Alliance for Water Stewardship Comformity Assessment Report Prepared for Career Electronic (Kunshan) Co., Ltd. (AWS-010-INT-CAB-00-08-00015-0076)
Prepared by: SGS SGS Ref.: CN/SZH Version: 1 Date: Dec. 14, 2018
This is a controlled document, which is subject to SGS document control procedures. It may not be reproduced in whole or in part without the express permission of SGS China
REPORT DETAILS
REFERENCE CLIENT REFERENCE Wang Changzhen REPORT TITLE ALLIANCE FOR WATER STEWARDSHIP CONFORMITY ASSESSMENT REPORT DATE SUBMITTED: Dec. 14, 2018 CLIENT: Changzhen Wang
Facility Manager, Career Electronic (Kunshan) Co., Ltd. T +86 0512 5771 8998 Ext. 589 No. 18, Chin Sha Chiang South Road, Kunshan Development Zone, Kunshan City, Jiangsu Province P.R.China http://www.Career.com.cn/ [email protected] PREPARED BY: Andy ZHOU Jiansong Chang
SGS-CSTC Standards Technical Services Co., Ltd. Suzhou Branch 4st floor, D Building, Ascendas Industry Park, No.5 Xinghan Street, SIP Suzhou, P. R. China. 215021
Tel: +86 (0) 512 6299 0222 E-mail: [email protected] SIGNED: Andy ZHOU Signed:
TECHNICAL Francesca Cerchia Signed: SIGNATORY STATUS FINAL DRAFT NOTICE This document is issued by SGS under its General Conditions of Service accessible at http://www.sgs.com/terms_and_conditions.htm. Attention is drawn to the limitation of liability, indemnification and jurisdiction issues defined therein.
Any holder of this document is advised that information contained hereon reflects SGS’s findings at the time of its intervention only and within the limits of Client’s instructions, if any. SGS’s sole responsibility is to its Client and this document does not exonerate parties to a transaction from exercising all their rights and obligations under the transaction documents. Any unauthorised alteration, forgery or falsification of the content or appearance of this document is unlawful and offenders may be prosecuted to the fullest extent of the law.
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TABLE OF CONTENT
REPORT DETAILS ...... 2
1 EXECUTIVE SUMMARY ...... 4
2 SCOPE OF ASSESSMENT ...... 5
3 STAKEHOLDER ANNOUNCEMENT AND CONSULTATION ...... 8
4 DESCRIPTION OF CATCHMENT ...... 11
5 SUMMARY OF SHARED WATER CHALLENGES ...... 18
6 INDICATORS CHECKLIST ...... 19
7 AUDIT FINDINGS ...... 28
8 SUMMARY ...... 31
9 OPPORTUNITIES FOR IMPROVEMENT...... 32
10 CONCLUSIONS AND RECOMMANDATIONS ...... 33
11 REFERENCES ...... 34
APPENDIX 1 SGS AUDIT CHECKLIST...... 37
APPENDIX 2 CAREER ACTION PLANS RESPONSE TO FINDINGS ...... 38
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1 EXECUTIVE SUMMARY The scope of services covers the conformity assessment of water use in compliance with the AWS International Water Stewardship Standard (Version 1.0) for Career Electronic (Kunshan) Co., Ltd. (hereinafter referred to as “Career” or “the site”) located at No. 18, Chin Sha Chiang South Road, Kunshan Development Zone, Kunshan City, Jiangsu Province P.R.China. The assessment has been completed in compliance with the AWS Certification requirements, Version 1.0 dated July 2015.
Career started operating in 1998, and it manufactures and assembles flexible printed circuit boards.
On Nov. 14-15, 2018, SGS-CSTC Standards Technical Services Co., Ltd. (hereinafter referred to as “SGS”) conducted the conformity assessment for Career’s facilities and activities with regard to certification to the AWS Standard. A total of five findings were raised during the course of the audit process, and they were all categorized as minor non- conformities.
Career responded the findings raised with root cause analysis and action plans, and submitted corrected documentation as evidence to successfully closeall findings raised in the audit.
Given the review of evidence provided and the site visit, SGS recommends that Career be awarded AWS Core Certified status with a surveillance audit interval of annual frequency.
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2 SCOPE OF ASSESSMENT The scope of services covers the conformity assessment of water use in compliance with the AWS International Water Stewardship Standard (Version 1.0) for Career Electronic (Kunshan) Co., Ltd. (hereinafter referred to as “Career”) located at No. 18, Chin Sha Chiang South Road, Kunshan Development Zone, Kunshan City, Jiangsu Province P.R.China. The assessment has been completed in compliance with the AWS Certification requirements, Version 1.0 dated July 2015.
A pre-assessment for Career’s facilities and activities with regard to certification to the AWS Standard was performed by SGS-CSTC Standards Technical Services Co., Ltd. (hereinafter referred to as “SGS”) on Sep. 25-26, 2018. During the pre-assessment, SGS carried out an on-site audit covering water supply facilities, electroplating workshop, chemical warehouse, hazardous waste storage, wastewater treatment facilities, online monitoring devices installed for treated effluent, employees’ canteen and dormitories, personnel interviews and document reviews. A total of twelve findings were raised during the course of the pre-assessment process. Career responded that corrective actions will be taken to successfully close all findings raised in the pre-assessment before the commencement of conformity assessment.
On Nov. 14-15, 2018, SGS conducted the conformity assessment of Career’s facilities and activities with regard to certification to the AWS Standard. Table 2.1 presents SGS audit team. The audit plan is attached as a separate document.
Table 2.1 SGS Audit Team
Audit Team Qualifications/Experience
AWS certified auditor, with more than 12 years experience Andy ZHOU Team Leader in pollution control, environmental impact assessment, ISO14001 audit and training.
AWS certified auditor, with more than 23 years experience in environmental impact assessment (EIA), treatment of wastewater, solid waste and hazardous waste, more than 5 Jiansong Chang Team Member years experience in performing environmental and social risk assessment in line with the IFC E&S, FSC FM and RTRS soy bean production standards.
Dr. Donglin Zhu, senior engineer, WWF’s special advisor of water stewardship, and external tutor of graduate student Donglin Zhu Technical Expert of Environmental College, Fudan University. A key expert to develop the state master plan for controlling Tai Lake contamination, and to be responsible for the study of 13th
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Five-Year Plan for water environmental governance of Tai Lake catchment.
During the conformity assessment, the audit team spent 0.5 day on the stakeholder consultation meeting, and 1.5 day on the inspection of Career’s installations and activities in its workshops, together with personnel interviews and document reviews.
Career provided most of the requested supporting documentation as evidence whilst on site. SGS provided initial feedback on the gaps between Career’s current management and the level required by the standard during the closing meeting of the conformity assessment on Nov. 15, 2018.
Table 2.2 shows some representative pictures regarding the site assessment.
Table 2.2 Photos from Career Site Assessment
Online monitoring devices installed for treated effluent
Rain water discharge
Treated effluent discharge Domestic sewage discharge
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Waste water treatment pool Chemical warehouse
Kuilei Lake (one of Kunshan’s drinking water Internal Training for Employees Regarding Water sources) Stewardship
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3 STAKEHOLDER ANNOUNCEMENT AND CONSULTATION Following the AWS Certification Requirements, before the on-site conformity assessment, SGS prepared a stakeholder announcement on Oct. 15, 2018, which stated Career’s intention to pursue AWS certification. Besides submitting to AWS for publication on the AWS website, the stakeholder announcement was also posted on the information disclosure bulletin board respectively installed at Career’s canteen, outside of Career’s main gate and surrounding community and displayed on Career’s website: http://www.careergroups.com/ZH/csr/Default.aspx?Id=46
SGS received no feedback information since the release of the stakeholder announcement.
Photo 3.1 Information Disclosure Bulletin Board Installed at Career’s Cateen
Photo 3.2 Information Disclosure Bulletin Board Installed Outside of Career’s Main Gate
Photo 3.3 Information Disclosure Bulletin Board Installed at Pingxiang Community
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During the conformity assessment, we also held a stakeholder consultation meeting. Table 3.1 presents the personnel interviewed.
Table 3.1 Personnel Interviewed during Stakeholder Consultation Meeting
Organization Personnel Interviewed
Surrounding community Mr. Xu, director of Pingxiang Community
Ms. Ruan, chairman of trade union
Employees' representative Ms. Jun Duan, employee and also an elected representative of rural migrant workers in Kunshan City
Mr. Jun Zhou, HSE manager of YASEN Supplier Mr. Baodong Cheng and Mr. Jizhang Li, HSE managers of SONGYANG
Mr. Tang, general manager of YUANDENG Neighbouring factory Mr. XIN, director of SANTAI
Ms. Zhenzhen Xu, chief representative of Greater China AWS Ms. Chang Ge, official of Greater China
Ms. Emily Chen, manager of water stewardship Apple Mr. Jack Yao, officer of water stewardship
The stakeholder consulting meeting was held in a Career’s conference room in the morning of 14 November 2018. All participants gave a high appraisal to Career’s efforts for its water stewardship. According to Mr. Xu, director of Pingxiang Community, the quality of local water bodies has been improved a lot since the implementation of more stringent regulations on water pollution control. Managers from Career’s suppliers and neighbouring factories showed their willingness to cooperate with Career to strengthen water stewardship, especially by sharing water-saving technologies. As an elected representative of rural migrant workers in Kunshan City, Ms. Jun Duan expressed a strong sense of water conservation. She often educates her colleagues and children that if no actions are taken to save water, the last drop of water on the earth may be the human’s tears. Ms. Ruan, chairman of Career’s trade union mentioned that a series of measures have been taken by Career to improve employees’ sanitation and health conditions including the establishment of a dormitory committee, a canteen committee, a factory manager’s open day and the trade union’s suggestion box.
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According to Ms. Ruan, employees’ suggestions mainly focused on the canteen and relevant improvement measures had been taken by the canteen.
In addition, the interview with 2 employees during the site visit further showed their satisfaction with Career’s WASH conditions.
Photo 3.4 and 3.5 show the stakeholder consultation meeting.
Photo 3.4 SGS Auditor Introducing the Requirements of AWS Standard
Photo 3.5 Stakeholders Participating in the Consultation Meeting
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4 DESCRIPTION OF CATCHMENT Both Career’s domestic and production water comes from the municipal water supplied by Kunshan Waterworks Group, which has three water supply plants and two water sources including the Kuilei Lake and the Yangtze River. According to the public information of Kunshan Waterworks Group, its water supply covers the whole Kunshan city with the total area of 927km2, and the daily maximum water supply is 1,102,100m3. In addition, according to Kunshan municipal plan, the control target of water consumption in 2020 will be 7.85x108m3. Since the total water consumption of Kunshan in 2017 is 4.3128x108m3, no water scarcity will happen in Kunshan in the next two years.
Career’s domestic sewage is discharged into the municipal pipeline network, and its industrial wastewater is discharged into the local electroplating centre, then into the wastewater treatment plant of Guangda Water Affairs (or named Kunshan Gangdong Wastewater Treatment Plant). The treated effluent is discharged into the Taicangtang River, and finally flows into the Wusongjiang River. Career has built the following wastewater treatment facilities at the site:
1 set of pre-treatment system for highly concentrated alkali wastewater with its treatment capacity of 90 m3/d; 1 set of pre-treatment system for highly concentrated acid wastewater with its treatment capacity of 400 m3/d; 1 set of pre-treatment system for cyanide-containing wastewater with its treatment capacity of 100 m3/d; 1 set of pre-treatment system for nickel-containing wastewater with its treatment capacity of 80 m3/d; 1 set of integrated wastewater treatment system with its treatment capacity of 1,000 m3/d; and 1 set of reclaimed water/gray water reuse system with its treatment capacity of 700 m3/d.
Based on the location of the water source and final destination of effluent, the external boundary for the sustainable water stewardship of the factory is determined as the Wusongjiang River Catchment in Kunshan City.
The Wusongjiang River catchment belongs to a sub-catchment of the Taihu Lake Catchment. The Wusongjiang River originates from the Taihu Lake. It flows through Wujiang, Suzhou, Kunshan and Shanghai's Qingpu, Jiading, Minhang, Putuo, Changning, Jing'an, Hongkou and Huangpu districts, and then enters into the Huangpu River at the Waibaidu Bridge. With the Bei Xinjing as the boundary, the upper reaches of the Wusongjiang River
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are called Wusongjiang River by local people, and the lower reaches of the Wusongjiang River is located in the east of the Bei Xinjing. After entering into the Shanghai area, it is called the Suzhou River by Shanghainese. It is 125 km long, including 53.1 km long in the territory of Shanghai. Wusongjiang River is 40km long from west to east in Kunshan. It enters into Kunshan from Suzhou Industrial Park (where the Jianglizhuang monitoring section controlled by Jiangsu province is installed) and flows into Shanghai (where the Shipu monitoring section controlled by the state is installed) after passing through Kunshan. With the total land area of 735.6 km2, and the total water area of 43.5 km2, the Wusongjiang River catchment covers Bacheng Town, Zhoushi Town, High-tech Zone, Development Zone, Lujia Town, Huaqiao Town, Zhangpu Town and Qiandeng Town. There are 1,917 rivers and 8 provincial key lakes in the catchment.
Figure 4.1, 4.2 and 4.3 respectively show the catchment of the Tai Lake, the catchment of Wusongjiang River, and the water system in the catchment of Wusongjiang River.
Yangtze River
Suzhou Shanghai Tai Wusongjiang Lake River Catchment
Figure 4.1 The Catchment of Tai Lake
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Career
Figure 4.2 The Catchment of Wusongjiang River
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Yangcheng Lake
Loujiang River Shanghai Kuilei Kunshan Jiading Lake District
Qingyanggang River
Suzhou Wusongjiang River Industrial Park Wusongjiang River
Shanghai Qingpu District
Career
Figure 4.3 The Water System in the Catchment of Wusongjiang River
In addition, to protect drinking water sources and ecological environment, Kunshan has demarcated the drinking water protected areas and the ecological protection red lines. Figure 4.4 and 4.5 respectively present the conservation areas of drinking water and the map of ecological conservation red lines.
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Yangcheng Lake
Kuilei Lake
Miaojinghe Water Supply Plant
Legend: First-grade protection zone Second-grade protection zone Prospective protection zone Water intake
Figure 4.4 Kunshan Conservation Areas of Drinking Water
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Yangcheng Lake Kuilei Lake
Miaojinghe Drinking Water Conservation Area
Drinking Water Conservation Area
Conservation Area for Chinese Mitten Crab
Conservation Area for Culter Ablurnus Bailewsky
Wetland of Dianshan Lake
Legend: Red: First-grade control area Green: Second-grade control area
Figure 4.5 Distribution Map of Kunshan Ecological Conservation Red Lines
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Figure 4.6 shows Career’s water supply and wastewater discharge.
Water Supply Plant of Kunshan Development Zone
Kuilei Lake Kunshan Gangdong Wastewater Treatment Plant
Taicangtang River
Electroplating Career Center
Figure 4.6 Career’s Water Supply and Wastewater Discharge (Blue: Water Supply; Orange: Wastewater)
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5 SUMMARY OF SHARED WATER CHALLENGES Career has identified general shared challenges in the catchment and these are listed in Table 5.1. Table 5.1.Detailed Shared Water Challenges for Career Associated Government Relevant/Rationale for Priority Rationale for Countermeasure/Plan No. Water Challenge Relevant/Rationale for Site Authority initiative/Plan* Stakeholders (1-4) Prioritization 1 More difficult to obtain Prohibition of expension project Local residents are given priority Difficulty for Career in 1 Based on Transferring the order for water license construction to water use. More difficult for an expansion Concerns and goods to other production enterprise to get water license for potential site its expension project. influence on 2 More stringent Requirement of higher water Residents will be less affected by The increase of water 1 normal Expansion of water requirements for water recycling and higher quality of water pollution. An enterprise will recycling may result in production: recycling system and efficiency and wastewater discharge invest more money to increase its Career’s increase of non- 1: Small establishment of buffer wastewater discharge water recycling. compliance risk 2: Medium pool for effluent 3 Policy uncertainty No effective solutions are found Non-compliance and penalty may Career may fail to inform top 2 3: High Actively communicate (such as some at the moment and only some occur for an enterprise if it fails to management the reason of with policy-making emergency specified emergency receive the notification in time. restriction for discharge in an department notifications) requirements are advanced. effective and timely manner. 4 Groundwater and Control of soil and water Local residents may complain Invest more money to 2 Taking anti-leakage surface water contanmination and introduce with an enterprise if they discover improve its infrastructure measures contamination risk relevant control parameters soil and water pollution. 5 Insufficient water New sewage treatment facilities Increase the safety risks of local Insufficient drainage during 3 Emergency gathering treatment may be built to collect and treat communities’ drinking water the rain storms may result in tank at the site infrastructure (such as domestic sewage water pollution collection of rainwater and wastewater, and centralized treatment of wastewater) 6 Potentially increased Control of water use during Influence of an enterprise’ normal Increase the stress of water 3 Increasing the efficiency levels of water peak period. Restriction of new production which may result in use of water use shortage and expansion projects. the relocation 7 Inadequate legal and Enhance all kinds of Non-compliance may be not Non-compliance may be not 3 Managing its activities regulatory supervision supervisions including test by a found and corrected in a timely found and corrected in a according to relevant third party. manner. timely manner. environmental regulations * Associated Government Authorities including national and local People’s Governments, national and local environmental protection departments, national and local water affairs departments, etc.
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6 INDICATORS CHECKLIST As per the requirement set out in the Section 2.11.3.1 of the AWS Certification Requirements, Table 6.1 presents all the CORE AWS indicators with the relevant reviewed evidence provided by Career.
Table 6.1 Evidence Reviewed by SGS Against Each CORE AWS Indicator
Indicator Details (Core) Evidence Reviewed/Document Reference
1 Leadership (core)
1.1 Leadership commitment on water stewardship Mr. Jinlong Qiu, Career’s vice general manager has signed the “Water Stewardship Commitment” developed for Career in Kunshan, which are made public on Career Group’s website. Please refer to the following website: http://www.careergroups.com/ZH/csr/Default.aspx?Id=46 REF001: Water Stewardship Commitment
1.1.1 Has the organisation signed and published a statement related to A water stewardship commitment to follow all the AWS core criteria has been signed by his water stewardship commitment that includes all of the Mr. Jinlong Qiu, Career’s vice general manager. This commitment has been displayed on elements listed in core criteria 1.1? the website of Career Group: http://www.careergroups.com/ZH/csr/Default.aspx?Id=46 and posted on the bulletin board respectively installed at Career Kunshan factory, and nearby community (Donggao Community). REF002: Bulletin board installed at employees’ canteen of Career REF003: Bulletin board Installed outside of factory main gate of Career REF004: Bulletin board installed at Donggao Community
1.2.1 Has the organisation elaborated, agreed upon and discloses a A water stewardship policy has been made public on Career Group’s website: water stewardship policy? http://www.careergroups.com/ZH/csr/Default.aspx?Id=46 and posted on the bulletin board respectively installed at Career Kunshan factory, and nearby community (Donggao Community).
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Indicator Details (Core) Evidence Reviewed/Document Reference REF005: Water Stewardship Policy
2 Water challenges (core)
2.1.1 Site boundaries (map) REF006: Layout of Career Factory
2.1.2 Name and location of sources of water (immediate and ultimate) REF007: Map of Water Supply and Wastewater Discharge
2.1.3 Name and location of effluent discharges REF007: Map of Water Supply and Wastewater Discharge REF008: Map of Water System in the Catchment of Wusongjiang River
2.1.4 Description or map of catchment (s) REF009: Catchment of Tai Lake REF010: Catchment of Wusongjiang River
2.2.1 Identification of stakeholders and their water challenges (list of REF011: List of Stakeholders stakeholders, prior engagement and their water challenges)
2.2.2 Site sphere of influence (how the stakeholders are within the REF012: EIA Report developed for Career’s construction project in July 2018 (page 34-35) sphere of influence).
2.3.1 Catchment data (catchment plan, public initiatives and/or public REF013: List of Catchment Plans, Scenarios and Notifications updated in 2018 goals for the site) REF014: Response to Finding 01MINCAR
2.3.2 Water governance for the catchment: Water legal and regulatory REF015: List of national and local applicable laws, regulations and standards related to requirements, including water and water use rights water and water use rights updated in 2018
2.3.3 Water balance for the catchment (surface water, ground water, REF016: Career Water Stewardship Report other)
2.3.4 Appropriate and credibly measured data to represent the physical, REF016: Career Water Stewardship Report chemical and biological status of the site’s water source(s) by
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Indicator Details (Core) Evidence Reviewed/Document Reference temporally relevant time unit, and commentary on any anticipated future changes in water quality
2.3.5 Water related areas for the catchment: identification of the areas REF017: Conservation Plan for Ecological Red Line Areas of Jiangsu Province and description of current status and trends REF018: Implementation Plan for Ecological Red Line Areas of Kunshan City REF019: Distribution Map of Kunshan Ecological Conservation Red Lines EEF020: Kunshan Conservation Areas of Drinking Water
2.3.6 Infrastructure for the catchment: available information on current REF016: Career Water Stewardship Report and projected sufficiency of water to meet the needs of the catchment
2.4.1 Water data for the site: water stewardship and incident response REF021: Career Water Stewardship Plan (EP05-F1) plan REF022: Procedure for Emergency Control REF023: Risk Assessment Report for Emergent Environmental Incidents REF024: Emergency Response Plan for environmental emergencies registered in local environmental protection authority REF025: Response to Finding 02MINCAR
2.4.2 Water data for the site: water balance (volumetric balance of REF026: Analysis of Water Balance in July 2018 water input and output) REF027: Analysis of Water Balance in August 2018 REF028: Analysis of Water Balance in September 2018 REF029: Analysis of Water Balance in October 2018 REF030: Summary Analysis of Water Balance from Janaury to October 2018
2.4.3 Water data for the site: water quality (direct and outsourced water REF031: Pictures of online monitoring devices effluent and also possible pollution sources) REF032: Test report for treated effluent in August 2018
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Indicator Details (Core) Evidence Reviewed/Document Reference REF033: Test report for treated effluent in September 2018 REF034: Test report for treated effluent in October 2018
2.4.4 Water data for the site: water quality (inventory of chemicals REF035: List of chemicals stored on site that are possible causes of water pollution) REF036: Emergency response plan for chemical leakage
2.4.5 Water data for the site: On-site identified water related. REF017: Conservation Plan for Ecological Red Line Areas of Jiangsu Province Documentation identifying existing, or historic, onsite Important REF018: Implementation Plan for Ecological Red Line Areas of Kunshan City Water-Related Areas, including a description of their status REF019: Distribution Map of Kunshan Ecological Conservation Red Lines EEF020: Kunshan Conservation Areas of Drinking Water
2.4.6 Water data for the site: water related costs, revenues and REF037: Analysis of water-related costs quantification of social, environmental and economic value generated by the site to the catchment
2.5.1 Indirect water use: list primary inputs with their associated REF038: List of suppliers of raw materials and chemicals including their water use and (annual) water use and, if possible, the origin of the water related water risk
2.5.2 Indirect water use: list of outsourced services that consume or REF038: List of suppliers of raw materials and chemicals including their water use and affect water quality. List estimated annual withdrawals and quality related water risk data. REF039: Response to Finding 03MINCAR
2.6.1 List of shared water challenges that affect the catchment REF040: List of Shared Water Challenges in the Catchment
2.7.1 Site risks and opportunities: list of site water related risks and REF041: Career Water-Related Risks and Opportunities actions to address the challenges
2.7.2 Site risks and opportunities: list water related opportunities REF041: Career Water-Related Risks and Opportunities
2.7.3 Site risks and opportunities: analysis of potential savings/value REF041: Career Water-Related Risks and Opportunities creation that could result from actions to address the challenges.
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Indicator Details (Core) Evidence Reviewed/Document Reference Look at the actions in the context of water quality, water related areas, water governance, etc.
3 Stewardship strategy and plan (core)
3.1.1 Evidence of a system that periodically evaluates compliance with REF015: List of national and local applicable laws, regulations and standards related to legal and regulatory requirements in criteria 2.3, together with water and water use rights updated in 2018 names of those responsible. REF042: Controlling Procedure for Laws, Regulations and Other Requirements (EP04) REF043: Table of compliance review
3.2.1 Stewardship strategy that contains water challenges within the REF044: Career Water Stewardship Strategy catchment and risks for the site together with the site responses
3.2.2 Stewardship plan that contains: a) List of targets (as per criteria 2.7) and how continuous REF045: Procedure for the Management of Objectives and Targets (EP05) improvement and best practice are achieved. The targets need to REF046: Table for Tracking the Achievement of Objectives and Targets (EP05-F2) be SMART REF047: Table of Objectives and Targets in 2018 REF021: Career Water Stewardship Plan (EP05-F1) b) Proposed actions to achieve the targets and names of individuals REF021: Career Water Stewardship Plan (EP05-F1) responsible for each c) A budget for the proposed actions with a cost benefit analysis REF021: Career Water Stewardship Plan (EP05-F1) d) Links to the desired results in terms of risks/opportunities, water REF021: Career Water Stewardship Plan (EP05-F1) stewardship outcome and shared water challenges
3.3.1 Evidence of responsiveness and resilience to water related risks REF022: Procedure for Emergency Control embedded in the site’s incident response plan REF023: Risk Assessment Report for Emergent Environmental Incidents
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Indicator Details (Core) Evidence Reviewed/Document Reference REF024: Emergency Response Plan for environmental emergencies registered in local environmental protection authority REF025: Response to Finding 02MINCAR
3.4.1 Evidence of notification to relevant catchment authority of the REF048: Record of communication with local environmental protection authority via email intention of the site to contribute to the objectives of the catchment plan
4 Implementation of the water stewardship plan
4.1.1 Evidence of compliance legal and regulatory requirements with REF049: Approvas of local environmental protection authority regarding Career projects regards to water balance, water management and Important REF050: Pollutant discharge permit Water related areas REF051: Agreement signed between Career and Guangda Water Affairs Group regarding its wastewater treatment REF032: Test report for treated effluent in August 2018 REF033: Test report for treated effluent in September 2018 REF034: Test report for treated effluent in October 2018 REF067: Records of Career’s rectification of non-compliance
4.1.2 Evidence of efforts to provide safe drinking water and sanitation REF052: Test report for drinking water quality of secondary water supply in July 2018 where stakeholders have an unmet human right
4.2.1 and Evidence that the site water balance targets are met. If in a water REF016: Career Water Stewardship Report 4.2.2 scarcity situation, also evidence that there is a continuous REF047: Table of Objectives and Targets in 2018 decrease in water withdrawals
4.2.3 Only in scarcity situations, evidence of no net increase in water It is not a water scares catchment. scarcity REF016: Career Water Stewardship Report
4.3.1 Evidence that shows that water quality targets are met REF016: Career Water Stewardship Report
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Indicator Details (Core) Evidence Reviewed/Document Reference REF052: Test report for drinking water quality of secondary water supply in July 2018
4.3.2 For water quality stressed catchments only: evidence of continual It is not a water quality stressed catchment. improvement or best practice
4.3.3 For water quality stressed catchments only and where the site It is not a water quality stressed catchment. wishes to increase effluent levels of water quality parameters: evidence of no net degradation in water quality in the catchment
4.4.1 Evidence that targets for the Important Water related Areas have Although the ecological red line areas of Jiangsu Province and Kunshan City had defined been met in the catchment, Career is located at the downstream of the ecological red line areas. Therefore, it has little influence on the water related areas for the catchment.
4.4.2 Where Important Water Related Areas is a shared water Please refer to the indicator 4.4.1. challenge, evidence that best practice are met.
4.5.1 Evidence of the site’s on-going efforts to contribute to good REF053: Contact List of Local Catchment Management Authorities catchment governance (evidence of coordination and cooperation RFE054: Records of participating in water-related meetings organized by local with catchment management authorities) environmental protection authority
4.5.2 Only for weak water governance catchments: evidence of As one of the most developed provinces and the most developed city in China, Jiangsu continual improvement/best practice Province and Kunshan City have paid great attention to water protection. Therefore, the catchment where Career is located does not belong to a weak water governance catchment.
4.6.1 Evidence that site product suppliers and water related service REF038: List of suppliers of raw materials and chemicals including their water use and providers have been contacted and are taking actions to related water risk contribute to the water stewardship outcomes REF058: Response to Finding 04MINCAR
4.7.1 List of actions to ensure WASH on site REF059:Pictures of Employees’ Dormitoriy REF060:Test report for drinking water quality in 2017
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Indicator Details (Core) Evidence Reviewed/Document Reference
4.8.1 Evidence and list of key owners of the water infrastructure and REF021: Career Water Stewardship Plan (EP05-F1) content of message that has been conveyed related to the site REF044: Career Water Stewardship Strategy risks and shared water challenges REF061: Record of sharing water stewardship plan and water stewardship strategy with local environmental protection authority REF062: Record of sharing water stewardship plan and water stewardship strategy with Guangda Water Affairs Group
5 Evaluation (core) “against the actions taken in the implementation of the plan”. Expectation of such an evaluation at least annually. For the first implementation, look for evidence that these indicators are included in the plan.
5.1.1 Post implementation data and discussion on performance (water REF063: Summary of annual management meeting in 2017 risk)
5.1.2 Total amount of water related costs, cost saving and value REF063: Summary of annual management meeting in 2017 creation with regards to the actions of criteria 3.2
5.1.3 Updated data for indicator 2.4.7 on catchment shared value This is the initial assessment. creation
5.2.1 Evidence of evaluation of water related emergencies and extreme No water related emergencies and extreme events occurred at the site in recent years. events (effectiveness of preventive and corrective measures) and inclusion of lessons learnt in the updated action plan
5.3.1 Feedback and commentaries from stakeholders on the site water REF064: Summary of satisfaction survey regarding Career’s water stewardship stewardship performance and factor input in the updated action plan
5.4.1 Update of the plan with the inputs from indicators 5.1.1, 5.1.2, This is the initial assessment. 5.2.1, 5.3.1. Update does not apply for the first implementation/audit
6 Disclosure and communication of performance (core)
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Indicator Details (Core) Evidence Reviewed/Document Reference
Disclosure and public availability of summary related to the general governance structure of the site’s management with REF065: Career water-related governance structure 6.1.1 names of those accountable for compliance with water related REF066: Response to Finding 04MINCAR laws and regulations
REF002: Bulletin board installed at employees’ canteen of Career Disclosure of summary of site’s water stewardship results against 6.2.1 REF003: Bulletin board Installed outside of factory main gate of Career the targets REF004: Bulletin board installed at Donggao Community
Disclosure and public availability of efforts to address shared REF061: Record of sharing water stewardship plan and water stewardship strategy with challenges and report on actions taken to help address these local environmental protection authority 6.3.1 challenges and engage stakeholders, including public sector agencies
6.4.1 Document and make available a list any site water compliance On 18 June 2018, Career received a rectification notice issued by local environmental violation together with the corrective action implemented to protection authority regarding its no EIA approvals for one gilding production line and one prevent further occurrence. tinning production line, and part of industrial effluent discharged into rainwater pipeline network. The deadline for the rectification was scheduled on 31 July 2018. Career paid great attention to the rectification notice, and rectified its non-compliance activities on time. Meanwhile Career keeps close contact with local environmental protection authority, and its final rectification results had been approved by local environmental protection authority and made public. Career maintains the relevant records. REF067: Records of Career’s rectification of non-compliance
6.5.1 Evidence of awareness related initiatives at site level with dates of REF068: Attendance list for training of water stewardship communications and, if possible, level of awareness REF069 On-site traing pictures REF070: Career water stewardship training materials
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7 AUDIT FINDINGS Five minor non-conformities were raised during the audit process. They were considered partially meeting the AWS Core criterion requirement, and some small adjustments were requested to make to the documentation in order to be considered fully compliant. Table 7.1 shows the details of the minor non-conformities and required new information.
Table 7.1 Minor Non-Conformities Raised during the AWS Audit Process
No. Type Ref. Details Response by Career Relevant References
1 Minor Non- 01MINCAR Indicator 2.3.1 List of relevant aspects of On 22 November 2018, Career provided a corrective REF013: List of Catchment Conformance catchment plan(s), significant publicly led action plan for 01MINCAR, which consisted of root Plans, Scenarios and initiatives and/or relevant waterrelated analysis, corrective actions, responsible person and Notifications updated in 2018 public policy goals for the site implementation deadline. Meanwhile, Career provided (with relevant articles) the evidence of completing the corrective actions. Career has established an update list of REF014: Response to Finding catchment plans, scenarios and Relevant articles of catchment plans, scenarios and 01MINCAR notifications. However, no aspects of the notifications applicable to Career’s water stewardship catchment plans related to Career’s had been identified, and a corresponding list was water stewardship were identified, developed. especially for some key catchment plans such as the Conservation Plan for Ecological Red Line Areas of Jiangsu Province and the Implementation Plan for Ecological Red Line Areas of Kunshan City.
2 Minor Non- 02MINCAR Indicator 2.4.1 Copies of existing water On 22 November 2018, Career provided a corrective REF022: Procedure for Conformance stewardship and incident response plans action plan for 02MINCAR, which consisted of root Emergency Control analysis, corrective actions, responsible person and Currently, the national and local REF025: Response to Finding implementation deadline. Meanwhile, Career provided environmental protection authorities have 02MINCAR the evidence of completing the corrective actions. established a lot of water quality monitoring sections at the rivers in the Career evaluated the water related emergencies caused catchment. If the deterioration of water by the production restriction, suspension or even quality is monitored, the national or local shutdown required by local environmental protection
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No. Type Ref. Details Response by Career Relevant References environmental protection authorities will authority because of the deterioration of river water launch their emergency response plans, quality in the catchment and developed relevant which may result in the production response plan, which had been integrated into Career’s restriction, suspension or even shutdown Procedure for Emergency Control. of a factory to reduce effluent discharge. However, Career fails to evaluate this water related emergencies and develop its response plan.
3 Minor Non- 03MINCAR Indicator 2.5.2 List of outsourced On 22 November 2018, Career provided a corrective REF071: Test report for treated Conformance services that consume water or affect action plan for 03MINCAR, which consisted of root effluent of YASEN in 2018 water quality. analysis, corrective actions, responsible person and REF072: Test report for treated implementation deadline. Meanwhile, Career provided Career has collected the indirect water effluent of SONGYANG in 2018 the evidence of completing the corrective actions. use and wastewater discharge of its main REF040: Response to Finding suppliers of raw materials and chemicals. Career collected the test reports of wastewater 03MINCAR However, no test report of wastewater discharge from YASEN and SONGYANG, two major discharge is collected by Career suppliers located in the same catchment. The testing regarding its main suppliers of raw results confirmed their compliance with national and materials and chemicals. local wastewater discharge standards. In addition, Career said that they will optimize its management of suppliers and more attention will be paid to their water- related performance in 2019.
4 Minor Non- 04MINCAR Indicator 4.6.1 List of suppliers and On 22 November 2018, Career provided a corrective REF073: Summary Table of Conformance service providers, along with the actions action plan for 04MINCAR, which consisted of root Energy & Water Efficient they have taken as a result of the site’s analysis, corrective actions, responsible person and Projects of YASEN in 2018 engagement relating to indirect water use implementation deadline. Meanwhile, Career provided REF059: Response to Finding the evidence of completing the corrective actions. Career has asked its suppliers to provide 04MINCAR water stewardship plan. As one of Career collected YASEN’s water saving scheme which Career’s main suppliers, YASEN is consists of responsible person, implementation schedule implementing a project regarding the and cost analysis. reuse of steam condensate. However, no
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No. Type Ref. Details Response by Career Relevant References specific implementation scheme was collected by Career.
5 Minor Non- 05MINCAR Indicator 6.1.1 Disclosed and publicly On 22 November 2018, Career provided a corrective REF054: Response to Finding Conformance available summary of governance at the action plan for 05MINCAR, which consisted of root 05MINCAR site, including those accountable for analysis, corrective actions, responsible person and compliance with water-related laws and implementation deadline. Meanwhile, Career provided regulations the evidence of completing the corrective actions. Although Career has established its Career has disclosed its water-related governance water-related governance structure and structure and contact information on Career Group’s contact information, it failed to disclose website: relevant information. http://www.careergroups.com/ZH/csr/Default.aspx?Id=46
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8 SUMMARY Based on the review of documents presented by Career, the interview with Career’s managers and employees, the interview with local stakeholders, and the site reconnaissance, Career has paid great attention to its water stewardship. A considerable quantity of effort and work has been put into the preparation for the audit of AWS certification.
Five minor non-conformities were raised during the audit process. They were considered partially meeting the AWS Core criterion requirement, and some small adjustments were requested to make to the documentation in order to be considered fully compliant. Career provided SGS additional information and documents after the completion of site visit to ascertain its compliance to the AWS Standard. No further action was deemed necessary.
All evidence submitted to SGS in response to the findings was reviewed and evaluated for compliance to the AWS standard. All actions were accepted as sufficient to demonstrate compliance and the findings were cleared and closed.
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9 OPPORTUNITIES FOR IMPROVEMENT This is the initial conformity assessment for Career against the AWS Standard, and more attention is paid to the documented plan and implementation to date. Less focus was placed on the evaluation of Career’s performance against the indicators as this was the first year of operation under the intention of conformity to the AWS Standard. Therefore, it allows for many areas for improvement going forward.
The future audits will additionally evaluate Career’s performance against the AWS Standard indicators and how this is monitored and presented as compliance. Thus, SGS recommends that Career develop practicable ways to monitor its performance against the AWS Standard indicators, and keep relevant records in anticipation of future audits.
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10 CONCLUSIONS AND RECOMMANDATIONS Given the review of evidence presented and the site reconnaissance performed at Career, SGS recommends that Career be awarded the AWS Core Certified status with a surveillance audit interval of annual frequency.
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11 REFERENCES REF001: Water Stewardship Commitment
REF002: Bulletin board installed at employees’ canteen of Career
REF003: Bulletin board Installed outside of factory main gate of Career
REF004: Bulletin board installed at Donggao Community
REF005: Water Stewardship Policy
REF006: Layout of Career Factory
REF007: Map of Water Supply and Wastewater Discharge
REF008: Map of Water System in the Catchment of Wusongjiang River
REF009: Catchment of Tai Lake
REF010: Catchment of Wusongjiang River
REF011: List of Stakeholders
REF012: EIA Report developed for Career’s construction project
REF013: List of Catchment Plans, Scenarios and Notifications updated in 2018
REF014: Response to Finding 01MINCAR
REF015: List of national and local applicable laws, regulations and standards related to water and water use rights updated in 2018
REF016: Career Water Stewardship Report
REF017: Conservation Plan for Ecological Red Line Areas of Jiangsu Province
REF018: Implementation Plan for Ecological Red Line Areas of Kunshan City
REF019: Distribution Map of Kunshan Ecological Conservation Red Lines
EEF020: Kunshan Conservation Areas of Drinking Water
REF021: Career Water Stewardship Plan (EP05-F1)
REF022: Procedure for Emergency Control
REF023: Risk Assessment Report for Emergent Environmental Incidents
REF024: Emergency Response Plan for environmental emergencies registered in local environmental protection authority
REF025: Response to Finding 02MINCAR
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REF026: Analysis of Water Balance in July 2018
REF027: Analysis of Water Balance in August 2018
REF028: Analysis of Water Balance in September 2018
REF029: Analysis of Water Balance in October 2018
REF030: Summary Analysis of Water Balance from Janaury to October 2018
REF031: Pictures of online monitoring devices
REF032: Test report for treated effluent in August 2018
REF033: Test report for treated effluent in September 2018
REF034: Test report for treated effluent in October 2018
REF035: List of chemicals
REF036: Emergency response plan for chemical leakage
REF037: Analysis of water-related costs
REF038: List of suppliers of raw materials and chemicals including their water use and related water risk
REF039: Response to Finding 03MINCAR
REF040: List of Shared Water Challenges in the Catchment
REF041: Career Water-Related Risks and Opportunities
REF042: Controlling Procedure for Laws, Regulations and Other Requirements (EP04)
REF043: Table of compliance review
REF044: Career Water Stewardship Strategy
REF045: Procedure for the Management of Objectives and Targets (EP05)
REF046: Table for Tracking the Achievement of Objectives and Targets (EP05-F2)
REF047: Table of Objectives and Targets in 2018
REF048: Record of communication with local environmental protection authority via email
REF049: Approvas of local environmental protection authority regarding Career projects
REF050: Pollutant discharge permit
REF051: Agreement signed between Career and Guangda Water Affairs Group regarding its wastewater treatment
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REF052: Test report for drinking water quality of secondary water supply in July 2018
REF053: Contact List of Local Catchment Management Authorities
RFE054: Records of participating in water-related meetings organized by local environmental protection authority
REF058: Response to Finding 04MINCAR
REF059:Pictures of Employees’ Dormitoriy
REF060:Test report for drinking water quality in 2017
REF061: Record of sharing water stewardship plan and water stewardship strategy with local environmental protection authority
REF062: Record of sharing water stewardship plan and water stewardship strategy with Guangda Water Affairs Group
REF063: Summary of annual management meeting in 2017
REF064: Summary of satisfaction survey regarding Career’s water stewardship
REF065: Career water-related governance structure
REF066: Response to Finding 04MINCAR
REF067: Records of Career’s rectification of non-compliance
REF068: Attendance list for training of water stewardship
REF069 On-site traing pictures
REF070: Career water stewardship training materials
REF071: Test report for treated effluent of YASEN in 2018
REF072: Test report for treated effluent of SONGYANG in 2018
REF073: Summary Table of Energy & Water Efficient Projects of YASEN in 2018
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APPENDIX 1 SGS AUDIT CHECKLIST
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APPENDIX 2 CAREER ACTION PLANS RESPONSE TO FINDINGS
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