the staff whose job roles carry a higher level of risk in the area of ethical Business Practice e.g. sales, purchasing, logistics are trained on what action to take in the event of an issue arising in their area.

Note for auditors and readers. This Business Ethics section is intended to take not more than 0.25 auditor days. It is an assessment not an audit and the main requirement is to gather information on the relevant Business Ethics issues in a supply chain. All findings will be recorded as observations not Non– Compliances and the data collected will allow the membership to define appropriate standards over time as part of a continuous review process.

Current Sy stems and Evidence Examined To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is /are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to support the systems.

Current systems: • Mr. Vipul Goel - Director is responsible for compliance with these code requirements. • Management is aware about the requirements.

Evidence examined – to support system description (Documents examined & relevant comments. Include renewal/expiry date where appropriate): Business Ethics policy

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 58

Observation

Description of observation: Objective evidence None Observed observed:

Local law or ETI/Additional elements requirement: Not Applicable Not Applicable Comments: Not Applicable

Good examples observed:

Description of Good Example (GE): Objective Evidence None Observed Observed: Not Applicable

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 59

Worker Interview Summary Worker Interview Summary Worker Interview Summary

A: Were workers aware of the audit? Yes No

B: Were workers aware of the code? Yes No

C: Number of group interviews: 1 groups of 4 employees each (Please specify number and size of groups. Please see SMETA Best Practice Guidance and Measurement Criteria)

D: Number of individual interviews Male: 04 Female: 02 (Please see SMETA Best Practice Guidance and Measurement Criteria)

E: Total number of interviewed Male: 08 Female: 02 workers (Please see SMETA Best Practice Guidance and Measurement Criteria)

F: Interviews were done in private Yes and the confidentiality of the No interview process was communicated to the workers?

G: In general, what was the attitude Favourable of the workers towards their Non–favourable workplace? Indifferent

H: What was the most common Nothing worker complaint?

I: What did the workers like the most Good management behaviour and on time payment about working at this site?

J: Any additional comment(s) None regarding interviews:

K: Attitude of workers to hours Positive worked: Agency Workers

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 60

Agency Workers (if applicable) (workers sourced from a local agent who are not directly paid by the site)

A: Number of agencies used 01 employee hired through 01 contractor from G.K Group Security (average):

B: Were agency workers’ Yes age/pay/hours included within scope No of this audit

C: Were sufficient documents for Yes agency workers available for review? No

Other findings

Other Finding s Outside the Scope of the Code

None Observed

Community Benefits (Please list below any specific community benefits that the site management stated that they were involved in, for example, HIV programme, education, sports facilities)

None Observed

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 61

Photo Form

Facility Outside View Facility Name Anti-Child Labour Policy

Fire Alarm Panel Emergency Assembly Area Marked Notice Board

Abstract of factories act displayed Employees Time Recording Machine Fire Extinguisher

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 62

Fire Hydrant System Hose Reel Change room

Emergency Evacuation map Emergency Light First Aid box provided

Modular Sprinkler and Smoke Fire Alarm call point and fire Goods Lift Detector Extinguisher

Diesel Generator area Electrical Panel Storage Section

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 63

Pressing section Pressing section Cutting / Bidding section

Packing Section Pressing Section Store Packed Goods Storage Area

Empty Cartoon Storage Area Polishing Section Storage area

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 64

Plating section Colouring section Eye Wash Station

Drinking Water Point Toilet Facility Suggestion Box

Non Compliance Photos:

1. Drinking water points situated 2. Chemical containers were found 3. Employees found working without within 6 meters of toilets stored without secondary using ear plugs. containment / MSDS and labelling

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You can leave feedback by following the appropriate link to our questionnaire:

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 65

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Your feedback on your experience of the SMETA audit you have observed is extremely valuable. It will help to make improvements to future versions.

You can leave feedback by following the appropriate link to our questionnaire:

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DISCLAIMER: "This report is for the exclusive use of the client of Intertek named in this report (“ Client ”) and is provided pursuant to an agreement for services between Intertek and Client (“ Client Agreement ”). This report provides a summary of the findings and other applicable information found/gathered during the audit conducted at the specified facilities on the specified date only. Therefore, this report does not cover, and

Intertek accepts no responsibility for, other locations that may be used in the supply chain of the relevant product or service. Further, as the audit process used by Intertek is a sampling exercise only, Intertek accepts no responsibility for any non-compliant issues that may be revealed relating to the operations of the identified facility at any other date. Intertek's responsibility and liability are also limited in accordance to the terms and conditions of the Client Agreement. Intertek assumes no liability to any party, for any loss, expense or damage occasioned by the use of this information other than to the Client and in accordance with the Client Agreement and these disclaimers. The disclaimer should be read in conjunction with the Terms and Conditions of Intertek.”

End of report.

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 66

Audit company: Intertek Report reference: IDA -16076 -01 Date: 02/03/2017 67