Woolworths Group Quality Technical Services:
Ethical Audit
Ethical Audit
Version 2.0
Group Quality Technical
Services
Ethical Audit: April 2016
Page 1 of 22
Woolworths Group Quality Technical Services:
Ethical Audit
AUDITOR GUIDANCE
This audit is to include all people (Workers/visitors / contractors / child minders) and property
(Production, Warehouse, Accommodation, Child care) within the production site, regardless of if they
are associated with the production area itself. Off site accommodation shall also be considered as part
of the audit unless otherwise agreed by Woolworths Ltd prior to audit.
The auditor, during a tour of the employment site, observing physical conditions and current practices
in all areas, shall form a view of how they compare with the applicable standards and codes including
how the site performs against its own policies and procedures.
Auditors shall visit all areas of the employment site, in some cases, employment sites may prohibit
visitors from walking through some areas or forbid photography for reasons of safety or commercial
confidentiality. The auditor shall note restrictions on access or photography in the audit report.
Auditors should make every effort to ensure production is not disrupted during the site tour, whilst
ensuring that they are able to view all production areas during busy production periods.
During the site tour, the auditor shall meet a range of managers / supervisors / workers across all site
operations, the auditor shall not be purely guided by management on areas to visit and shall freely
investigate all areas they believe are needed to perform the audit.
The auditor shall raise issues as they arise, giving managers the opportunity to seek clarification,
respond, and provide explanations or further evidence.
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Ethical Audit
Include space for an executive Summary
Factory Overview
Company Information
Site Name:
Street Number:
Building Number:
Street Name:
Address:
City:
State / Province:
Post Code:
Country:
First Name:
Last Name:
Contact Person:
Position:
Contact Numbers:
Phone:
Fax:
Contact E-mail:
Types of products to be supplied/currently supplied:
Language(s) spoken
at the factory:
Name & title of people present during the opening and closing meetings:
Who was the responsible senior manager for ensuring compliance with client ethical codes?
Major production processes used:
Peak Production Season:
Does the facility fall under the definitions of a Shared
Facility as described in the “Shared Facilities Business
Rule”?
Please specify the other uses in the building that are
not under your management/control.
Please specify the local authority responsible for
building safety and fire licensing and regulations.
Any Additional
Information
Ethical Outcome Summary
Audit Company:
Audit Date:
Time in and time out
Audit Type:
Announced/Special
Ethical Non-Conformance Issued
Auditor Name
No. NC‟s Raised
Close Out Due Date
CRITICAL
MAJOR
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Woolworths Group Quality Technical Services:
Ethical Audit
MINOR
Key Factory Information
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
Details
Attitude of managers:
(Include attitude to audit, and audit process. Both positive and negative information should be included)
Details
Does the factory have access to a copy of the Woolworths Ltd Ethical Sourcing Policy?
Has the factory demonstrated implementation and compliance to the Policy requirements?
Do all workers (including migrant workers) have contracts of employment?
Yes/No
Were appropriate records available to verify hours of work and wages?
Yes/No
Were any inconsistencies found? (if yes describe nature)
Yes/No
Details
For the lowest paid production worker, are wages paid for standard hours (excluding
overtime) below or above the legal minimum?
Yes/No
Wages found:
Please indicate the breakdown of workforce according to earnings:
Below Legal Min
____% of workforce earning under min wage
Meet
Above
____% of workforce earning min wage
____% of workforce earning above min wage
% of piece rate workers:(If applicable)
Combined hours (standard and overtime) over 60 per week found?
Are the correct overtime premiums paid?
Yes/No
Is there any night production work at the site?
Yes/No
% of workers living in site provided accommodation (if applicable):
Age of youngest worker found:
Are workers under 18 subject to hazardous work assignments?
_____% of under 18‟s at this site (out of total workers)
Yes/No
What form of worker representation / union is there on site?
Is it a legal requirement to have a union?
Yes/No
Is It a legal requirement to have a workers committee?
Yes/No
Is there any other form of effective worker/management communication channel?
Yes/No
Yes/No
Nationality of Management
Majority nationality of workers
Number of workers leaving in last 12 months as a % of average total number of
workers on site over the year (annual worker turnover)
_____ %
Were accurate records shown at the first request? If not, why not?
Yes/No
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In the last 12 months, has the site been subject to any fines/prosecutions for noncompliance to any regulations? Please describe:
Yes/No
Worker Analysis
Worker
numbers
Local
Permanent
Temporary
Migrant
Agency
Permanent
Temporary
Agency
Home
workers
Male
Female
Total
Number of
Workers
interviewed
Contractors:
(Individuals supplying workers to site with the workers paid by contractors, not by site)
Any contractors on site?
Yes/No
If yes, how many workers supplied by contractors
Are all contractor workers paid according to local law?
Yes/No
Migrant Workers
Originating Locations/Countries:
Work undertaken by migrant workers:
Were migrant workers recruited through an agency?
If yes, is there a contract with the agency?
Provide details of agencies and contractual
arrangements
Percentage of migrant workers in company provided
accommodation:
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Total
Woolworths Group Quality Technical Services:
Ethical Audit
Wages Analysis
Sample size:
(number of wages checked and which weeks or months)
Legal minimum wage for standard time:
(excluding OT - please include time period e.g.
hour/week/month)
If yes, please give details:
Are there different legal minimum wage grades?
Where there are different legal minimum wage grades are
all workers graded correctly?
If no, please give details:
What deductions are required by law:
Have all of these deductions been made?
Industry norm for this region:
(please include time period e.g. hour/week/month)
Legal overtime premium for weekdays:
(please include time period e.g. hour/week/month)
Legal overtime premium for rest days:
(please include time period e.g. hour/week/month)
Legal overtime premium for holidays:
(please include time period e.g. hour/week/month)
Worker Type
Process Operator
(Highest paid)
Process Operator
(Average paid)
Process Operator
(Lowest paid)
Select one worker’s records from each “Worker Type” and populate the boxes.
Ensure comparison is made for same pay period (peak) and only uses full-time workers.
Pay period
(please include time period e.g.
hour/week/month):
Anonymous Employee Reference/Dept.
Employee Gender
Contracted wage
(please include time period e.g.
hour/week/month):
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Woolworths Group Quality Technical Services:
Ethical Audit
Standard working hours (excluding OT - please
include time period e.g. hour/week/month):
Standard work pay rate (excluding OT - please
include time period e.g. hour/week/month):
Standard day overtime – hours (please include
time period e.g. hour/week/month):
Standard day overtime – wage (please include
time period e.g. hour/week/month):
Rest day overtime – hours (please include time
period e.g. hour/week/month):
Rest day overtime – wage (please include time
period e.g. hour/week/month):
Statutory Holiday overtime – hours (please
include time period e.g. hour/week/month):
Statutory holiday OT - wages (please include time
period e.g. hour/week/month):
Total overtime hours (please include time period
e.g. hour/week/month):
Incentives/Bonus/Allowances etc. (please include
time period e.g. hour/week/month):
Gross wages (please include time period e.g.
hour/week/month):
Social insurance and other deductions
Actual wage paid after 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)
Is there a defined living wage:
This is not normally legal wage. If answered ‟Yes‟ please
state amount and source of info:
Yes/No
Please specify amount/time period:
Are workers paid in a timely manner in line with local
law?
Yes/No
Is there evidence that equal rates are being paid for
equal work?
Yes/No
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How are workers paid: (explain payment method)
Actual overtime premium paid in sample for…
V: Weekdays:
W: Rest days:
X: Holidays:
Working Hours Analysis
Please include time period e.g. hour/week/month
What timekeeping systems are used: time card etc.
Sample size checked (number of workers):
Legal standard work week (hours):
(Excluding OT - please include time period e.g. hour/week/month).
Contracted standard work week this site (hours)
(excluding OT - please include time period e.g. hour/week/month):
Actual standard work week averaged over sample for
full time workers:
(excluding OT - please include time period e.g. hour/week/month)
Lowest standard hours worked
(excluding OT - please include time period e.g. hour/week/month)
Highest standard hours worked (excluding OT - please
include time period e.g. hour/week/month)
Percentage workers on part-time contracts
___ % age
Legal permitted overtime hours (please include time period
e.g. hour/week/month)
Any local waivers or permission for annualised hours
for this site:
Actual overtime hours:
(averaged over sample) (please include time period e.g.
hour/week/month)
Range of overtime hours over all workers:
(quote highest and lowest please include time period e.g.
hour/week/month)
Approx % of workers on highest overtime hours:
___ %
Peak season(s):
Months
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Subcontracting / Home Working
Summary of sub-contracting – if applicable
Number & Names of sub-contractors/agents used
Is there a site policy on sub-contracting?
If yes, summarise details:
Yes/No
What checks are in place to ensure no child labour is being used and work is safe?
Can the facility provide documentation demonstrating Woolworths‟ approval of a sun-contracted process related to
the manufacture of Woolworths Ltd goods?
What processes are sub-contracted?
Is the supplier making periodic checks of their sub-contractors to ensure the conditions of work and employment
comply with Woolworths Ethical policy
Summary of home working – if applicable
Male:
Female:
Total:
Number of home workers
Are home workers employed direct or through agents?
Directly/ Through Agents
If through agents, number of agents
Is there a site policy on home working?
Yes/No
How does site ensure worker hours and pay meet local laws for home
workers?
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What processes are carried out by home workers?
Are written agreements in place for home workers that include regular
employment?
Yes/No
Are full records available at the site?
Yes/No
Worker Interview Summary
Were workers aware of the audit?
Yes/No
Number of group interviews:
Please specify number and size of groups.
Number of individual interviews
Number of interviewed workers
Interviews were done in private and the confidentiality of the
interview process was communicated to the workers?
Male:
Female:
Male:
Female:
Yes/No
Was a Union or worker s‟ representative included in an interview?
In general, what was the attitude of the workers towards their
workplace?
Favourable / Non-favourable/ Indifferent
What was the most common worker complaint?
Do workers have any concerns around their personal safety at work?
What did the workers like the most about working at this site?
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Any additional comment(s) regarding interviews:
Agency Workers
(workers sourced from a local agent who are not directly paid by the site)
Number of agencies used :
And names if available:
Were agency workers‟ age/pay/hours included within scope of this
audit
Ethical Audit Checklist
1
Bribery & Corruption
1.1
Does the management of the factory understand
the applicable local legal requirements on bribery
and how do they comply with these requirements?
1.2
Does the factory have an anti-corruption or antibribery written policy or code?
1.3
If so, is there appropriate training for employees
who may encounter bribes being offered to them
due to the nature of their dealings?
1.4
Does the factory have confidential
communications channels for employees to report
incidents of bribery and corruption?
2
Labour Rights
2.1
Are workers issued with a written copy of their
contract in an understandable format (ie
language)?
2.2
Is a copy of the Woolworths Ethical Policy
available on site? Is the content communicated to
the employees?
2.3
CNC
Does the factory use forced, bonded or
involuntary labour?
Yes / No
/ NA
Comments / Details
Yes / No
/ NA
Comments / Details
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2.4
CNC
Are workers forced to lodge unreasonable
deposits or their identity papers and/or
passports with their employer? (Unless
required by local law)
2.5
Are workers allowed to leave their employer after
reasonable notice is given?
3
Freedom of Association
3.1
Do workers have the right to collectively bargain in
unions or groupings of their choosing (Where
applicable)?
3.2
Are there any independent unions in the factory?
3.3
Has there been any opposition to the set up of
employee representation from management or
workers?
3.4
Are workers‟ representatives elected by the
workers freely without influence or interference
from management?
3.5
Has there been any system set up by the
company to allow proper dialogue between
workers and employers in the field of OH&S,
housing, food facilities, disciplinary practices,
training, etc.?
3.6
Do workers representatives have access to the
workplace in order to carry out their representative
functions, in accordance with International Labour
Standards?
3.7
Where the right to freedom of association and
collective bargaining is restricted under law, does
the employer facilitate and does not hinder the
development of parallel means for independent
and free association and bargaining?
4
Working Conditions
4.1
Do policies exist that restrict smoking to
designated areas? i.e. outdoors, away from
buildings, & exit doors & not located in the vicinity
of dangerous/ hazardous good?
(In line with country specific legislation)
4.2
Is the factory regularly assessed for pest control?
4.3
Are documented cleaning procedures in place and
maintained?
4.4
Do workers have access to clean drinking water?
4.5
Are the number of toilets and washing facilities
suitable for the number of workers (according to
Yes / No
/ NA
Yes / No
/ NA
Comments / Details
Comments / Details
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Ethical Audit
local labour laws)?
4.6
Are all areas in the factory, including workshops,
accommodation, canteen, toilets and washing
facilities clean and hygienic?
4.7
Does the kitchen have a hygiene permit?
4.8
Do all food operators have health certificates?
4.9
CNC
If provided, is accommodation clearly
segregated from the factory / production area
and any material storage areas?
4.10
Is the floor space per worker in each dormitory
room adequate (according to local labour laws)?
4.11
Are sleeping rooms / quarters segregated by
gender (where applicable)?
4.12
If provided, do any of the worker‟s children live at
the facility‟s accommodation?
4.13
If worker‟s children live at the facility‟s
accommodation, are appropriate arrangements
made for the children‟s safety e.g. segregation
from the factory area and access to schooling?
4.14
Are recreational facilities provided?
5
Child Labour
5.1
Does the factory have a „No Child Labour‟ policy?
5.2
Are adequate procedures in place to verify the
age of workers?
5.3
CNC
Does the factory employ children below the
age of 15, or the minimum age allowed for
completing compulsory schooling, if so then
is the employment in line with ILO directives?
5.4
What is the age of the youngest worker in the
factory?
5.5
State the national / local legal minimum age
5.6
If any child worker is found, are there policies and
programmes in place to provide for the safe
transition from work to go back to education until
no longer a child?
6
Living Wages
6.1
Are the wages and benefits paid in line with the
Yes / No
/ NA
Comments / Details
Yes / No
/ NA
Comments / Details
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Ethical Audit
industry benchmark and / local standards?
Whichever is higher?
6.2
State the industry benchmark or local standard
wage
6.3
Describe how and when workers are paid
6.4
Describe any deductions made from wages
6.5
Are all wage deductions clearly understood and
reasonable in the context of the total wage?
6.6
Describe any non-financial benefits provided to
workers e.g. medical care, pensions, food, etc.
6.7
Are overtime rates higher than regular shift rates
and calculated pursuant to law?
6.8
For each pay period, does the employer provide
workers with an understandable wage statement,
which includes days worked, wage or piece rate
earned per day, hours of overtime at each
specified rate, bonuses, allowances and legal or
contractual deductions?
6.9
Are there inconsistencies between production
records and employee timesheets or pay slips, in
terms of pay rates, hours worked etc?
7
Working hours
7.1
Give details of national / local laws that exist to
control working hours.
7.2
Do normal working hours (excluding breaks and
overtime) meet the local requirements?
7.3
Are effective procedures in place to record
working hours for all types of workers?
7.4
Is overtime voluntary?
7.5
On average, are workers allocated at least 1 day
off in every 7 days? Or where allowed by national
law 2 days off in every 14 days period?
7.6
Is overtime paid at the legal overtime rate or
higher?
7.7
Are workers allocated breaks during the working
day whose duration and frequency is appropriate
for the tasks undertaken?
7.8
Are workers required to work in excess of local
law requirements for overtime on a regular basis?
7.9
Are there any specific workers who work
excessive amounts of overtime?
8
Discrimination
Yes / No
/ NA
Comments / Details
Yes / No
Comments / Details
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Ethical Audit
/ NA
8.1
Can the factory provide evidence that there is no
discrimination on any grounds in the hiring,
compensation, access to training, promotion,
termination or retirement of workers or in the
conditions of their employment?
8.2
Do valid records and reasons justify recent
company dismissals?
9
Regular Employment
9.1
Are workers offered regular, continuous
employment?
9.2
Is contracting, sub-contracting, home working
arrangements or apprenticeship schemes used in
no real intent to impart skills or provide regular
employment?
10
Harsh or Inhumane
Treatment
10.1
Are there fair and reasonable disciplinary
procedures currently in place within the factory?
10.2
Are rules documented and clearly communicated
to workers? Describe these rules and the
disciplinary action when broken.
10.3
CNC
Are workers subjected to physical abuse or
discipline, the threat of physical abuse, sexual
abuse, verbal abuse or any other form of
intimidation?
11
Entitlement to Work &
Immigration
11.1
Do all employees (including agency staff) have
the legal right to work in the facility?
11.2
Are employees‟ documents validated upon
employment by reviewing original documents (i.e.
birth certificates, working visas etc.)?
11.3
Is there an employment process in place?
11.4
When labour hire agencies are used, is there an
periodic verification that the agencies abide by
their obligations as employer?
Yes / No
/ NA
Yes / No
/ NA
Yes / No
/ NA
Comments / Details
Comments / Details
Comments / Details
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Ethical Audit
11.5
If labour hire agencies are used, is the
engagement under a written contract clearly
stating the labour hire agencies obligations in
relation to labour rights, wages and working
conditions?
12
Subcontracting & Home
Working
12.1
Are subcontractors, home workers or cottage
units used at any point in the supply chain?
12.2
Has the use of subcontractors, home workers or
cottage units been previously agreed with
Woolworths Limited?
12.3
Does the factory has a process to check the
conditions of employment of all subcontractors
(i.e. working conditions, living wages, working
hours etc.), including home workers and cottage
industry workers?
13
Health & Safety
13.1
Can the factory demonstrate that training is
provided for workers in safe handling methods of
hazardous chemicals / materials (Inc. restricted
access) and in the safe use of machinery for new
and reassigned workers?
13.2
Does the factory store its hazardous chemicals
and flammables adequately? (sealed containers,
no leakage, locked store rooms, separate from
living and working quarters, bonded to stop spills
spreading, properly ventilated)
13.3
Are material safety data sheets maintained where
appropriate?
13.4
Is there evidence of the use of necessary
personal protective equipment (PPE)? Describe
the PPE that is supplied to workers free of
charge?
13.5
Is adequate ventilation provided for dust and
fumes?
13.6
CNC
Are all aisles, corridors and exits clearly
marked and free of obstruction across all
areas of production, warehousing/storage,
accommodation and meal preparation and
dining areas?
13.7
Are machines fitted with adequate guards to
safely reduce the risk to workers?
13.8
Does the factory have procedures for safe use of
Yes / No
/ NA
Yes / No
/ NA
Comments / Details
Comments / Details
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all machinery?
13.9
CNC
13.10
CNC
a) Are fire alarms available in all areas of
the facility including production,
warehousing, accommodation areas of
meal preparation?
b) Do fire alarms meet relevant legislative
requirements (where applicable)?
Is fire fighting equipment available?
a) Is the equipment available in all areas
within the facility including production,
warehousing, accommodation, areas of
meal preparation?
b) Is fire fighting equipment accessible for
use when needed?
c) Does the equipment provided cover all
the different potential fire types? (E.g
Chemical, Electrical)
d) State the type of equipment used
13.11
CNC
Is equipment tested in accordance with
legislative requirements (where applicable) to
ensure functionality?
Record dates of testing reviewed
Where legislation in absent refer to
recommendations by the manufacturer.
13.12
CNC
a) Are fire / evacuation drills conducted
in line with legislative requirements
(where applicable) and inclusive of all
administration, production,
warehousing, accommodation, meal
preparation and dining areas?
b) Are fire/evacuation drills records and
outcomes assessed?
13.13
Is the level of lighting, heating and cooling in the
factory adequate for local conditions?
13.14
Are adequate first aid facilities available on site?
13.15
Are trained first aid personnel available in the
factory all times during production?
13.16
Is an accident log kept?
13.17
Is there a clear Health and Safety Policy?
13.18
Is there a Health and Safety Committee with a
senior management representative?
13.19
Are all fire exits clearly marked in a language that
workers can understand or that is shown
graphically?
13.20
CNC
Does the number of exits (per building
structure & per floor) meet legislative
requirements?
Guidance: The fire exits/ escape routes must
provide for safe evacuation from each floor of the
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factory, warehouse, meal preparation & dining
areas or accommodation.
The auditor shall walk all escape routes to ensure
safe evacuation in the case of fire in lower floors
of the factory. For example, is there a safe route
th
from the 4 floor to the ground floor if there is a
fire on the ground floor?
13.21
CNC
Are there evacuation plans available for all
areas of the facility, including administration
production, accommodation, warehousing,
meal preparation and dining areas?
Ensure the evaluation plans are documented,
displayed in each area, and available in
diagrammatical format considering all languages
spoken (read) on site.
13.22
CNC
Are workers trained in the use of fire fighting
equipment and in the application of factory
evacuation procedures?
13.23
Has an occupational health examination taken
place for all applicable workers?
13.24
Are all internal and external doors easy to open
and free moving?
13.25
Does every facility have a responsible Safety
Manager as the first point of contact? If so; Is this
safety manager easily approachable by workers?
Is there open communication?
13.26
Is there an emergency preparedness (plan) to
prevent / minimise a catastrophe for each facility?
13.27
Are the workers covered by insurance for health
and life in line with country requirements?
14
Building Structure & Safety
14.1
Is there a Building & Fire Safety Audit in place for
each facility? If so at what frequency?
14.2
Does the factory have any building structural
integrity certification in place from local
jurisdictions?
14.3
Does the factory/facility have a building safety and
fire safety licence/permit?
Please provide a current/valid copy.
14.4
Does the factory internal audit identify corrective
actions including risk management identifying
proposed controls within an agreed time frame?
14.5
Is there a specific person accountable for
conducting auditing of each facility?
14.6
Is the facility located in a flood plane? If so are
appropriate safety preventions in place?
Yes / No
/ NA
Comments / Details
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14.7
CNC
Do building inspection records meet the
applicable local/national regulatory
requirements with regards to build structure
or safety?
15
Environmental Standards
15.1
Does the factory require either local or national
regulatory approval for manufacture?
15.2
Does the factory have an environmental policy?
15.3
Does the factory have an environmental action
plan?
15.4
Does the plan monitor progress?
15.5
Does the environmental action plan cover
implemented controls to minimize the impacts on
the environment for:
Yes / No
/ N/A
Comments / Details
 solid waste disposal?
 hazardous chemicals storage / management?
 air and water emissions?
15.6
Does the factory require an environmental
license?
If so does it have one?
Can the factory demonstrate compliance with its
environmental license conditions?
15.7
Has the factory operated for the past 3 years
without prosecution under environmental
legislation?
15.8
Is there evidence of local pollution from the
factory?
15.9
Does the factory knowingly and continually
contravene local and national environmental
legislation?
15.10
Do building inspection records meet the
applicable regulatory requirements with regards to
Environmental Protection?
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Corrective Action Plan
Clause
Clause
Grading
Action Required
Evidence Required for
closure
Close
Out Date
Status
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Factory Photos
Description: PRODUCT SUPPLIED TO WOOLWORTHS
LTD OR PRODUCT MANUFACTURED AT THIS SITE
Description:
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