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Chart - Nonprofit organization dedicated to ending sweatshop

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									FLA Audit Profile Country Factory name IEM Date(s) in facility PC(s) Number of workers Product(s) Production processes INDIA 08003296DV T-GROUP SOLUTIONS PVT. LTD. NOVEMBER 24 & 25, 2005 NORDSTROM, Inc. 733 WOVEN TOPS CUTTING, SEWING, WASHING, FINISHING & PACKING

IEV: BUREAU VERITAS CONSUMER PRODUCTS SERVICES Date (s) in facility: November 21, 2007 PC (s): NORDSTROM, Inc.

FLA Comment: In situations where a FLA-affiliated Company is no longer sourcing from a factory that has received an Independent External Monitoring visit, the Company shall submit information on (a) the reason for exiting; (b) the status of compliance and summary of efforts to remediate noncompliances in the factory; and (c) plans to follow up on critical issues. The FLA-affiliated Company in this case has submitted the following information, which has not been verified by the FLA: Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

1. Code Awareness Code posting/information

Industrial Employment ( Standing Orders) Act, 1946

FLA Principle of Monitoring, Obligation of Companies: Establish and articulate clear, written workplace standards. Formally convey those standards to Company factories as well as to licensees, contractors and suppliers. FLA Principle of Monitoring, Obligation of Companies: Ensure that all Company factories as well as contractors and suppliers inform their employees about the workplace standards orally and through the posting of standards in a prominent place (in the local languages spoken by employees and managers) and undertake other efforts to educate employees about the standards on a regular basis.

The only Nordstrom Code of Conduct poster posted on the inside of the boundary wall near the main gate is in English and an Oriental language, perhaps, Mandarin and not in the local language of this region

Visual inspection & Interview with management

Worker/management awareness of The factories Act, 1948 Code

Code Elements have not been communicated to the Management and Workers. The Management have also not communicated the Code elements to workers.

Interview with management & workers

Confidential non-compliance reporting channel

FLA Principle of Monitoring, Obligation of Companies: Develop a secure communications channel, in a manner appropriate to the culture and situation, to enable Company employees and employees of contractors and suppliers to report to the Company on noncompliance with the workplace standards, with security that they shall not be punished or prejudiced for doing so.

Though a contact number and mailing address of PC's head office has been provided on the Code Poster, none of the employees are aware of this . In fact none of the workers are aware of this Code posting and name of the PC. Management was also not aware of the reason for providing the contact number/address.

Visual inspection, Interview with management & workers

2.Forced Labor There will not be any use of forced labor, whether in the form of prison labor, indentured labor, bonded labor or otherwise

1

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

Employment Records

Factories Act 1948 & Industrial Employment (Standing Orders ) Act 1956

Employers will maintain sufficient hiring and 1. Job application is missing from personnel employment records to demonstrate and files. 2. Employment records are not verify compliance with this Code provision maintained for casual workers out-sourced through agents for short duration work like hand-embroidery, alteration, mending etc.

Interview with management & workers / review of records

3. Child Labor No person will be employed at an age younger than 15 (or 14 where the law of the country of manufacture allows) or younger than the age for completing compulsory education in the country of manufacture where such age is higher than 15. Age Documentation The Factories Act, 1948 Employers will maintain a proof of age documentation for all workers, such as a birth certificate, which verifies date of birth. No proof of age documents maintained for casual workers out-sourced through agents for short duration work like hand-embroidery, alteration, mending etc. Interview with management

4. Harassment or Abuse Every employee will be treated with respect and dignity. No employee will be subject to any physical, sexual, psychological or verbal harassment of abuse. Other: Legal Compliance Per Supreme Court Judgment No.666-70 of 1992 Factory does not have a “SEXUAL HARASSMENT - COMPLAINTS COMMITTEE” as required by Law. Interview with management

Training of Management in Disciplinary Practices

Employers will provide training to managers Employer does not provide training to and supervisors in appropriate disciplinary managers and supervisors in appropriate practices disciplinary practices

Interview with management

2

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

Freedom of Movement

Employers will not unreasonably restrain Workers interviewed stated that they have to freedom of movement of workers, including obtain a gate pass to exit the factory during movement in canteen, during breaks, using lunch break toilets, accessing water, or to access necessary medical attention

Interviews with workers and management

5. Nondiscrimination No person will be subject to any discrimination in employment, including hiring, salary, benefits, advancement, discipline, termination or retirement, on the basis of gender, race, religion, age, disability, sexual orientation, nationality, political opinion, or social or ethnic origin. 6. Health and Safety Employers 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 employer facilities Evacuation Procedure Factories Act 1948 All applicable legally required or recommended elements of safe evacuation (such as posting of evacuation plans, unblocked aisles/exits, employee education, evacuation procedures, etc.) shall be complied with and workers shall be trained in proper safety, first aid, and evacuation procedures 1. Evacuation signs and aisles are either missing or have got erased owing to wear and tear in most work areas. 2. Evacuation plans in work areas have discrepancies. Do not entirely match with the floor layout. 3 Sewing halls are congested. Space between two work stations in some places was as little as 12 to 15 inches. Instances of two workers working together at the same work-station noticed. This is also causing congestion. 4. Rear horizontal aisle in the sewing hall in the basement is narrow. Standing workers on work-stations were seen on the passage. Side aisle in production hall in the basement and on ground floor and another in the training section on the terrace are narrow – 16 to 24 inches width. 5. Some sewing operators had blocked their access to passage with bins. 6. An aisle in the cutting section on the groundfloor was blocked with fabric bundles. 7. Store has only one exit 8.The passage at the fabric laying table near the wall in the cutting section in the basement is narrow and restricts free movement. One side was partially blocked with fabric. Visual Inspection

3

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

9. Aisles were seen blocked with heaps of garments in production areas. 10. Canteen does not have an Emergency exit at the opposite end. 11. Emergency lights on staircase landing are not high-beam type with battery back-up. There are no emergency lights installed on exits at the production hall on first floor. 12. „Keep clear‟ yellow boxes are not marked in front of exits at the production hall on first floor. 13. Fusing machine area in the cutting section in the basement is congested with little room for movement. 14. A sewing station in the finishing section in the basement had the operator blocked on both sides with cartons. Wire of the machine was running across the passage. 15. New cartons and hanger storage shed on the ground floor is disorganized . Also scrapings from wood work in progress (carpenters making furniture) are lying in this area in poly-bags.

Visual Inspection

Safety Equipment

Factories Act 1948

All safety and medical equipment (such as fire fighting equipment, first aid kits, etc.) shall be in place, maintained as prescribed and accessible to the employees

1.First-aid boxes have eye-wash cups but no eye-wash/distilled water. (Floating fabric dust particles were seen in work areas.) 2. A Fire extinguisher was found blocked in the cutting section in the basement and another in the new cartons/hanger storage shed on the ground floor. 3. No fire extinguisher is installed in the area near the laundry where boilers and diesel storage tank are installed. 4Kitchen area on the first floor has 4 LPG cylinders for cooking . There is no fire extinguisher installed in this area. 1. Some operators on over-lock operations where fabric dust was observed and some with fabric dust on their hair are not using appropriate protective masks. 2. Personal protective gear and material safety data sheets were not available at the stain removing areas in the finishing section in the basement and on first floor. 3. Band knife operator in the cutting section uses protective glove on one hand instead of both hands 4. No ear muffs were available for use by the generator operator in the generator area inside which the decibel level is in excess of 100 dbs.

Visual Inspection

PPE

Factories Act 1948

Workers shall wear appropriate protective equipment (such as gloves, eye protection, hearing protection, respiratory protection, etc.) to prevent unsafe exposure (such as inhalation or contact with solvent vapors, noise, dust, etc.) to hazardous elements including medical waste.

Visual Inspection

4

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

Chemical Management

Factories Act 1948

All chemicals and hazardous substances should be properly labeled and stored in accordance with applicable laws. Workers should receive training, appropriate to their job responsibilities, in the safe use of chemicals and other hazardous substances

1. A container containing „hexine‟ used for stain removing was found lying on the floor in the finishing hall in the basement. 2. Cans of machine oil were seen kept in the open on the terrace in the canteen area exposed to rain and sun-light. 3. High speed diesel barrels were seen lying outside in the open exposed to rain and sun near the cartons and hanger storage shed. There is no „No Smoking‟ sign installed. 4. Stain removing stations in finishing areas do not have exhaust pipes for discharging exhaust fumes outside the work area

Visual Inspection

Ventilation/Electrical/facility maintenance

All ventilation, plumbing, electrical, and lighting services shall be provided and maintained to conform to applicable laws and prevent hazardous conditions to employees in the facility

1. Damaged wiring with taped joints was noticed at some of the pressing stations in finishing areas, also at the stain removing station on first floor and on the exhaust fan wiring in the cutting section in the basement. 2. Lighting at needle point on some of the sewing machines ranged from 150 to 250 lux. 3. Loose machine wires were seen running near operators‟ feet at some work stations in sewing areas. 4. Water seepage on walls, some of them with electrical installations was noticed on most floors 5. Electrical wiring junction boxes were seen without covers in pressing areas and on the wall at the staircase landing on the terrace. 6. Lint accumulation was noticed on the cooling vent above the fusing machine in the cutting section in the basement, on the pedestal fan and exhaust fan in the same cutting section and on exposed wires on the wall in the ladies toilet blocks on ground and first floors. 7. Junk, including discarded tube lights were seen lying behind the electrical panels in the distribution panel room. 8.The water down pipe from the terrace at the canteen to the drain on the ground floor was found to have developed a leak where connected to the man-hole on the ground floor outside the generator room. There was food waste from the washing area in the canteen lying in this area which is part of a passage.

Visual Inspection

The Indian Electricity Rules, 1956.

5

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

Machinery Maintenance

Factories Act 1948

All production machinery and equipment shall be maintained, properly guarded, and operated in a safe manner

1. Many sewing machines do not have pedal mats. 2. Boiler installed in the finishing area in the basement is not fenced. Steam-pipe lines in finishing sections are not insulated and could cause burn injuries. 3. Tag gun in use in the finishing section on first floor does not have the name of the user to ensure personalized usage.

Visual Inspection

Sanitation in Facilities

Factories Act 1948 & Uttar Pradesh Factory Rules 1950

All facilities including factory buildings, toilets, canteens, kitchens, and clinics, shall be kept clean and safe and be in compliance with applicable laws

1. Few broken floor tiles were noticed on the floor of the production hall on first floor. 2. Mens toilet blocks are in a very poor condition of maintenance. A urinal was seen choked while the toilet seats, sinks and urinals are completely stained with spit stains caused by chewing tobacco and betel. „Biri‟ (cheroot like cheap Indian cigarette) stubs and used matchsticks were seen lying on the floor. Some of the flushes were not functional while no soap and towels/hand-dryer are provided at the hand wash areas. Some of the flushes in ladies toilet blocks were not working while soap in some hand wash areas and towels at all hand wash areas were not provided. 3. Waste fabric room located near workers toilet blocks on the ground floor is completely disorganized with loose fabric bits and pieces dumped inside. At the entrance of this room a man-hole with a broken cover over a drain was noticed. 4. Packaging waste was dumped in a room at the canteen area in a disorganized manner. There is no „No Smoking‟ sign installed. 5. Cooked food items lying uncovered were seen in the kitchen area

Visual Inspection

Sanitation in Dining Area

Factories Act 1948

All food preparation shall be prepared, stored, and served in a sanitary manner in accordance with applicable laws. Safe drinking water should be available in each building.

1. The canteen on the terrace is open air without a roof. 2. A container of food was lying uncovered, without a lid, at the food sale counter. 3. Those serving food were not using appropriate gloves for hygiene

Visual Inspection

Other

Factories Act 1948

6

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

7. Freedom of Association and Collective Bargaining Employers will recognize and respect the right of employees to freedom of association and collective bargaining Other Factories Act 1948 & Industrial Disputes Act 1947

Workers in this committee are nominated by the Management and not elected as required by law

Interview with Workers & Management

8. Wages and Benefits Employers recognize that wages are essential to meeting employees‟ basic needs. Employers will pay employees, 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 Voluntary Use of Benefits All workers have a right to use or not to use Workers interviewed stated that INR 225 is employer provided services, such as deducted from their wages towards cost of housing or meals transportation being provided by the company. These workers stated that it was mandatory for them to avail of this facility and pay for it. Many workers complained that they reside within 5 kms from the factory , and it would take them 10 to 15 minutes to cycle/walk down to the work-place. Hence they suggested that availing of and paying for transportation provided by the company should be made optional. Factories Act 1948 Employers will provide workers a pay statement each pay period, which will show earned wages, regular and overtime pay, bonuses and all deductions 1. No pay slip is provided for overtime hours worked. 2. Piece rated pressmen and casual workers, provided by agent *** do not receive a wage slip. Interview with management and workers.

Pay statement

Review of records & interview with management & workers

7

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

Time-recording system

Factories Act 1948

Time worked by all employees, regardless of compensation system, will be documented by time cards or other accurate and reliable recording systems such as electronic swipe cards

Factory does not maintain time records for casual workers out-sourced through external agents. Factory maintains 2 sets of time records. The first set records the regular hours of work while the second set records overtime hours and rest days worked. The second set is an unofficial record. ( All records were available for review )

Interview with management, workers & review of records

Record Maintenance

The Factories Act, 1948

All compensation records will be maintained Pay-records for casual workers out-sourced accurately and should be acknowledged by through an external agent - *** *** were not the employee as accurate. available for review.

Interview with management

Legal benefits

The Employee State Insurance Act, 1948 Employee Provident Fund & MP act, 1952 The factories Act, 1948 Payment of bonus Act, 1956

Employers will provide all legally mandated Casual workers provided by an external agent benefits to all eligible workers - *** *** reported that they work in this facility temporarily for short durations (1-2 months) as & when required & are not enrolled for legally mandated benefits of Employees State Insurance & Provident Fund

Interview with Management & workers

Legal Compliance for holiday/leave The Factories Act, 1948

Workers will be paid for holidays and leave 1.These benefits are not extended to casual as required by law workers provided by *** *** 2.Earned leave is being accumulated for up to 45 days. By law , earned leave cannot be accumulated for over 30 days

Interview with management & workers

Timely Payment

Payment of Wages Act, 1936

All compensation shall be paid in a timely manner

Piece rated workers stated that they receive their wages between the 7th & 10th day of every month. By law, all payments are to be made within the 7th day of the month.

Interview with management & workers ; review of records

9. Hours of Work Except in extraordinary business circumstances, employees will (i) not be required to work more than the lesser of (a) 48 hours per week and 12 hours overtime or (b) the limits on regular and overtime hours allowed by the law of the country of manufacture or, where the laws of such country will not limit the hours of work, the regular work week in such country plus 12 hours overtime; and (ii) be entitled to at least one day off in every seven day period

8

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

Overtime Limitations

Factories Act 1948

Except in extraordinary business circumstances, employees will (i) not be required to work more than the lesser of (a) 48 hours per week and 12 hours overtime or (b) the limits on regular and overtime hours allowed by the law of the country of manufacture or, where the laws of such country will not limit the hours of work, the regular work week in such country plus 12 hours overtime; and (ii) be entitled to at least one day off in every seven day period. An extraordinary business circumstance is a temporary period of extra work that could not have been anticipated or alleviated by other reasonable efforts

1. Review of time records reveal excessive working hours over the past 3 months ranging between 63 hours to 97 hours per week. 2. Numerous instances of continuous work noticed ( up to 16 days ) with no day of rest being provided. By law, a worker cannot work for more than 10 days continuously without a day of rest.3. Factory has worked on most rest days over the past 3 months 4. On most occasions , factory works overtime up till 7 pm. The period of work from 1pm ( after lunch break ) is continuous till 7 pm. without any break. By law , a break of 30 minutes is required to be given after every 5 hours of continuous work

Interview with management & workers and review of records

10. Overtime Compensation In addition to their compensation for regular hours of work, employees 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. Factories Act 1948

Miscellaneous

9

FLA Code/ Compliance issue

Country Law/Legal Reference

FLA Benchmark

Non-compliance

Risk of Non-compliance

IEM Findings Evidence of Non-compliance (uncorroborated)

If not corroborated, explain why

Sources/Docu mentation used for corroborating

Notable Features implemented by Factory Management or Company

Outsourced Workers

Contract Labor (Regulation and Abolition) Act , 1970

License to provide workers to this factory , of an Agent - *** , has expired on Aug 31, 2004. The license has not been renewed though the agent continues to provide workers to this factory. This is a legal violation

Review of records and interview with Management.

other

Minimum wages act, 1950 The payment of wages act, 1936; The factories act. 1948; The maternity benefit act, 1961; Industrial Employment (Standing Order) Act 1946

10

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up)

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

Nordstrom will send a code of conduct poster for the workers in their native language

11/24/2005

4/1/2006 Mailed Poster to Factory

3/8/2006 photos of Nordstrom Partnership Guidelines posted in factory in local language 3/8/2006 Received photos 1/18/2007 Third Party of training. Will Re-audit found issue schedule 3rd still pending. party to interview workers and confirm understanding of Code elements, and factory policy and procedures 7/11/06 Nordstrom staff visited factory to determine progress. 3/6/2007 Nordstrom staff visited factory to determine progress. Factory has developed pocket-size handbook of code elements and factory guidelines. All workers receive the handbook upon employment at the factory. Management has been trained on code guidelines and is responsible for training the workers they support.

Posted code was found in both English and Hindi (Local language) on main gate and canteen.

Factory must educate the workers about Code elements, factory policies and procedures and Nordstrom's Code of Conduct. Post the Code elements and Nordstrom Conduct poster in a prominent location in the factory. Conduct a training to review codes and with all workers in the factory. Document the date and time of this training and keep a participant list of who attended. Workers must be informed about the workplace standards orally and through the posting of standards in a prominent place (in the local languages spoken by employees and managers) and undertake other efforts to educate employees about the standards on a regular basis. In order to ensure there is a secure communications channel, please ensure workers are aware of name and address of Nordstrom as listed on the Code Poster in the factory. Please also ensure they are aware of **Nordstrom's agent** and have a contact name. Please make sure this is provided in a manner appropriate to the culture and situation, to enable employees to report to Nordstrom or **Nordstrom's agent** on noncompliance with the workplace standards, with security that they shall not be punished or prejudiced for doing so.

4/1/2006

4/1/2006

During interview it was noted that Code Element still was not communicated to both workers and Management staff. No such books have been issued as per workers interview. Training records are also not maintained.

4/1/2006

4/1/2006 photo of contact info posted for workers

3/8/2006

1/18/2007 Third Party Re-audit: Complete.

3/6/2007 Nordstrom staff visit confirmed contact name and phone number provided.

It was again noted that none of the employees were aware of the local contact number. No local numbers were displayed below the code on the day of the audit. Management was also not aware of the reason for not providing the local contact number/address.

11

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up) 4/1/2006 1) Copies of job applications and factory procedures for maintaining employee records.

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

1. Employers will maintain sufficient hiring and employment records to demonstrate and verify compliance with this Code provision. 2. Factory must maintain sufficient hiring and employment records for casual workers to demonstrate and verify compliance with this Code provision.

4/1/2006

3/8/2006 1) copies of job applications now on file.

1/18/2007 Third Party re-audit found issue still pending.

7/11/06 Nordstrom staff visited factory to determine progress. 3/6/2007 Company has requested that factory research and explore options to address issues surrounding casual workers.

It was noted that factory has not employed any casual workers on the day of the audit. All the reviewed personnel files were found having all necessary legal documents.

Employers will maintain proof of age documentation for all workers, such as a birth certificate, which verifies date of birth. Copies should be kept in each worker file.

4/1/2006

1/18/2007 Third Party re-audit found issue still pending.

7/11/06 Nordstrom staff visited factory to determine progress. 3/6/2007 Company has requested that factory research and explore options to address issues surrounding casual workers.

It was noted that factory has not employed any casual workers on the day of the audit. All the reviewed personnel files were found with all necessary legal documents.

Please create and establish this Sexual Harassment Committee. Please ensure your Sexual Harassment Policy is posted in the factory for worker review and all workers are aware. This policy and committee should cover such facts as: employers shall not offer preferential work assignments or other preferential treatment of any kind in actual or implied exchange for a sexual relationship, nor subject employees to prejudicial treatment of any kind in retaliation for refused sexual advances

4/1/2006

4/1/2006 Committee meeting schedule, participant list, and meeting notes.

3/8/2006 Received photos of Committee postings. Requested more information.

1/18/2007 Third Party Re-audit found issue still pending.

7/11/06 Nordstrom staff visited factory to determine progress 3/6/2007 Nordstrom staff visited factory to determine progress. Factory has developed pocket-size handbook of code elements and factory guidelines. All workers receive the handbook upon employment at the factory. Management has been trained on code guidelines and is responsible for training the workers they support.

As per workers interview it was noted that none of the workers were aware of the sexual harassment committee. Moreover no such handbooks were issued to any of the workers interviewed. However as per management statement, they have made this committee but no records produced on the day of audit.

Please provide training to managers and supervisors in appropriate disciplinary practices. Document this training.

4/1/2006

7/11/06 Nordstrom staff visited factory to determine progress. 3/6/2007 Nordstrom staff visited factory to determine progress. Factory has developed pocket-size handbook of code elements and factory guidelines. All workers receive the handbook upon employment at the factory. Management has been trained on code guidelines and is responsible for training the workers they support.

As per management & supervisors interview it was noted that factory has provided training on disciplinary practices. However the training records were not maintained. Hence we couldn‟t verify the authenticity of the aforesaid statement.

12

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up)

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

Factory should not unreasonably restrain freedom of movement of workers, including movement in canteen, during breaks, using toilets, accessing water, or to access necessary medical attention. Please advise why workers need to obtain a gate pass to exit for lunch.

4/1/2006

1/18/2007 Third Party Re-audit found issue still pending.

7/11/06 Nordstrom staff visited factory to determine progress. Contracting with 3rd Party was decided to ensure root causes are addressed. 3/6/2007 Nordstrom staff visited factory and expressed importance of Freedom of Movement. Factory's intentions are to protect women workers from the dangerous area around the factory. Factory agreed to change policy to allow all workers free movement and will conduct trainings to women workers on safety.

As per management they have stopped this practice for the workers and it was also cross verified during workers interview. All interviewed workers reported that they have full freedom of movement except to the restricted zones.

1. Exit signs must be marked and visible up to 100 feet. Work floors must be clearly marked with emergency lines. 2. An evacuation plan must be posted in a prominent location that is accessible to workers indicating the best means of exiting in an emergency situation and locations of fire extinguishers. 3-6. Workers must have enough space between work stations to allow for free body movement that provides adequate room for emergency evacuation. Secondary aisle ways must allow for 1 worker to comfortably walk (36 inches or 1 meter). 7. There must be at least two unlocked and accessible emergency exits on each floor and in each facility.

4/1/2006

1/18/2007 Third Party Re-audit found issue still pending.

3/6/2007 Nordstrom staff visit found that factory intends to include a new factory to address issues of congestion.

It was noted during factory tour that, 1. Evacuation signs were found clear however aisles were found blocked / congested in Maximum production areas. 2. Evacuation plans in work areas still have discrepancies. Do not entirely match with the floor layout. 3. Sewing halls are still congested. Space between two work stations in some places was as little as 12 to 15 inches. However there were no instances of workers working together at the same work-station noticed. 4. Rear horizontal aisle in the sewing hall in the basement is still found narrow. However no standing workers on work-stations were seen on the passage. Side aisle in production hall in the basement and on ground floor and another in the training section on the terrace are still narrow – 16 to 24 inches width. 5. Some sewing operators still had blocked their access to passage with bins. 6. Still aisle in the cutting section / stitching sections of all floors were found blocked by fabric bundles, tables 7. Store still has only one exit, however there were only 3 persons found working on the day of audit and as per law requirement it was in compliance. 8. Still the passage at the fabric laying table near the wall in the cutting section in the basement is narrow and restricts free movement and still partially blocked with fabrics.

13

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up) photos requested

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

9. Aisle ways must be clear at all times in order to create a safe evacuation path. 10. Exit signs must be marked and visible up to 100 feet. 11. Work floors must be clearly marked with emergency lines. 12.There must be at least two unlocked and accessible emergency exits on each floor and in each facility. An evacuation plan must be posted in a prominent location that is accessible to workers indicating the best means of exiting in an emergency situation and locations of fire extinguishers. 13-14. Workers must have enough space between work stations to allow for free body movement that provides adequate room for emergency evacuation. Secondary aisle ways must allow for 1 worker to comfortably walk (36 inches or 1 meter). 15. Please organize storage areas so no scraps are laying on the floor, obstructing walk ways. Ensure cover of drain is repaired to avoid injury.

3/8/2006 (9&11) Photos of marked clear aisles provided.

01/19/2007 Third Party re-audit: 9) Pending 10) Pending 11) Complete 12) Pending 13) Complete 14) Complete 15) Pending

It was noted that 9. Aisles were still seen blocked with heaps of garments in production areas. 10. Canteen still does not have an Emergency exit at the opposite end. 11. Emergency lights on stair-case landing were found with high-beam type with battery back-up. Also emergency lights were installed on exits at the production hall on first floor. 12.„Keep clear‟ yellow boxes are still not marked in front of exits at the production hall on first floor. 13. Fusing machine area in the cutting section in the basement is still congested with little room for movement. 14. A sewing station in the finishing section in the basement still had the operator blocked on both sides with finished piece cartons. However no Wires of the machine were found across the passage. 15. New cartons and hanger storage shed on the ground floor is found organized. There was no wood work found in the factory.

During the factory tour it was noted that, 1. Exit door in second floor canteen side was opening inward. 2. Fire fighting drills were not conducted as often once in every three months as per factory rules. The last drill was conducted on 26. June 2007. Management informed that due to busy schedule and management reshuffling it was missed. However committed to carry on as required. 3. Nobody in factory had trained for fire safety training from outside competent agency. However, 50% workers were aware of the use of fire extinguishers and fire equipments. But they were not aware of complete procedures for fire safety in case of fire.

1. Please ensure distilled water is available along with eye-wash cups in first aid kits at all times. 2. Fire extinguishers must be clear or obstruction within 3x3 foot (1x1 meter) radius. 3-4. Fire equipment must be within 75 feet (23 meters) of each employee. All rooms with combustible materials must have fire equipment. This includes laundry and kitchen areas.

4/1/2006

01/19/2007 Third Party re-audit: 1) Complete 2) Complete 3) Pending 4) Complete

1. First-aid boxes have eye-wash cups but still no eyewash/distilled water. (Floating fabric dust particles were seen in work areas.) further more unidentified medicines were found in the first aid boxes. 2. No fire extinguishers were found blocked in any of the departments. 3. Adequate fire extinguishers were found installed in the area near the laundry where boilers and diesel storage tank are installed. 4 Factory has provided fire extinguishers for the Kitchen area on the first floor.

1-4. Workers shall wear appropriate protective equipment (such as gloves, eye protection, hearing protection, respiratory protection, etc.) to prevent unsafe exposure (such as inhalation or contact with solvent vapors, noise, dust, etc.) to hazardous elements including medical waste.

4/1/2006

Nordstrom is contracting with 3rd party to engage in a dialogue with the management to understand the pending issues and problems the factory is facing. Consulting activities to launch in September 2006.

7/11/06 Nordstrom staff visited factory to determine progress. Contracting with 3rd party was decided to ensure root causes are addressed.

1 It was noted that operators on over-lock operations were provided adequate PPE's, however no PPE's were provided to spotters. 2. Personal protective gear and material safety data sheets were found provided and used at the stain removing areas in the finishing section in the basement and on first floor. 3. Band knife operator in the cutting section found using appropriate PPE's on the day of audit. 4. Ear muffs were found provided for use by the generator operator in the generator area inside which the decibel level is in excess of 100 dbs. New findings (if noted): Nothing to report

14

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up)

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

1-4. All chemicals and hazardous substances should be properly labeled and stored in accordance with applicable laws. Workers should receive training, appropriate to their job responsibilities, in the safe use of chemicals and other hazardous substances

4/1/2006

1/19/2007 Third Party re-audit: 1) Pending 2) Pending 3) Complete 4) Pending

1. No containers of hazardous chemicals were found laying on the floor. 2. No cans of machine oil were seen kept in the open area on the terrace. 3. Diesels were found stored appropriately on the floor. Also „No Smoking‟ signs were found installed. 4.Still stain removing stations in finishing areas do not have exhaust pipes for discharging exhaust fumes outside the work area, further more spotting was found being done in the middle of production..

Eyewash station was not provided near chemical room although hazardous chemicals like acetic acids, soda, acetone etc. were used by factory.

1. All ventilation, plumbing, electrical, and lighting services shall be provided and maintained to conform to applicable laws and prevent hazardous conditions to employees in the facility. 2. Work stations must have adequate lighting. 3-5. All ventilation, plumbing, electrical, and lighting services shall be provided and maintained to conform to applicable laws and prevent hazardous conditions to employees in the facility. 6-7. Please keep work floors clean, discard trash in distribution panel room. Keep areas clean in order to maintain safety. Clean cooling vents in cutting sections in basement to ensure proper ventilation.

4/1/2006

01/19/2007 Third Party Re-audit: 1) Pending 2) Pending 3) Pending 4) Pending 5) Complete 6) Complete 7) Complete.

3/6/2007 Nordstrom staff visit revealed more action has been taken regarding loose wires and exposed wires.

1. During factory tour it was noted that all electrical wirings were properly fenced. No open/loose wiring found on day of audit. 2. Lighting at needle point on all the sewing machines were measured adequate found more than 300 -400 lux. 3. All the wirings were found properly grounded in sewing section 4. On the day of audit nowhere water seepage on walls were found in any area of factory. 5. All the electrical wiring junction boxes were seen properly covered in all area of the factory 6. During the factory tour it was noted that the factory building, work area, toilets etc. were very neat and clean. 7. No junk nor discarded tube lights were seen lying anywhere in the factory on the day of audit.

8. Please repair the water down pipe leak. Please clean up all food waste in washing area of canteen. This ensures proper health and safety standards are maintained in the food preparation areas.

8. Factory has taken corrective measures for the identified leakage in the drain pipe from the terrace at the canteen to the drain on the ground floor and nowhere any food waste was found in the factory.

Factory has not obtained permit for diesel generators installed in the factory.

15

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up)

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

1. Please ensure all sewing machines have pedal mats 2. All production machinery and equipment shall be maintained, properly guarded, and operated in a safe manner. Please fence in boiler, insulate steam pipe lines in finishing section to avoid injuries to workers. 3. Tagging guns should be individually labeled (in order to prevent infectious diseases) and should not be shared.

4/1/2006

1/19/2007 Third Party Re-audit: 1) Pending 2) Complete 3) Complete

1. All the sewing machines were provided with rubber pedal mats. 2. During factory tour it was noted that boiler installed in the finishing area in the basement was still not fenced. Steampipe lines in finishing sections were also not insulated and could cause burn injuries. 3. During factory tour it was noted that tag gun used in the finishing section on first floor did not have the name of the user to ensure personalized usage.

1. Please replace floor tiles to ensure safety and compliance with applicable laws. 2. All facilities including factory buildings, toilets, canteens, kitchens, and clinics, must be kept clean and safe and be in compliance with applicable laws. Please provide a schedule showing dates and time all toilets are cleaned. This should occur at least 2 times per day with supplies restocked.

4/1/2006

4/1/2006 photos of improvemen ts requested

3/8/2006 1) Photos received showing broken tiles have been repaired. 2) Digital copy of cleaning schedule provided. Cleaning schedule is both written and pictorial

1. Factory has replaced all the broken floor tiles in all area of the factory. 2. On the day of audit, all the toilets were found neat and clean. Factory has made a policy and made aware of not using any tobacco etc. inside the factory premises and closely monitored it. All the toilets were provided with appropriate elements such as soap, towel etc. All the flushes were found working properly. 3. Waste fabric room located near workers toilet blocks on the ground floor was found organized and the identified manhole covered properly. 4. On the day of audit no such packaging waste was found in or near the canteen area. Management informed they had made a separate area for dump storage.

5. Please cover all foods and organize so insects or vermin do not tamper with food

1/19/07 Third Party Reaudit: Complete

5. On the day of audit all the items in canteen found kept covered and maintain in hygienic condition.

1. Please construct roof for canteen. 2. Please cover all foods and organize so insects or vermin do not tamper with food 3. Please ensure workers serving or handling food wear proper masks and gloves for hygiene and health reasons

4/1/2006

1/19/07 Third Party Reaudit: 1) Complete. 2) Complete 3) Pending

3/6/07 Nordstrom staff visit confirmed 3) canteen workers using disposable gloves.

1. The canteen on the terrace was found covered by roof appropriately. 2. All items were appropriately stored in canteen. 3. All canteen workers were found using appropriate PPEs while serving food items, observed on the day of audit.

Factory has not tested periodically drinking water to ensure whether it was potable. However, water was tested on 29 May 2006.

16

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up)

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

Creche was found near production area as it was not separated from production. Furthermore, factory has not appointed any care taker in creche. However, as per workers interview, no female workers were interested to carry their babies. Management also informed that since no females were carrying their babies, they have not appointed any care taker in creche. Inadequate facilities were found in creche on the day of audit. Facilities such as washroom were not provided. Factory had only provided one bed in creche.

3. No welfare officer was found in the factory although factory had employed more than 500 workers. As per factory management, welfare officer had resigned since last week and they were in process of appointing a new welfare officer in the factory very soon. Spotters were not medically examined.

1. Engage workers in health and safety committees and ensure workers are aware of committee's function and participants. 2. Ensure workers are selected by their peers. 3. Factory to workers and management are aware of the intended function of the committee. Post additional material about the committee around the factory.

01/19/2007 Third Party Re-audit did not confirm that this was addressed. Further follow up is required.

Workers in this committee were still nominated by the management and not elected as required by law, verified through management interview, workers interview and works committee minutes review. Further more factory have not posted any additional information about the committee and it‟s function, not making the workers aware about it.

Please explain more about the INR 225 transportation fees charged to all workers. Why is this mandatory? Workers who use the transportation should pay for it, but others that reside nearby should not have to pay for transportation they do not use. Please provide more detail regarding this issue for our full understanding.

4/1/2006

4/1/2006 wage records

Factory must provide workers a pay statement each pay period, which will show earned wages, regular and overtime pay, bonuses and all deductions

4/1/2006

4/1/2006 copies of wage slips

3/8/2006 Received copies of wage records showing transportation fee is no longer deducted from all workers wages. Correction of this issue will be further followed up by 3rd party interviews of workers. 3/8/2006 Copies of wage slips provided for overtime and for casual workers which list earned wages, regular and overtime pay, bonuses and all deductions.

01/19/2007 Third Party Re-audit: Complete

During workers interview, management interview it was noted that factory had provided transportation facility to the workers. INR 150 to INR 225 was deducted from workers; but it was 100% optional and based on the distance and route. Furthermore, workers stated that they benefitted from this service as public transportation was more costly than that provided by factory. Workers were happy with this facility. Workers also confirmed that this facility is not compulsory for those workers who are staying near by the factory premises..

01/19/2007 Third Party Re-audit: Complete

During interview it was noted that pay slips were still not provided to workers. Management agreed that contracted workers were not provided pays lips. No piece rated / casual workers were found working in the factory.

17

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up)

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

Time worked by all employees, regardless of compensation system, must be documented by time cards or other accurate and reliable recording systems such as electronic swipe cards. This must be kept at the factory for review.

4/1/2006

01/19/2007 Third Party Re-audit: Complete

During the factory tour and through Management interview it was noted that, 1. No casual workers were employed in the factory. As per factory they have stopped recruiting casual workers. Factory has produced all the time records for all the workers including contract workers. 2. As per factory they have stopped maintaining 2 sets of records and all hours of work were recorded as per actual working. As per provided time records and through workers interview it was noted that factory provided records are correct.

All compensation records must be maintained accurately and must be acknowledged and verified by the workers as accurate.

4/1/2006

01/19/2007 Third Party Re-audit: Pending

3/6/2007 Company has requested that factory research and explore options to address issues surrounding casual workers. Factory to provide insight by June 2007.

Payment records of all contracted workers were available for verification for all hours, days and months of work for months preceding September 2007. However, pay and time records for months of September and October 2007 were not available for verification. As per factory they have stopped employing casual workers after initial audit. In absence of records for two months (September & October), compliance to sections like wages and benefits and exact hours of work could not be verified completely.

Factory must provide all legally mandated benefits to all eligible workers immediately. This includes permanent and casual workers.

4/1/2006

01/19/2007 Third Party Re-audit: Pending

3/6/2007 Company has requested that factory research and explore options to address issues surrounding casual workers. Factory to provide insight by June 2007.

No casual workers were employed by factory. Factory used contracted workers through contractors only and their time, wage records were available for verification for months preceding September 2007. However, pay and time records for months September and October 2007 were not available for verification. As per available records, all eligible workers were provided all the legal social benefits such as provident fund and employees state insurance scheme. this was crossverified through workers interview.

01/19/2007 Third Party Re-audit: Pending

3/6/2007 Company has requested that factory research and explore options to address issues surrounding casual workers. Factory to provide insight by June 2007.

1. No casual workers were employed by factory. Factory used contracted workers through contractors only and their time, leave records were available for verification. 2. During the document review it was noted that earned leave was not accumulated over 30 days only as per law. All the employees were provided leaves as per law. This was also Cross-verified through workers interview.

All compensation shall be paid in a timely manner. Why are wages being paid after the 7th day of each month? Please provide more detail and ensure all workers are provided their pay no later than the 7th day of the month.

4/1/2006

01/19/2007 Third Party Re-audit: Complete

3/6/2007 Visit by Nordstrom staff witnessed payment of wages.

All the workers working in the factory were employed on monthly rate basis. Factory has stopped piece rate workers. And all workers were paid on or before 7th day of every next pay period which was in compliance with law. Also it was Cross-verified through workers interview. However, this issue could not be verified completely due to unavailability of time and wage records for months September and October 2007.

18

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up)

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

1-4. Except for peak production times and extraordinary the factory workers will (i) not be required to work more than the lesser of (a) 48 hours per week and 12 hours overtime or (b) the limits on regular and overtime hours allowed by the law of the country of manufacture or, where the laws of such country will not limit the hours of work, the regular work week in such country plus 12 hours overtime; and (ii) be entitled to at least one day off in every seven day period. An extraordinary business circumstance is a temporary period of extra work that could not have been anticipated or alleviated by other reasonable efforts. Please advise why there has been excessive overtime hours and what the factory plans to do to reduce these to be within legal limits. Employees must be allowed one day off in seven. This means after 6 consecutive days worked all workers must be given 24 hours of uninterrupted time of rest (1 full day). All workers must receive this regardless of peak production periods.

4/1/2006

1/18/2007 Third Party Re-audit found issues still pending.

3/6/2007 Nordstrom staff visited and was advised that factory plans to move some production to new factory to alleviate the strains on factory.

1. Compliance to overtime hours could not be verified for all workers due to time and wage records of all workers for the month of September and October 2007 were not available for verification. As per management, these records were gone for audit to their head office. However, from records review for months preceding September 2007 showed that factory has done overtime within the legal limits. 2. Compliance to provision of weekly rest could not be verified for all workers due to time and wage records of all workers for the month of September and October 2007 were not available for verification. However, from records review for months preceding September 2007 showed that factory has not worked on any weekly rest days.

3-4. Compliance to intervals of rest could not be verified for all workers due to time records of all workers for the month of September and October 2007 were not available for verification. As per management, these records were gone for audit to their head office. However, from records review for months preceding September 2007 showed that factory has done overtime within the legal limits and rest period provided was as per law. This was also cross-verified through workers interview.

Compliance to overtime hours (on regular and weekly off) and payments and benefits made thereafter could not be verified for all workers due to time and wage records of all workers for the month of September and October 2007 were not available for verification. As per management, these records were gone for audit to their head office. However, from records review for months preceding September 2007 showed that factory has done overtime within the legal limits.

19

PC Remediation plan

Remediation Target Completion Date

Company Documentati follow up on (Cite date of follow up)

Updates (3/8/2006) Company Documentation Follow up (3/8/2006)

Third-Party Verification (Contracted External Verification Documentation (1/18/2007)

Company Verification Follow up Company Follow up (7/11/06 and Documentation 3/6/2007)

Third-Party Verification Independent External Verification (Cite Date of Verification) 21 November 2007

Please obtain updated license and have it available for view at the factory.

4/1/2006

01/19/2007 Third Party Re-audit revealed issue still pending.

3/6/2007 Nordstrom staff visited. Factory confirmed all licenses to be available for review by end of May 2007.

License to provide workers to this factory through an Agent ******* expired on Aug 31, 2006. Contractor had still not obtained renewed license from concerned legal authority.

Mandatory acts such as abstracts of the minimum wages act, 1948; The payment of wages act, 1936; The factories act 1948; The maternity benefit act, 1961; pay day, factory timing, holiday list were not displayed in the factory. Factory has even not displayed revised rate of minimum wages (effective from 1st October 2007) in the factory. Old minimum wage notification was displayed in the factory. Moreover, workers were not aware of the revised rate of minimum wages fixed, revised and notified by state government.

20

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

Visual observation of Code and interview with workers.

Issue Completed

FLA Re-audit Verification

Workers & Management interview.

Factory must educate the workers and Pending Management Staff about Code elements, factory policies and procedures and Nordstrom's Code of Conduct. Post the Code elements and Nordstrom Conduct poster in a prominent location in the factory. Conduct a training to review codes and with all workers in the factory. Document the date and time of this training and keep a participant list of who attended. Workers must be informed about the workplace standards orally and through the posting of standards in a prominent place (in the local languages spoken by employees and managers) and undertake other efforts to educate employees about the standards on a regular basis.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

Visual observation of Code and Workers interview

Nordstrom is researching secure communication channels to provide a local contact number for workers to utilize. In the meantime, a phone number is listed on the Code of Conduct poster for the Nordstrom Social Responsibility Headquarters in the USA.

Pending

5/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

21

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

Personnel files review, management Issue Completed interview, worker interviews for old as well as newly recruited workers.

FLA re-audit verification

Personnel files review, workers interview. legal documents such as age proof documents mostly in the form of doctor‟s certificate (Dental) and school certificate.

Issue Completed

FLA re-audit verification

Workers interview, management interview.

Create and establish Sexual Harassment Committee. Educate and train all workers about the Sexual Harassment Committee and harassment policies. Create handbooks and distribute to workers that include the policy and committee details such as: employers shall not offer preferential work assignments or other preferential treatment of any kind in actual or implied exchange for a sexual relationship, nor subject employees to prejudicial treatment of any kind in retaliation for refused sexual advances, conduct training on disciplinary practices and documents and maintain training records, attendance sheets in a file at the factory for review. Conduct training on disciplinary practices and document and maintain training records, attendance sheets on file at the factory for review.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

Interviews of management and workers, also reviewed document such as factory‟s disciplinary policy and standing order review.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

22

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

Workers interview, management Issue Completed interview. Gate pass issuing system review and security interview.

FLA Re-audit Verification

FLA Re-audit Verification No issues reported

During factory tour it was noted.

1. Rearrange aisles so no exits are blocked. 2. Ensure evacuation plans match the area it represents by matching number of exits, listing the fire extinguisher location, indicating a "you are here" icon so people can find the closest exit to them. 3. Space between sewing hall work stations needs to be arranged to provide more than 15 inches of space. 4. Please expand rear horizontal aisle in the sewing hall in the basement. Please expand side aisle in production hall in the basement on ground floor, and training section on the terrace are still narrow more than 24 inches width. 5. Ensure all sewing operators access passages are clear from debris and bins. 6. Clear aisles in cutting section / stitching sections of all floors of all fabric, tables and debris. 7. Please add an additional exit to the Store 8. Clear and widen the passage at fabric laying table near wall in the cutting section of basement.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

23

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

During factory tour it was noted.

9. Unblock aisles and properly store garments in production areas. 10. Add an emergency exit at opposite end of Canteen and ensure door opens outwards. 12. Mark „Keep clear‟ yellow boxes in front of exits at the production hall on first floor. 13. Expand Fusing machine area space in the cutting section in basement to provide more room for movement. 14. Clear finished piece cartons from both sides of sewing station in the finishing section in basement so operator is not blocked in.

Document review, workers interview 1. Change or replace exit door in second and management interview. floor canteen side to open outward. 2. Conduct fire fighting drills once in every three months as per factory rules. Have first drill conducted in 2008 by March 2008. 3. Fire safety training must be conducted by an outside competent agency by March 2008. This training should include use of fire extinguishers, fire equipments and complete procedures for fire safety in case of fire.

During factory tour it was noted.

1. Restock First-aid boxes with eyewash/distilled water. Identify and label medicines in the first aid boxes which should only be for burns, cuts, scrapes, indigestions or other minimal ailments.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

During factory tour it was noted.

1. Provide proper PPE's provided to spotters immediately.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

24

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

During factory tour it was noted.

4. Install exhaust pipes in stain removing stations for discharging of exhaust fumes outside of the work area. Spotting must only be done in the spotting stations. No spotting should occur in the middle of production so workers are not exposed to harmful, toxic chemical fumes.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

factory tour

During factory tour it was noted.

Install eyewash station near chemical room. Eyewash station should have 2 spigots turned upwards to easily flush out eyes and have water that runs continuously for at least 15 minutes. Issues Completed

FLA Re-audit Verification

Document review & management interview

Obtain permit for diesel generators installed in the factory.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

25

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

During factory tour it was noted.

2. Fence in boiler area and insulate steampipe lines in finishing section to prevent injuries and accidents. 3. Please list the name of the user on tagging gun for accident injury medical purposes.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

During factory tour it was noted.

Issues Completed

FLA Re-audit Verification

During factory tour it was noted.

Issues Completed

FLA Re-audit Verification

Document review and Management interview.

Have water tested immediately to ensure water is potable. Water should be tested at a minimum of once per year.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

26

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

factory tour , Management interview Creche must be moved and separated from & Workers interview production area. Factory must appoint a care taker in creche. The Creche must have adequate facilities such as a washroom and multiple beds. Noted no women are carrying babies and state they do not want to use the creche. However, the factory must be able to prove that workers would still not want to use the creche if all proper improvements were made. Factory must get actual statements from workers in writing that they do not want to use the creche, even if it were properly run and maintained. Management interview, Workers interview Hire new welfare officer as soon as possible. Advise as soon as this has occurred.

3/1/2008

3/1/2008

Management and workers interview. Spotters must be medically examined immediately to ensure they are healthy.

3/1/2008

Works committee minutes document review and workers and management interview

workers interview and management interview, records review

Issues Completed

FLA Re-audit Verification

Pay records review, workers Pay slips must be provided to all workers interview and management interview starting immediately.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

27

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

Pay records review, workers Issues Completed interview and management interview

FLA Re-audit Verification

Pay and time records review, management interview

All records should be maintained at the factory for 12 months. This ensures all working hours, rest days, wages and benefits can be verified.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly. Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly. FLA Re-audit Verification

Payment records review, All records should be maintained at the management and workers interview. factory for 12 months. This ensures all working hours, rest days, wages and benefits can be verified.

3/1/2008

Payment, records, time records, PF records, ESI records, workers interview and management interview.

Issues Completed

Payment, records, time records, workers interview and management interview.

All records should be maintained at the factory for 12 months. This ensures all working hours, rest days and wages can be verified.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

28

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

time records, wage records, management and workers interview

All records should be maintained at the factory for 12 months. This ensures all working hours, rest days and wages can be verified.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

Time records, wage records, management and workers interview

All records should be maintained at the factory for 12 months. This ensures all working hours, rest days and rest day intervals can be verified.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

29

Third-Party Verification Documentation

Remediation (11/21/07) Company Documentation PC Remediation plan (11/21/07 re-audit) Target Completion Date follow up (Cite date of follow up)

Updates 8/22/08 Documentation Company Follow up (8/22/2008)

Contract License review

Contractor must obtain renewed license from concerned legal authority as soon as possible.

3/1/2008

Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly. Nordstrom now has regretfully ceased efforts due to the termination of business relationships between the agent, factory, and Nordstrom. Due to the termination of business relationships, the company's leverage for implementing remediation has diminished completely. For further comment, please contact Nordstrom directly.

It was noted during factory tour, workers interview.

Post all updated government rules, laws, mandatory acts and factory regulations in the factory for review of all workers. Educate the workers of revised minimum wage rates

3/1/2008

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