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