cap_syngenta_karnataka_hadagali_2009 by xiagong0815

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									FLA Audit Profile
Country                                                                       India
Number of Total Farms Visited                                                 25
Audit State/Province                                                          Karnataka
Independent External Monitoring Organization                                  St. John's Medical College, Bangalore
Date(s) in Farms                                                              September 29-30, 2009
FLA Affiliated Compan(ies)                                                    Syngenta
Total Number of Workers                                                       2
Total area covered under audit (Acres)                                        Over 21 Acres
Production Processes at time of IEM visit (sowing,                            Harvesting, seed removal and sorting of okra seeds
harvesting, chemical spray, hybridization or none)
Product(s)                                                                    Okra

                         FLA Code/Benchmark                                       Compliance Status        Describe noncompliance or        List sources/documentation used for Cite and describe local and/or    Describe notable features
                                                                                                           uncorroborated evidence of      reference and corroborating evidence country laws used for additional implemented by growers or
                                                                                                                 noncompliance                  (e.g. worker interviews, farms             reference                     Company
                                                                                                                                             walkthrough, records review, etc.)

1. Code Awareness
GEN 1: Establish and articulate clear, written workplace standards.           Noncompliance            The standards are not clearly       Grower and worker interviews
Formally convey those standards to Company Growers as well as to                                       conveyed to the growers and seed
Seed Organizers.                                                                                       organisers.

GEN 2: Ensure that all Company growers as well as Seed Organizers Noncompliance                        The workers are not aware of the    Grower and worker interviews
inform their workers about the workplace standards orally and through                                  workplace standards.
the posting of standards in a prominent place (in the local languages
spoken by workers) and undertake other efforts to educate workers
about the standards on a regular basis.
2. Forced Labor
There shall not be any use of forced labor, whether in the form of
bonded labor, indentured labor or prison labor or other wise.

3. Child Labor
No person will be employed at an age younger than 15 years of age
(or 14 where the law of the country allows) or younger than the age for
completing compulsory education in the country of produce where
such age is higher than 15.

4. Harassment or Abuse
Every worker will be treated with respect and dignity.
No worker will be subject to any physical, sexual, psychological or
verbal harassment or abuse.
H&A.12 Grievance Procedure                                                    Noncompliance            The growers and the workers are     Grower and worker interviews
                                                                                                       not aware of the grievance policies
                                                                                                       or procedures.

No person shall be subject to any discrimination in employment,
including hiring, wages, benefits, advancement, discipline, termination,
on the basis of gender, religion, caste, age, disability, sexual
orientation, political opinion, or social or ethnic origin.

D.3 Sex-Based Wage Discrimination                                             Noncompliance            Wages are different for males and   Grower and worker interviews
                                                                                                       females for the same kind of job.

6. Health and Safety
Grower will provide a safe and healthy working environment to prevent
accidents and injury to health arising out of, linked with, or occurring in
the course of work or as a result of the operation of the farm.

H&S.2 Document Maintenance/Worker Accessibility and Awareness                 Noncompliance            MSDS Sheets were not available.     Grower and worker interviews,
                                                                                                                                           Observations
H&S.3 Written Health and Safety Policy                                        Noncompliance            None of the farmers had a copy of   Grower and worker interviews,
                                                                                                       any available H&S policy.           Observations


                                                                                                                                                                                                                                              1
                         FLA Code/Benchmark                                    Compliance Status       Describe noncompliance or         List sources/documentation used for Cite and describe local and/or    Describe notable features
                                                                                                       uncorroborated evidence of       reference and corroborating evidence country laws used for additional implemented by growers or
                                                                                                             noncompliance                   (e.g. worker interviews, farms             reference                     Company
                                                                                                                                          walkthrough, records review, etc.)

H&S.4 Health and Safety Management System                                 Noncompliance            A system could be introduced        Grower and worker interviews,
                                                                                                   whereby workers reporting illnesses Observations
                                                                                                   or injuries are recorded in the
                                                                                                   attendance register.
H&S.5 Communication to Workers                                            Noncompliance            Workers are not aware of any H&S Grower and worker interviews,
                                                                                                   policy - they had not been given any Observations
                                                                                                   training about this.

H&S.6 Access to Safety Equipment and First Aid                            Noncompliance            The workers depend on the              Grower and worker interviews,
                                                                                                   grower's ability/interest in providing Observations
                                                                                                   the equipment and first aid.

H&S.8 Chemical Management and Training                                    Noncompliance            The safe disposal of chemicals has   Grower and worker interviews,
                                                                                                   to be focused on.                    Observations
H&S.11 Machinery Maintenance and Worker Training                          Noncompliance            Though large machines are not        Grower and worker interviews,
                                                                                                   used, it is important to train the   Observations
                                                                                                   workers on the safe use of
                                                                                                   equipment, like chemical sprayers.
H&S.12 Medical Facilities                                                 Noncompliance            First aid boxes are not available on Grower and worker interviews,
                                                                                                   the farms.                           Observations
H&S.14 Rest Areas                                                         Noncompliance            No rest areas are provided.          Grower and worker interviews,
                                                                                                                                        Observations
7. Freedom of Association and Collective Bargaining

Grower will recognize and respect the right of employees to freedom
of association and collective bargaining.

8. Hours of Work
No worker shall be expected to work for more than 8 hours in a day
and can be extended to 10 hours in case of extra ordinary
circumstances.
HOW.2 Rest Day                                                            Uncorroborated           Local stakeholders said that        Grower and worker interviews
                                                                          noncompliance            workers were likely to work on all
                                                                                                   days of the week during peak
                                                                                                   season, but the interviewed workers
                                                                                                   could not confirm this.
HOW.4 Overtime                                                            Uncorroborated           Local stakeholders said that        Grower and worker interviews
                                                                          noncompliance            overtime was present on rare
                                                                                                   occasions in the peak season, but
                                                                                                   the interviewed workers could not
                                                                                                   confirm this.
HOW.5 Over Time/Positive Incentives                                       Uncorroborated           Local stakeholders said that        Grower and worker interviews
                                                                          noncompliance            overtime was likely to be present
                                                                                                   during the peak season, but there
                                                                                                   were no documents to confirm or
                                                                                                   refute this finding.
HOW.6 Public Holidays                                                     Uncorroborated           Local stakeholders said that         Grower and worker interviews
                                                                          noncompliance            workers have to work on public
                                                                                                   holidays during peak season, but
                                                                                                   the interviewed workers could not
                                                                                                   confirm or deny this.
9. Wages, Benefits and Overtime Compensation
WAGES AND BENEFITS: Growers recognize that wages are
essential to meeting workers’ basic needs. Growers will pay workers,
as a base, at least the minimum wage required by local law or the
prevailing industry wage, whichever is higher, and will provide legally
mandated benefits.




                                                                                                                                                                                                                                           2
                        FLA Code/Benchmark                                    Compliance Status       Describe noncompliance or     List sources/documentation used for Cite and describe local and/or    Describe notable features
                                                                                                      uncorroborated evidence of   reference and corroborating evidence country laws used for additional implemented by growers or
                                                                                                            noncompliance               (e.g. worker interviews, farms             reference                     Company
                                                                                                                                     walkthrough, records review, etc.)

OVERTIME COMPENSATION: In addition to their compensation for
regular hours of work, workers will be compensated for overtime hours
at such premium rate as is legally required in the country of
manufacture or, in those countries where such laws will not exist, at a
rate at least equal to their regular hourly compensation rate.

WBOT.2 Minimum Wage                                                       Noncompliance           Wages are less than the minimum Grower and worker interviews
                                                                                                  wages recommended in Karnataka.
                                                                                                  Workers are paid the wages as
                                                                                                  decided by the village leaders.


WBOT.7 Record Maintenance                                                 Noncompliance           No records are available.        Grower and worker interviews

Miscellaneous




                                                                                                                                                                                                                                      3
FLA Audit Profile
Country                                                                        India
Number of Total Farms Visited                                                  25
Audit State/Province                                                           Karnataka
Independent External Monitoring Organization                                   St. John's Medical College, Bangalore
Date(s) in Farms                                                               September 29-30, 2009
FLA Affiliated Company(ies)                                                    Syngenta
Total Number of Workers                                                        2
Total area covered under audit (Acres)                                         Over 21 Acres
Production Processes at the time of IEM visit (sowing,                         Harvesting, seed removal and sorting of okra seeds
harvesting, chemical spray, hybridization or none)
Product(s)                                                                     Okra

                           FLA Code/Benchmark                                  Compliance Status                                                                                                                        Remediation                                                                                                                                     Status
                                                                                                    Description of noncompliance, or uncorroborated   Company Internal Audit                                       Company Remediation Plan                                           Target Completion Growers Response Company Follow-Up        Documentation   Completed, Pending,
                                                                                                               evidence of noncompliance                Findings (optional)                                                                                                                  Date           (optional)    (cite date of follow-                       On-going
                                                                                                                                                                                                                                                                                                                                   up)
GEN 1: Establish and articulate clear, written workplace standards. Formally   Noncompliance       The standards are not clearly conveyed to the                                As part of an overall remediation plan, Syngenta launched a country-wide program called                                                                                           Pending
convey those standards to Company Growers as well as to Seed Organizers.                           growers and seed organisers.                                                "Syngenta Me & Mine" in August 2009. Under this program, the consensus from key internal
                                                                                                                                                                               stakeholders was secured to define tangible, recognizable, practical and respected commitment
                                                                                                                                                                               from the growers so that they have a sense of ownership. To implement this program, two special
                                                                                                                                                                               agencies, IRFT and Glocal, were appointed to train the implementing staff of Syngenta and work
                                                                                                                                                                               with growers and laborers in the field. The Syngenta COC covers all the Codes/Workplace
                                                                                                                                                                               Standards prescribed by the FLA COC. The COC in English and the respective local language is
                                                                                                                                                                               available in the IMS center. Trainings provided so far and in the future will be documented in a
                                                                                                                                                                               standard format that is in the process of development. Syngenta will continue with their existing
                                                                                                                                                                               code awareness strategy, which includes a door-to-door campaign, pre-season meetings with
                                                                                                                                                                               growers, village level trainings and advertising through the local cable television network. All
                                                                                                                                                                               activities will be documented with lists of attendees.
                                                                                                                                                                               Actions:
                                                                                                                                                                               1) Prepare internal audit module and plan for 2010.
                                                                                                                                                                               2) Prepare standard format for training and documentation for recording.
                                                                                                                                                                               3) Prepare training schedule for 2010 covering all the topics.
                                                                                                                                                                               4) Compile and implement feedback from the monitoring data (external and internal).
                                                                                                                                                                               5) Continue to distribute the COC along with the foundation seed/seedlings in the local
                                                                                                                                                                               language, and also display it prominently at the IMS center.



                                                                                                                                                                               6) Company field supervisors and organizers will be nominated to receive and conduct                     August, 2010                                                              Pending
                                                                                                                                                                               awareness training. They will be responsible for identifying key areas in the village where
                                                                                                                                                                               the code can be posted. They will also conduct periodic monitoring of posting of the code.
                                                                                                                                                                               7) Codes of Conduct will not be posted at each farm, but rather relevant messages will
                                                                                                                                                                               be posted or disseminated in village schools; temples; common meeting places and
                                                                                                                                                                               offices of the local administration body (Panchayat); to organizers and to the company as
                                                                                                                                                                               prescribed by the stakeholders.
                                                                                                                                                                               8) Audio-visual aids instead of written material will be used, as growers and workers are mostly an
                                                                                                                                                                               illiterate audience.
                                                                                                                                                                               9) Trainings will be customized for family labor farms. The grower, who is generally the head of the
                                                                                                                                                                               family, can be trained as an educator. Female members (mothers/elder women) of the family will be
                                                                                                                                                                               involved in awareness programs. A communication strategy for each target audience within the
                                                                                                                                                                               program: organizers, growers, family labor and hired labor will be developed.
                                                                                                                                                                               10) A peer-to-peer awareness building model (worker-to-worker, grower-to-grower,
                                                                                                                                                                               supervisor-to-supervisor and women-to-women) and self-help groups will be established.
                                                                                                                                                                               Separate meetings will be held with women, keeping in mind cultural sensitivities.
                                                                                                                                                                               11) Tools in the internal monitoring system will be developed to measure awareness over a
                                                                                                                                                                               period of time.




GEN 2: Ensure that all Company growers as well as Seed Organizers inform Noncompliance             The workers are not aware of the workplace                                  Syngenta will insist the growers train the workers on COC. During the COC training Syngenta will     August, 2010
their workers about the workplace standards orally and through the posting of                      standards.                                                                  also insist the growers to invite the workers.
standards in a prominent place (in the local languages spoken by workers)                                                                                                      Action:
and undertake other efforts to educate workers about the standards on a                                                                                                        1) Codes of Conduct will be not posted at each farm, but rather relevant messages posted or
regular basis.                                                                                                                                                                 disseminated in village schools, temples, common meeting places, offices of the local administration
                                                                                                                                                                               body (Panchayat), organizers and the company as prescribed by the stakeholders.
                                                                                                                                                                               2) Trainings will be customized for family labor farms. The grower, who is generally the head of the
                                                                                                                                                                               family, can be trained as an educator. Women members (mothers/elder women) of the family will
                                                                                                                                                                               be involved in awareness programs. A communication strategy for each target audience within the
                                                                                                                                                                               program: organizers, growers, family labor and hired labor will be
                                                                                                                                                                               developed.
                                                                                                                                                                               3) A peer-to-peer awareness building model (worker-to-worker, grower-to-grower,
                                                                                                                                                                               supervisor-to-supervisor, and women-to-women) and self-help groups will be established.
                                                                                                                                                                               Separate meetings will be held with women, keeping in mind cultural sensitivities.
                                                                                                                                                                               4) Increase the women mobilizers to work closely with the growers' families.




H&A.12 Grievance Procedure                                                     Noncompliance       The growers and the workers are not aware of the                            Syngenta to create awareness through training programs to all the concerned stakeholders on the        August, 2010                                                                Pending
                                                                                                   grievance policies or procedures.                                           noncompliance matters. Syngenta will also develop a culture with a transparent work environment
                                                                                                                                                                               and establish strong communication among the team.
                                                                                                                                                                               Actions:
                                                                                                                                                                               1) Syngenta will start engaging opinion leaders, teachers and women at the village level to form a
                                                                                                                                                                               committee that can serve as a channel for information dissemination and worker grievances. At
                                                                                                                                                                               least 50% of grievance committee members will be women. The company will take appropriate
                                                                                                                                                                               steps to publicize this grievance channel among growers and workers. The village committee
                                                                                                                                                                               members' contact information, as well as that of the organizers and company supervisors, will be
                                                                                                                                                                               made available to the growers and workers. The village committee will contact the company in the
                                                                                                                                                                               case of grievances.
                                                                                                                                                                               2) One day per month will be assigned for the company representative to deal with worker
                                                                                                                                                                               grievances at the field level. All grievances from the workers will be documented for analysis.




                                                                                                                                                                                                                                                                                                                                                                     4
                            FLA Code/Benchmark                  Compliance Status                                                                                                                             Remediation                                                                                                                                       Status
                                                                                     Description of noncompliance, or uncorroborated      Company Internal Audit                                         Company Remediation Plan                                             Target Completion Growers Response Company Follow-Up        Documentation   Completed, Pending,
                                                                                                evidence of noncompliance                   Findings (optional)                                                                                                                      Date           (optional)    (cite date of follow-                       On-going
                                                                                                                                                                                                                                                                                                                           up)
D.3 Sex-Based Wage Discrimination                               Noncompliance       Wages are different for males and females for the                              Action:                                                                                                    December, 2010                                                              Pending
                                                                                    same kind of job.                                                              Both males and females will be provided equal wages for equal work. Syngenta will create
                                                                                                                                                                   awareness in the production regions on this and shall monitor this under internal monitoring.



H&S.2 Document Maintenance/Worker Accessibility and Awareness   Noncompliance       MSDS Sheets were not available.                                                We are developing such posters to create more awareness among the growers and workers.                     August, 2010                                                                Pending
                                                                                                                                                                   Action:
                                                                                                                                                                   1) Develop pictorial images on safe working conditions on the farms.
                                                                                                                                                                   2) Information on safety methods for chemical management will be imparted to the workers and
                                                                                                                                                                   growers. Informational materials such as the Material Safety and Data Sheet (MSDS), H&S
                                                                                                                                                                   regulations, banned chemicals, chemical storage and machine maintenance are difficult to
                                                                                                                                                                   understand in their original forms. Abstracts of the same will be made available in local languages.
                                                                                                                                                                   Emphasis will be placed on training rather than posting.
                                                                                                                                                                   3) Field Standard Operating Procedures (SOPs) on chemical usage will provide information such
                                                                                                                                                                   as the amount and frequency of chemical use, ill effects of chemical, proper mixing and spraying
                                                                                                                                                                   along with other relevant information. Frequent internal monitoring team visits will be conducted to
                                                                                                                                                                   ensure correct implementation of the procedures.
                                                                                                                                                                   4) Periodic health checks of farmers engaged in chemical use will be organized. A list of
                                                                                                                                                                   medicines in the first aid kit will be made available. First aid training engaging local doctors will be
                                                                                                                                                                   adopted. Information on the nearest health care facility will be made available to the growers.
                                                                                                                                                                   5) Crop life standards for HSE will be studied and adapted to Syngenta farms.
                                                                                                                                                                   6) Exclusive training session on effective first aid is planned for all the locations.




H&S.3 Written Health and Safety Policy                          Noncompliance       None of the farmers had a copy of any available                                Formal, disciplined working systems H&S policy is developed. This document explains about how              December, 2010                                                              Pending
                                                                                    H&S policy.                                                                    the company stands on H&S. The document is available at all IMS centers. However, key points of
                                                                                                                                                                   this are included in the document "Best Seed Production Practices," which is explained and given
                                                                                                                                                                   to the growers at the time of seed production.                                        Action:
                                                                                                                                                                   Create more awareness on the HSE aspects.



H&S.4 Health and Safety Management System                       Noncompliance       A system could be introduced whereby workers                                   Syngenta has developed a H&S policy and a system to implement it.                                          From June to                                                                Pending
                                                                                    reporting illnesses or injuries are recorded in the                            Actions:                                                                                                   December, 2010
                                                                                    attendance register.                                                           1) More awareness campaigns to be organized.
                                                                                                                                                                   2) Appoint an agency to help Syngenta in this area.



H&S.5 Communication to Workers                                  Noncompliance       Workers are not aware of any H&S policy - they                                 Awareness programs in this area are in progress. Syngenta has made this part of their routine              October, 2010                                                               Pending
                                                                                    had not been given any training about this.                                    campaigns. As the seed production area is increasing day by day we have to continue educating
                                                                                                                                                                   the new growers.                                                                 Actions:
                                                                                                                                                                   1) Strengthen the awareness campaigns,
                                                                                                                                                                   2) Engage the exclusive agency,
                                                                                                                                                                   3) Focus on new growers.



H&S.6 Access to Safety Equipment and First Aid                  Noncompliance       The workers depend on the grower's ability/interest                            First aid kits kept at the schools are for farmers and the workers. The trainings are in progress in       October, 2010                                                               Pending
                                                                                    in providing the equipment and first aid.                                      this area. Practically it is difficult to supply first aid to all the growers but,
                                                                                                                                                                   Action:
                                                                                                                                                                   1) Syngenta will provide first aid boxes.
                                                                                                                                                                   2) Additional requirement will be worked out and purchased.
                                                                                                                                                                   3) Growers will be encouraged to keep the first aid boxes on their own.
                                                                                                                                                                   4) Growers will be sufficiently trained in effective use of first aid.

H&S.8 Chemical Management and Training                          Noncompliance       The safe disposal of chemicals has to be focused                               Our internal monitoring data indicates that there is a greater degree of improvement noticed in this October, 2010                                                                     Pending
                                                                                    on.                                                                            area. We have organized safe chemical handling trainings, in which we have covered maximum
                                                                                                                                                                   growers and made aware about its handling. One more agency, IRFT, was also in place to address
                                                                                                                                                                   this issue. The implementing team is well trained in this area and now they are taking efforts in
                                                                                                                                                                   improving the situation.
                                                                                                                                                                   Actions:
                                                                                                                                                                   1) Organize more of such trainings to cover all the growers.
                                                                                                                                                                   2) Engage one agency which will help the company address this issue at a greater level.
                                                                                                                                                                   3) Stringent monitoring.


H&S.11 Machinery Maintenance and Worker Training                Noncompliance       Though large machines are not used, it is important                            This area will be covered under the above mentioned training on comprehensive H&S procedures.              October, 2010                                                               Pending
                                                                                    to train the workers on the safe use of equipment,                             Actions:
                                                                                    like chemical sprayers.                                                        1) Stringent monitoring of all the farms are in progress.
                                                                                                                                                                   2) We have added this as a separate element in the tool.
                                                                                                                                                                   3) We will cover this in our regular awareness campaigns.


H&S.12 Medical Facilities                                       Noncompliance       First aid boxes are not available on the farms.                                First aid kits kept at the schools are for farmers and the workers. The trainings are in progress in       October, 2010                                                               Pending
                                                                                                                                                                   this area. Practically it is difficult to supply first aid to all the growers, but:
                                                                                                                                                                   Actions:
                                                                                                                                                                   1) Syngenta will provide first aid boxes.
                                                                                                                                                                   2) Additional requirements will be worked out and purchased.
                                                                                                                                                                   3) Growers will be encouraged to keep the first aid boxes on their own.
                                                                                                                                                                   4) Growers will be sufficiently trained in the effective use of first aid


H&S.14 Rest Areas                                               Noncompliance       No rest areas are provided.                                                    Actions:                                                                                                   October, 2010                                                               Pending
                                                                                                                                                                   1) We are encouraging the growers to have rest areas on their farms.
                                                                                                                                                                   2) Many of the growers are starting to have shades on their farms.




                                                                                                                                                                                                                                                                                                                                                             5
                         FLA Code/Benchmark   Compliance Status                                                                                                                          Remediation                                                                                                                                   Status
                                                                   Description of noncompliance, or uncorroborated      Company Internal Audit                                      Company Remediation Plan                                         Target Completion Growers Response Company Follow-Up        Documentation   Completed, Pending,
                                                                              evidence of noncompliance                   Findings (optional)                                                                                                               Date           (optional)    (cite date of follow-                       On-going
                                                                                                                                                                                                                                                                                                  up)
HOW.2 Rest Day                                Uncorroborated      Local stakeholders said that workers were likely to                            Actions:                                                                                           October, 2010                                                                Pending
                                              noncompliance       work on all days of the week during peak season,                               1) We are encouraging the growers to have rest areas on their farms.
                                                                  but the interviewed workers could not confirm this.                            2) Many of the growers are starting to have shades on their farms.



HOW.4 Overtime                                Uncorroborated      Local stakeholders said that overtime was present                              Action:                                                                                            October, 2010                                                                Pending
                                              noncompliance       on rare occasions in the peak season, but the                                  1) Syngenta will encourage the growers to keep records of overtime.
                                                                  interviewed workers could not confirm this.                                    2) Syngenta will insist the growers to pay overtime to the workers
                                                                                                                                                 3) Syngenta will also encourage the growers to pay equal wages for males and females when they
                                                                                                                                                 perform the same work.


HOW.5 Over Time/Positive Incentives           Uncorroborated      Local stakeholders said that overtime was likely to                            Actions:                                                                                           October, 2010                                                                Pending
                                              noncompliance       be present during the peak season, but there were                              1) Syngenta will encourage the growers to keep records of overtime.
                                                                  no documents to confirm or refute this finding.                                2) Syngenta will insist the growers pay overtime to the workers.
                                                                                                                                                 3) Syngenta will also encourage the growers to pay equal wages to males and females when they
                                                                                                                                                 perform the same work.
HOW.6 Public Holidays                         Uncorroborated      Local stakeholders said that workers have to work                              Actions:                                                                                           October, 2010                                                                Pending
                                              noncompliance       on public holidays during peak season, but the                                 1) Syngenta will encourage the growers to keep records of overtime.
                                                                  interviewed workers could not confirm or deny this.                            2) Syngenta will insist the growers pay overtime to the workers.
                                                                                                                                                 3) Syngenta will also encourage the growers to pay equal wages to males and females when they
                                                                                                                                                 perform the same work.


WBOT.2 Minimum Wage                           Noncompliance       Wages are less than the minimum wages                                          Actions:                                                                                              December, 2010                                                            Pending
                                                                  recommended in Karnataka. Workers are paid the                                 1) Continuous monitoring on the wage situation;
                                                                  wages as decided by the village leaders.                                       2) Syngenta will continue strict vigilance on such matters;
                                                                                                                                                 3) Syngenta will encourage the growers to pay the minimum wages as per the local law.
                                                                                                                                                 4) There is a gap between the legal minimum wage and the actual wage paid to workers. It is
                                                                                                                                                 important to report this gap in internal monitoring. A study on wages and benefits will be undertaken
                                                                                                                                                 to understand the causes behind the non-payment of minimum wages, whether governed by
                                                                                                                                                 market forces, culture and regular practice, in-between contractors, etc. This will help the company
                                                                                                                                                 develop remediation plans that address root causes.

WBOT.7 Record Maintenance                     Noncompliance       No records are available.                                                      Although maintaining documents at farms is difficult, it is important. The company has designed December, 2010                                                                  Pending
                                                                                                                                                 and provided a simple, uniform documentation system to growers, which can help them in
                                                                                                                                                 maintaining records of employment, wages, advances, hours of work, etc. Incentives can be a way
                                                                                                                                                 to promote record maintenance. Awareness building needs to happen around record maintenance,
                                                                                                                                                 as this can lead to growers’ and workers’ own good.
                                                                                                                                                 1) Auditors have expressed their satisfaction on documentation over last few years.
                                                                                                                                                 2) New formats are developed like event cards, family cards and farmer education cards.
                                                                                                                                                 3) All records are available at the IMS center across the locations.




                                                                                                                                                                                                                                                                                                                                    6
FLA Audit Profile
Country                                                               India
Number of Total Farms Visited                                         25
Audit State/Province                                                  Karnataka
Independent External Monitoring Organization                          St. John's Medical College, Bangalore
Date(s) in Farms                                                      September 29-30, 2009
FLA Affiliated Company(ies)                                           Syngenta
Total Number of Workers                                               2
Total area covered under audit (Acres)                                Over 21 Acres
Production Processes at time of IEM visit (sowing,                    Harvesting, seed removal and sorting of okra seeds
harvesting, chemical spray, hybridization or none)

Product(s)                                                            Okra

                       FLA Code/Benchmark                                    Compliance Status             [Status]              Description of noncompliance, or uncorroborated          Updates (Cite Date of Follow-Up)        Third-Party Verification           Company Verification Follow-Up
                                                                                                    Completed, Pending, On-                 evidence of noncompliance                    Company Follow-Up      Documentation    External Documentation Company Follow-Up (cite            Documentation
                                                                                                            going                                                                                                               Verification               date of planned or follow-up
                                                                                                                                                                                                                                  (Date)                       visit, if appropriate)
GEN 1: Establish and articulate clear, written workplace standards.   Noncompliance               Pending                     The standards are not clearly conveyed to the growers
Formally convey those standards to Company Growers as well as to                                                              and seed organisers.
Seed Organizers.



GEN 2: Ensure that all Company growers as well as Seed Organizers Noncompliance                   Pending                     The workers are not aware of the workplace standards.
inform their workers about the workplace standards orally and
through the posting of standards in a prominent place (in the local
languages spoken by workers) and undertake other efforts to educate
workers about the standards on a regular basis.




H&A.12 Grievance Procedure                                            Noncompliance               Pending                     The growers and the workers are not aware of the
                                                                                                                              grievance policies or procedures.


D.3 Sex-Based Wage Discrimination                                     Noncompliance               Pending                     Wages are different for males and females for the same
                                                                                                                              kind of job.


H&S.2 Document Maintenance/Worker Accessibility and Awareness         Noncompliance               Pending                     MSDS Sheets were not available.



H&S.3 Written Health and Safety Policy                                Noncompliance               Pending                     None of the farmers had a copy of any available H&S
                                                                                                                              policy.


H&S.4 Health and Safety Management System                             Noncompliance               Pending                     A system could be introduced whereby workers
                                                                                                                              reporting illnesses or injuries are recorded in the
                                                                                                                              attendance register.

H&S.5 Communication to Workers                                        Noncompliance               Pending                     Workers are not aware of any H&S policy - they had not
                                                                                                                              been given any training about this.



H&S.6 Access to Safety Equipment and First Aid                        Noncompliance               Pending                     The workers depend on the grower's ability/interest in
                                                                                                                              providing the equipment and first aid.


H&S.8 Chemical Management and Training                                Noncompliance               Pending                     The safe disposal of chemicals has to be focused on.



H&S.11 Machinery Maintenance and Worker Training                      Noncompliance               Pending                     Though large machines are not used, it is important to
                                                                                                                              train the workers on the safe use of equipment, like
                                                                                                                              chemical sprayers.


H&S.12 Medical Facilities                                             Noncompliance               Pending                     First aid boxes are not available on the farms.

H&S.14 Rest Areas                                                     Noncompliance               Pending                     No rest areas are provided.

HOW.2 Rest Day                                                        Uncorroborated noncompliance Pending                    Local stakeholders said that workers were likely to work
                                                                                                                              on all days of the week during peak season, but the
                                                                                                                              interviewed workers could not confirm this.




                                                                                                                                                                                                                                                                                           7
                        FLA Code/Benchmark        Compliance Status               [Status]              Description of noncompliance, or uncorroborated         Updates (Cite Date of Follow-Up)        Third-Party Verification           Company Verification Follow-Up
                                                                           Completed, Pending, On-                 evidence of noncompliance                   Company Follow-Up      Documentation    External Documentation Company Follow-Up (cite            Documentation
                                                                                   going                                                                                                              Verification               date of planned or follow-up
                                                                                                                                                                                                        (Date)                       visit, if appropriate)
HOW.4 Overtime                               Uncorroborated noncompliance Pending                    Local stakeholders said that overtime was present on
                                                                                                     rare occasions in the peak season, but the interviewed
                                                                                                     workers could not confirm this.



HOW.5 Over Time/Positive Incentives          Uncorroborated noncompliance Pending                    Local stakeholders said that overtime was likely to be
                                                                                                     present during the peak season, but there were no
                                                                                                     documents to confirm or refute this finding.


HOW.6 Public Holidays                        Uncorroborated noncompliance Pending                    Local stakeholders said that workers have to work on
                                                                                                     public holidays during peak season, but the interviewed
                                                                                                     workers could not confirm or deny this.


WBOT.2 Minimum Wage                          Noncompliance               Pending                     Wages are less than the minimum wages
                                                                                                     recommended in Karnataka. Workers are paid the
                                                                                                     wages as decided by the village leaders.



WBOT.7 Record Maintenance                    Noncompliance               Pending                     No records are available.




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