Example of guidelines for taking remedial action

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Template: Example of guidelines for taking remedial action:
Critical failure points and non-compliance
This document provides an example of guidelines that an organisation may establish to inform the interpretation of audit reports
and findings, as well as responses to some of the most common issues found. The document has been derived from approaches
applied by procurement organisations.
Critical issues:
For the majority of the critical issues that are listed, if they were found in a prospective supplier’s supply chain, the organisation
would expect the corrective action to take place before a trading relationship was established. Critical issues are assessed to be
fundamental and where they exist, pose significant financial and reputational risks to the supply chain and procurers.
If the report relates to the supply chain of an existing supplier to the organisation, the corrective action should generally occur within
the timeframe indicated (subject to mitigating circumstances). Engagement and progress are what is required, so whilst the issue
may still be present for some of the critical issues, the supplier should not be penalised if they are genuinely working towards
improvements. For the issues that have an immediate timeframe, it is assessed that the issue will be relatively easy to solve and
the procuring organisation should expect this timeframe to be met, however remedial actions and timeframes should always be
agreed by all parties and be realistic and proportionate.
Measure ETI Base Code
Finding
Corrective action
Time frame
Employment is
Unpaid, forced, bonded
Ensure all workers are able to leave employment
Immediate
freely chosen
or trafficked labour
and return any deposits or other money withheld.
Employment is
Original IDs held
Return all original IDs to workers, keeping only a
section
Critical
Critical
freely chosen
Immediate
copy on file. Ensure all workers are able to leave
employment
Critical
Critical
Employment is
Workers fined for not
Ensure that all workers are able to refuse to work
Immediate – three
freely chosen
working overtime
overtime. Workers must not be fined for not
months – removal of
working over their standard hours. Steps must be
fines and significant
taken to reduce the reliance on overtime, even
improvements re:
during busy periods
reliance on overtime.
Ensure that all workers are working of their own
Immediate
Employment is
Prison labour found
freely chosen
free will. This is especially important in China. No
workers on site should be serving any form of
custodial sentence
Critical
Health and safety
Dangerous storage of
Development of safe system of storage – away
Three months –
production materials
from production sites and accommodation
significant
improvement
Critical
Health and safety
Locked fire exits
Ensure all fire exits are unlocked at all times when
workers are on site. This should also be true of fire
Immediate
exits in accommodation.
Critical
Health and safety
Only 1 feasible and
Ensure that more than one fire exit is available and
three months –
useable fire exit
useable for each floor of the production site. This
significant
should also be true of fire exits in accommodation.
improvement –
working towards
structural changes
Critical
Health and safety
Machinery poses a risk
Ensure that all machinery is safely operated and
Three months –
to the lives and/or limbs
regularly maintained and cleaned, and that all
significant
of those working with or
moving parts have guards to protect workers.
improvement – no
around them
Where appropriate, machinery should be 2 button
further risk to life or
operated and have a working emergency stop
limb, and guards in
button
place. Operation and
emergency stop
buttons in progress
Critical
Health and safety
Pregnant and
Pregnant or breastfeeding workers to be removed
breastfeeding workers
from dangerous or hazardous work areas and
doing dangerous or
given work in areas which do not risk health and
hazardous work
well being of the mother or the child. Away from
Immediate
heat, chemicals, dangerous machinery etc.
Critical
Health and safety
Premises are not
Structural changes made following local law and
structurally safe
regulations. Consultation made on completing
Six months
structural work on entire site, and work completed
on ensuring immediate risk is resolved.
Critical
Health and safety
Accident compensation
Workers should be provided with accident
Three months – all
compensation if they are involved in a workplace
workers should be
incident or contract a work-related illness. All
covered by state
workers should be covered by any necessary state
insurance scheme
insurance for the provision of such compensation.
and accident
compensation paid in
all entitled cases.
Critical
Critical
Child labour
Working hours
Children found working
Confirm age and name of all children found.
Immediate – three
at production site
Children removed from work and full remediation
months – all
plan initiated. Children to be entered into school
confirmed children
and wages paid to ensure that they have financial
included in
security to remain. No further recruitment of
remediation work. No
children and robust age verification system to be
further recruitment of
installed.
children
Workers working over
Initiate work to improve productivity and production
Three months –
350 hours per month
planning to ensure that the number of working
movement towards
hours is reduced. Ensure that all workers have 1
legally compliant
day off per week. Ensure that workers’ pay is not
hours. Engagement
reduced with the decrease in working hours
in improvement
programme to reduce
hours
Critical
Critical
Working hours
Discrimination
Workers to be provided with at least one day off
Three months –
(full period of 24 hours rest) every week. Linked to
movement towards
work on productivity and production planning –
provision of rest day.
production should not be planned over 7 day week,
Engagement in
but over 6 day week to allow workers to have day
improvement
of rest.
programme.
Pregnancy testing used
End the use of pregnancy testing as part of the
Immediate
for recruitment
recruitment process. Workers to be employed
1 day off per week
based on merit, and not pregnancy status
Critical
Discrimination
Jobs unavailable to
Ensure that workers are permitted to return to work
Three months – all
workers after maternity
when they return from maternity or paternity leave.
workers able to return
leave
Workers should be able to return to the role that
to work. Production
they were in when they went on leave. Any cover
site should have
for this role while they are on leave should be
written policy on
temporary by agreement.
maternity leave which
is followed.
Critical
Harsh or inhumane Workers being
End use of physical violence and/or punishment of
treatment
workers.
physically abused
Immediate
Major issues
Major issues are assessed to be important areas for remedial action and pose financial and reputational risks to the supply chain
and procurers. While important, it may be that remedial actions can be taken over a longer timeframe than Critical Issues.
For suppliers (and their supply chains) that do not yet have a trading relationship with the organisation, ‘Major’ issues should not
normally prevent a relationship being established. However, if the production site does not demonstrate effective improvements on
the issues raised, within the timeframes agreed, there would be cause to review or terminate any contractual agreement.
If the report relates to the supply chain of an existing supplier to the organisation, the corrective action should generally occur within
the timeframe indicated (subject to mitigating circumstances). Engagement and progress are what is required, so whilst the issue
may still be present for some of the critical issues, the supplier should not be penalised if they are genuinely working towards
improvements. For the issues that have an immediate timeframe, it is assessed that the issue will be relatively easy to solve and
the procuring organisation should expect this timeframe to be met, however remedial actions and timeframes should always be
agreed by all parties and be realistic and proportionate.
Measure ETI Base Code
Finding
Corrective action
Time frame
Employment is
Workers paying
Ensure all workers are able to leave employment
One month
freely chosen
deposits
and return any deposits or other money withheld.
Employment is
Workers not being paid
Ensure that all workers are paid their final salary
freely chosen
their final salary when
when they have left the production site. This
leaving
should be paid at the normal time, and should
Section
Major
Major
One month
include payment for all hours worked, including
overtime.
Major
Employment is
Significant limitation on
Ensure that all workers are allowed to move freely
freely chosen
workers’ freedom of
around the site, within the bounds of safety, and
movement (i.e. gate
are able to leave the site at any time.
One month
passes, toilet cards,
aggressive prevention
of movement,
intimidation)
Major
Freedom of
Workers unable to
Ensure that all workers have free and fair access
Three months –
association
unionise
to trade unions and are able to join if they so wish.
progress made and
any significant
preventative
measures halted
Major
Major
Major
Freedom of
No means for workers
Ensure that workers are able to freely
Three months –
association
to communicate with
communicate with management. This may involve
progress made and
management
the installation of a suggestion box, or the
timeline in place for
formation of a workers committee.
continued work
Freedom of
Workers penalised for
Stop all fines immediately. Ensure that all
Immediate – all fines
association
union or other
penalising measures are stopped and historical
stopped
representational
ones overturned where possible. Ensure that
Three months –
memberships
workers have free and fair access to
significant progress
representational measures inside and outside the
made on historical
production site
issues and access
Chemicals – unsafe
Ensure workers and management are aware of
One month – training
handling of chemicals
safety issues for all chemicals and MSDS sheets
and awareness
are provided. All chemicals should be stored and
raising completed,
handled in accordance with the safety guidelines.
and all workers safely
PPE must be provided and worn in accordance
handling chemicals
Health and safety
with guidelines.
Major
Health and safety
Chemicals – unsafe
Ensure workers and management are aware of
One month – training
use of chemicals
safety issues for all chemicals and MSDS sheets
and awareness
are provided. All chemicals should be stored and
raising completed, all
handled in accordance with the safety guidelines.
workers safely using
PPE must be provided and worn in accordance
chemicals
with guidelines.
Major
Health and safety
PPE – workers do not
PPE to be provided and management to actively
One month – training
have the correct PPE
encourage its use at all times. Training to be given
given and significant
for the work and
to workers to educate them about risks posed by
improvements in the
chemicals and
chemicals and machinery, and the benefits of PPE
use of PPE.
Fire – inadequate
Ensure that all emergency lighting is functioning
Three months
lighting
and workers are able to safely evacuate the site
machines that they are
using
Major
Health and safety
during an emergency.
Major
Major
Major
Health and safety
Health and safety
Health and safety
Fire – escape routes
Ensure that all escape routes on the site are clear
are not clear
from any obstruction, including work in progress.
Fire – inadequate
All fire fighting equipment must be adequate for the One month
numbers or types of fire
risks present, well maintained and be sufficient in
fighting equipment
number in all areas of the site.
Fire – no or inaudible
Ensure that a fire alarm is in place which can be
Two months – if
fire alarm
activated and is audible in all areas of the site.
installation of an
Activation points should be clearly marked and
alarm is required
workers should be aware of what the alarm sounds
One month – if
like
improvements are
One month
required
Major
Health and safety
Housekeeping – toilets
All toilets should be regularly cleaned and
are not hygienic
maintained, with free access to clean water, soap
One month
and hand drying facilities at all times
Major
Health and safety
Housekeeping –
Ensure that all food storage areas and hygienic,
canteen and/or food
and that workers have a place to hygienically store
storage not hygienic
food should they bring it in. Canteens should have
One month
legally compliant facilities for cooking and storing
food
Major
Health and safety
Housekeeping – no
Workers to have access to potable water in all
access to potable water
areas of the site (where it is safe to do so).
Immediate
Workers must be free to drink water at any time.
Major
Major
Health and safety
Health and safety
Machinery – Guards on
All machines must have guards to prevent workers
machines missing or
from being injured – all moving parts must be
damaged
guarded.
First Aid – Boxes not
Ensure that all first aid boxes are unlocked and
freely accessible
workers are able to access them when required
One month
One month
(this may be via a trained first aider). All boxes to
be fully stocked with hygienic and in-date items
Major
Health and safety
First aid – no or limited
Workers to have access to timely medical attention
access to medical
when required, either via a trained medic on site,
attention when required
or an arrangement with a local clinic
One month
Major
Children and
Young workers
A list of young workers to be compiled and
young workers
engaged in hazardous
compared with job roles and hazardous working
work
areas. All young workers to be removed from
One month
hazardous work, and hazardous working
environments.
Major
Children and
Inadequate age
All workers to have their age verified before
young workers
verification checks
starting work at the production site. An age
Three months
verification policy to be established, and enforced.
No worker below the legal minimum working age
should be employed, and where there are doubts
more extensive checks to be carried out (i.e.
medical)
Major
Wages
Failure to pay minimum
Workers to be paid more, working up to the legal
Three months –
wage
minimum wage where this is a significant
action plan in place
improvement on the current wage, as a result of
and initial steps being
improvement work in productivity and profitability.
taken.
Work must focus on allowing workers to benefit
from improvements
Major
Wages
No legal overtime
Workers to be paid legal overtime premiums as a
Three months –
premium paid
result of improvement work on productivity and
action plan in place
profitability. Staggered improvements working
and initial steps being
towards the legal premium should be in place
taken
where it requires significant improvements.
Major
Major
Wages
Working hours
Workers to be paid their full wage on time, to
Three months –
ensure regular and reliable income. Work to
action plan in place
improve production planning and productivity
and initial steps being
should result in improvements with regular pay.
taken
Working hours exceed
Working hours to be gradually reduced to bring
Three months –
250 hours per month
them into line with the legal maximum. This to be
action plan in place
done in conjunction with improvements in
and initial steps being
productivity and profitability to ensure that workers
taken
Late payment of wages
are not paid less
Major
Working hours
Compulsory overtime
Workers to be allowed to say no to overtime.
Three months –
Improvements in productivity and production
action plan in place
planning to be initiated to ensure that production is
and initial steps being
planned over regular hours and overtime is not
taken
required as often.
Major
Working hours
Workers not given one
Improvements in productivity and production
Three months –
day off per week
planning to be initiated to ensure that workers are
action plan in place
able to take one day off per week. Production to be
and initial steps being
planned over a regular working week of no more
taken
than 6 days.
Major
Harsh or inhumane Workers being shouted
Ensure that workers are not shouted at or verbally
Six months – where
treatment
abused by supervisors, or any other member of
significant issues are
production site staff. All workers should feel safe
present
and comfortable at work
Three months –
at or verbally abused
where issues are
more straightforward
Major
Major
Harsh or inhumane Workers are fined for
Ensure that any fines that are used as a
Three months – fines
treatment
disciplinary measure are phased out in favour of a
stopped and
more incentivised system. All inappropriate
incentives being
deductions to be stopped
developed
Three months
making mistakes
Regular
No contracts given to
All workers to be given contracts which have been
employment
workers
explained and understood. Workers to be given a
copy of the contract.
Major
Accommodation
Inadequate living space
Workers to be given adequate and legally
Six months – where
compliant living space. Accommodation should be
structural changes
spacious and hygienic. Couples should be housed
are required
in their own private rooms, and wherever required
Three months –
family accommodation should be provided.
where re-allocation is
required
Major
Accommodation
Unhygienic living
All accommodation to be regularly cleaned and
conditions
maintained to ensure that it is hygienic and clean
One month
Major
Accommodation
Inadequate hygiene
All accommodation to have appropriate hygiene
Six months – where
facilities
facilities, separated by gender. All hygiene facilities
structural changes
to be regularly cleaned and maintained.
are required
One month – where
maintenance is
required
Major
Accommodation
No separate cooking
Cooking facilities to be separate from living areas
Six months – where
facilities
where they are required.
structural changes
are required
Three months –
where re-allocation is
required
Major
Accommodation
Inadequate emergency
All accommodation areas to be installed with
Three months –
lighting
working and well maintained emergency lighting.
where installation is
All escape routes to be fully lit and visible to
required
workers during an emergency.
One month – where
maintenance is
required
Major
Accommodation
Inadequate fire fighting
All fire fighting equipment must be adequate for the One month
equipment
risks present, well maintained and be sufficient in
number in all areas of accommodation.
Major
Accommodation
No or inaudible fire
Ensure that a fire alarm is in place which can be
Two months – if
alarm
activated and is audible in all areas of
installation of an
accommodation. Activation points should be clearly alarm is required
marked and workers should be aware of what the
One month – if
alarm sounds like
improvements are
required
Major
Subcontracting
Work subcontracted to
All production sites involved in the manufacture of
Six months – supply
other production site
The organisation Group products should be
chain information
without notification to
disclosed to The organisation Group and involved
provided for all
The organisation
in the ethical sourcing programme. Visibility of
regular and sporadic
Group.
supply for all products and suppliers should be
production sites. Any
assured and maintained.
subcontracting
disclosed to The
organisation Group.
Concerns
Concerns relate to identified areas for remedial action which need to be addressed as part of any improvement programme.
Concerns are assessed to pose moderate financial and reputational risks to the supply chain and procurers.
For suppliers (and their supply chains) that do not yet have a trading relationship with the organisation, concerns should not
normally prevent a relationship being established. However, if the production site does not demonstrate effective improvements on
the concerns raised, within the timeframes agreed, there would be cause to review or terminate any contractual agreement.
If the report relates to the supply chain of an existing supplier to the organisation, the corrective action should generally occur within
the timeframe indicated (subject to mitigating circumstances). Engagement and progress are what is required, so whilst the issue
may still be present for some of the critical issues, the supplier should not be penalised if they are genuinely working towards
improvements. For the issues that have an immediate timeframe, it is assessed that the issue will be relatively easy to solve and
the procuring organisation should expect this timeframe to be met, however remedial actions and timeframes should always be
agreed by all parties and be realistic and proportionate.
Measure ETI Base Code
Findings
Corrective action
Time frame
Security guards control
Ensure that security guards are not preventing
Three months
workforce
people from leaving. Provide training and
Section
Concern Employment is
freely chosen
information to them on job responsibilities and how
to address workers.
Concern Employment is
freely chosen
Unreasonable
Ensure that residents of the company dormitory
restrictions on the
are permitted to move about the premises, and the
movement of dormitory
only restrictions on their movement are necessary
residents.
for their safety or the safety of other residents. Post
Three months
security requirements on notice boards so that
workers are aware of them.
Concern Employment is
freely chosen
Unreasonable notice
Make sure that workers are allowed to leave
requirements or
employment without penalty provided they have
financial penalties for
given the legally required notice. Any financial
leaving
penalties should be removed, and the company
Six months
should ensure that workers are not restricted from
giving notice.
Concern Employment is
freely chosen
Delaying payments to
Ensure that all workers are given their full final
workers when they
payment should they leave the production site. Any
leave
workers who are due money since leaving the
Three months
production site should be paid as soon as possible.
Concern Employment is
freely chosen
Restricted toilet or rest
Phase out and stop the use of toilet cards or any
breaks
other restrictions on workers going to the toilet.
Three months
Ensure that workers are given the legally required
rest breaks, during the working day and are free to
go to the toilet at any time.
Concern Employment is
freely chosen
Use of ‘extended’
Ensure that no worker has their probation period
probation periods
extended beyond the legal limit. Workers should be
Six months
assessed and trained sufficiently to be able to do
the job, and the probation period set to correspond
to this amount of time. Workers should not have
their probation periods extended unless absolutely
necessary and this should never go over the legal
limit.
Concern Employment is
freely chosen
No free employment
Ensure that the production site has a written policy
policy
on free employment, which sets out their standards
Three months
and requirements. This should be in compliance
with the law, and should adhere to best practice
guidelines wherever possible/reasonable.
Concern Employment is
freely chosen
Monetary deposits for
Ensure that unreasonable deposits are not taken
accommodation
and those that have been are returned to workers.
6 months
Deposits should cover the cost of likely damage to
the accommodation, although this should not
include general wear and tear. Workers should
have deposits returned to them when they leave
employment, with only reasonable amounts taken
from them to cover any unreasonable damage that
they have caused.
Concern Freedom of
association
Inadequate facilities for
Ensure that unions have access to adequate
union activities
facilities in order to be able to speak to and
Three months
represent workers. This may include office facilities
and/or time with the workforce
Concern Freedom of
association
Worker representatives
Ensure that all worker representatives are given
not given time off for
adequate time off in order to conduct meetings and
activities
address issues in the workplace. Ideally this should
Six months.
be paid time off.
Concern Freedom of
association
Workers unaware of
Make sure that there is an effective system in
how to raise issues with
place for workers to raise issues with the
management/unaware
management, and that workers are aware of the
of who their reps are.
system and how it works. Inform workers of who
Six months
their reps are.
Concern Freedom of
Collective agreements
Ensure that all collective agreements meet at least
Six months
association
fail to comply with local
minimum legal standards. Ideally a collective
law
agreement should go over and above the minimum
legal requirements.
Concern Freedom of
association
Concern Freedom of
association
Concern Freedom of
association
Company does not
Ensure that collective agreements are in writing,
comply with collective
and that the company complies with their
agreements or
requirements. Collective agreements are legally
agreement is not in
binding on all parties, and should be followed as
writing.
such.
Penalising or
Ensure that the company does not penalise or
discriminating (directly
discriminate against union members or
or indirectly) against
union/worker reps. This may involve training and
union members, union
interactive work to educate management about the
reps or worker reps.
value of worker representation.
No parallel means for
Make sure that there is an effective system in
workers to raise issues
place for workers to raise issues with the
with management
management, and that workers are aware of the
Six months
Nine months
Six months
system and how it works.
Concern Freedom of
association
No records kept of
Ensure that all meetings between management
union or worker rep
and union/worker reps are minuted, and that these
meetings with
minutes are kept on file and circulated amongst the
management
workforce.
Three months
Concern Freedom of
Employer interferes
Ensure that management/employer is removed
association
with union decision
from the decision making and election process for
making or the election
unions.
Six months
of representatives
Concern Freedom of
Lack of regular
Ensure that all union/worker reps are
elections for
democratically elected at least every 2 years.
worker/union reps.
Ideally this should occur every year.
Concern Freedom of
Representative body
Ensure that worker reps or the union are equipped
association
does not discuss key
and able to discuss workplace issues, and raise
issues.
this with management. Representative body should
association
Nine months
Nine months
not just discuss social issues, but should cover
issues such as H&S, hours and pay.
Concern Health and safety
Electrical wiring
Ensure that all wiring is safely secured and no
exposed/inadequately
wiring is exposed or frayed.
One month
secured
Concern Health and safety
Failure to comply with
Ensure that the workplace has the required
requirements of safety
certification for all electrical appliances and wiring,
inspections
as well as other legal inspection and certification
Three months
requirements such as hygiene and ventilation.
Concern Health and safety
Poor or inadequate
Ensure that lighting is improved so that workers
lighting in production or
and other staff are able to adequately see the work
Three months
other areas
on the production floor, as well as being able to
safely move around the site.
Concern Health and safety
Inadequate ventilation
Ensure that all areas of the production site are
or air conditioning
adequately ventilated or air conditioned to create a
Three months
comfortable working environment.
Concern Health and safety
Premises require minor
Ensure that all minor and major repairs undertaken
repairs
are completed, and a system is in place to monitor
Three months
repair requirements moving forward.
Concern Health and safety
Fire extinguishers not
Ensure that all fire extinguishers and other fire-
installed at correct
fighting equipment is installed to comply with legal
height/other non-
requirements and optimise ease of use.
Three months
functional requirements
not met
Concern Health and safety
Incomplete records
Ensure that all evacuations of the site, whether
from fire evacuation
drills, false alarms or actual incidents, are
drills
adequately recorded. This should include nature of
Three months
incident, number of workers on site and areas that
are operational, time taken to evacuate, resulting
work and risk assessments, and any other legally
required information.
Concern Health and safety
No records of training
Ensure that all training of fire evacuations is
Three months
for fire evacuations
recorded. This should include information such as
time spent in training, information covered, list of
attendees, and list of people absent.
Concern Health and safety
Concern Health and safety
Concern Health and safety
Concern Health and safety
Concern Health and safety
No records of fire alarm
Ensure that all fire alarm tests are recorded and
tests
any required work recorded and acted upon.
Failure to provide
Ensure that there are a sufficient number of lockers Three months
adequate or secure
or other secure storage units for workers to keep
storage for workers’
their personal effects. This may include investing in
personal effects
new storage.
Inadequate and/or
Ensure that clean and functioning sinks are
unhygienic facilities for
available in washrooms or toilets, and that
washing and/or drying
sufficient soap and hand drying facilities are
hands
provided.
No testing of water
Ensure that drinking water is tested regularly to
potability
ensure that it is potable.
Isolated failures to carry Ensure that all workers are given regular medical
out medical
checks, and that those who are working in
examinations
dangerous or hazardous situations, or working with
chemicals, are given medical examinations to
assess their exposure to risks and the effects of
that every 6 months.
One month.
Three months
One month
Three months
Concern Health and safety
Lack of appropriate
Ensure that all workers who are obliged to or likely
equipment and/or
to handle heavy loads are given manual handling
training on safe
training to ensure that they are able to do so
handling of loads
safely. Ensure that required equipment is available
Three months
and well maintained where it is necessary to safely
handle loads.
Concern Health and safety
Insufficient seating in
Ensure that there is sufficient and adequate
canteen/dining area
seating available for workers to be able to eat and
Three months
rest during breaks. May require purchasing new
furniture, or staggering rest breaks to reduce the
number of workers using the room concurrently.
Concern Children and
young workers
Concern Children and
young workers
Isolated cases where
All ID’s to be checked for all workers to verify age,
ID is not present.
and right to work status
No formal policy on
Written policy on child labour and the treatment of
child labour.
young workers to be developed, in line with legal
One month
Three months
requirements.
Concern Children and
young workers
Young workers not
All young workers to be registered with relevant
registered as per legal
authority as per local law.
Three months
requirements
Concern Children and
young workers
No risk assessments for Risk assessments carried out for each individual
young workers
young worker, taking into account their job role and
Three months
proximity to hazards.
Concern Wages
Workers are not
All workers to begin participating in all legally
participating in all
required benefits schemes.
Three months
benefits schemes
Concern Wages
Concern Wages
Disciplinary measures
All disciplinary measures to be recorded and put in
not recorded
worker’s personnel files.
Workers moved to other Workers’ hours to be recorded and paid correctly
facilities to avoid paying
regardless of which facility they are working in. All
them for overtime
hours worked for one organisation to be included in
Three months
Six months
total hour calculations and paid according to legal
or contractual requirements.
Concern Wages
Concern Working hours
Individual payroll
Payroll to include all workers’ hours and wages,
records missing or
and all aspects of pay and/or deductions. Payroll to
incomplete
be kept on file for a minimum of 3 years.
Inadequate time
All working hours to be accurately recorded and
Six months –
records
used to pay workers accurately.
significant progress
Six months
and movement
towards all records
being complete
Concern Working hours
No clear policy on
Policy on overtime working to be developed, in line
overtime working
with local law, and communicated to workforce.
Three months
Concern Working hours
Overtime exceeds 12
Records of hours and overtime to be examined to
hours per week, or
determine trends in overtime work, and actions
relevant legal limit, in
undertaken to tackle those trends. Where no
isolated cases
trends are found, monitoring to occur to ensure
Six months
that there are none in the future. Workers to be
actively discouraged from working over 12 hours of
overtime.
Concern Discrimination
Concern Discrimination
Evidence of
All workers to be treated equally in all aspects of
discrimination in one or
employment. Assessment of issues present and
more aspects of work
work done to address them. This may include
on site (i.e. training
training and capacity building for staff and
and/or promotion)
management.
Lack of transparency
Policies on all aspects of employment such as
on issues such as
recruitment, training, promotion, remuneration,
promotion, hiring,
benefits etc to be developed and communicated to
training etc
workforce. Must be in line with local law, and
Six months
Six months
strictly followed subsequent to dissemination
Concern Regular
employment
Agencies charging fees
All fees to be stopped, and assessment of agency
to workers on site
undertaken by company or commissioned
Six months
organisation to assess practices.
Concern Regular
Probationary workers or All employees to be paid an equal wage for work of
Nine months
employment
trainees not paid the
equal value, regardless of qualification levels.
same wage as
permanent or qualified
workers
Concern Regular
employment
No communication of
Working conditions and appropriate labour
standards to agencies
standards requirements to be communicated
Three months
or other sub-contractors effectively to all labour providers and
subcontractors used by the company.
Concern Regular
employment
Unclear internal rules
All internal rules and regulations to be clearly
and/or regulations
communicated to entire workforce. Information to
Three months
be included in a handbook for all new
employees/workers, and communicated to them
upon starting at the production site.
Concern Harsh or inhumane No discipline and/or
treatment
grievance procedures
Company to write policies and procedures on
Six months
discipline and grievances and communicate them
to the workforce. These must be in line with local
law and followed wherever necessary.
Concern Harsh or inhumane Discipline and/or
treatment
All discipline and/or grievance procedures to be
grievance procedures
clearly communicated to entire workforce.
not communicated to
Information to be included in a handbook for all
workforce
new employees/workers, and communicated to
Three months
them upon starting at the production site.
Concern Harsh or inhumane No documentation of
treatment
All discipline and/or grievance procedures initiated
discipline or grievance
or undertaken within the company to be accurately
procedures or reviews
recorded and kept on file.
Three months
that have been
undertaken
Concern Harsh or inhumane Management and/or
treatment
Concern Accommodation
Management and supervisors to be given training
supervisors do not
on the relevant procedures in place within the
understand/follow the
company, and performance monitored for use of
discipline and/or
the procedures. Records of the training to be kept
grievance procedures
on file.
Incomplete records of
All evacuations, be they drills, false alarms or
evacuation drills
genuine incidents, to be recorded and kept on file.
Six months
Six months
Information should include nature of incident,
number of people on site, length of time to
evacuate, any people missing or injured etc.
Concern Accommodation
Isolated failures in
Records to be kept of all maintenance
maintenance
requirements and all maintenance undertaken.
Management programme to be brought in to
ensure that no maintenance issues are missed and
not completed.
6 months
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