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									FLA Audit Profile
Country                                                              USA
Factory name                                                         170082653F
IEM                                                                  Accordia Global Compliance Group
Date(s) in facility                                                  August 21, 2007
PC(s)                                                                Herff Jones Inc.
Number of workers                                                    68
Product(s)                                                           Fine Paper Products - Diplomas, Announcements
Production processes                                                 Cutting, Printing, Engraving, Assembly, Shipping


FLA Code/Benchmark                                                   compliance status             If noncompliant, risk of non compliance or          Sources/Documentation used for reference   Notable Features implemented by Factory
                                                                                                   uncorroborated - explain why                        (ref country law) and corroborating        Management or Company




1. Code Awareness
GEN 1: Establish and articulate clear, written workplace standards. non compliance                 FLA workplace Code of Conduct was found posted Management interviews/document
Formally convey those standards to Company factories as well as                                    in the worker's lunch area. No formal           review
to licensees, contractors and suppliers.                                                           communication between Corporate office and this
                                                                                                   facility was evident.

GEN 2 Ensure that all Company factories as well as contractors       non compliance                No training or code awareness conducted on          Management and worker interviews
and suppliers inform their employees about the workplace                                           Company Obligations at this facility according to
standards orally and through the posting of standards in a                                         the management interviews
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.

GEN 3 Develop a secure communications channel, in a manner           non compliance                Workers were not aware of any communication         Worker interviews/management
appropriate to the culture and situation, to enable Company                                        channel that exists to report non-compliance to     interviews
employees and employees of contractors and suppliers to report to                                  the Standard in a confidential manner.
the Company on noncompliance with the workplace standards, with
security that they shall not be punished or prejudiced for doing so.

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


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.
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.




                                                                                                                                                                                                                                            1
FLA Code/Benchmark                                                        compliance status   If noncompliant, risk of non compliance or          Sources/Documentation used for reference   Notable Features implemented by Factory
                                                                                              uncorroborated - explain why                        (ref country law) and corroborating        Management or Company




H&A2 Discipline/Progressive Discipline                                    non compliance      The factory's policy on discipline is addressed in Employee Manual/Worker Interviews
                                                                                              the Employee Handbook under the section of
                                                                                              attendance. The policy addresses absences and
                                                                                              tardiness and provides for suspension or
                                                                                              termination. The statement is made "We will
                                                                                              enforce a progressive disciplinary schedule for
                                                                                              excessive tardiness" however, this practice is not
                                                                                              applicable according to published documentation
                                                                                              for other disciplinary actions. The monitor is of
                                                                                              the opinion that the company should improve and
                                                                                              expand on its disciplinary system to include not
                                                                                              only attendance and tardiness but other types of
                                                                                              corrective action. Disciplinary actions should be
                                                                                              progressive in nature and communicated to
                                                                                              workers.

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
H&S9 Evacuation Requirements and Procedure                                non compliance      Main aisles are demarcated with yellow/black floor Observation of work place
                                                                                              tape to designate passageways. In aisles along
                                                                                              the designated evacuation routes (i.e. adjacent to
                                                                                              shipping department, aisle separating cutting area
                                                                                              from packing area) various materials were found
                                                                                              that encroach into the aisle. Specifically of
                                                                                              concern were wooden pallets that are stacked
                                                                                              upright, leaning against walls (three and four at a
                                                                                              time) that may present a hazard to workers in the
                                                                                              event of an emergency evacuation or normal
                                                                                              passage if the pallets were to be disturbed. Pallets
                                                                                              may fall and cause injury to workers or entirely
                                                                                              block the passageway. Pallets should be stored
                                                                                              flat on the floor surface.
H&S10 Safety Equipment and First Aid Training                             non compliance      Fire extinguishers were found to be out of          Observation of work place
                                                                                              inspection for over one year. Management
                                                                                              indicated that they have received quotations and
                                                                                              approval for replacing all units in the facility.




                                                                                                                                                                                                                                       2
FLA Code/Benchmark                                                     compliance status   If noncompliant, risk of non compliance or          Sources/Documentation used for reference   Notable Features implemented by Factory
                                                                                           uncorroborated - explain why                        (ref country law) and corroborating        Management or Company




Other                                                                  non compliance      There is a small, stand-alone flammable storage      Observation of work place
                                                                                           unit on the exterior of the building adjacent to the
                                                                                           shipping docks that is used for storage of full and
                                                                                           empty LP Gas cylinders (used by fork trucks). A
                                                                                           garbage dumpster is located in close proximity to
                                                                                           the storage unit. The monitor observed that the
                                                                                           storage unit does not have any signage to indicate
                                                                                           contents are flammable nor is there a "No
                                                                                           Smoking" sign or a fire extinguisher within 10 feet.
                                                                                           Fire extinguisher should be located near the
                                                                                           structure to handle any sources of ignition.


7. Freedom of Association and Collective Bargaining
Employers will recognize and respect the right of employees to
freedom of association and collective bargaining
FoA.24 Grievance Procedure                                             non compliance      There is no grievance procedure found in the        Worker and management interviews -
                                                                                           factory                                             document review
8. Wages and Benefits/Overtime
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
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

HoW.5      Time-recording System                                       non compliance      Time recording system has not been operational      Management and worker interviews
                                                                                           for a period of 3 to 8 weeks




                                                                                                                                                                                                                                    3
FLA Audit Profile
Country                                                  USA
Factory name                                             170082586F
IEM                                                      Accordia Global Compliance Group
Date(s) in facility                                      8/21/2007
PC(s)                                                    Herff Jones Inc.
Number of workers                                        68
Product(s)                                               Fine Paper Products - Diplomas, Announcements
Production processes                                     Cutting, Printing, Engraving, Assembly, Shipping

                                                         Compliance                                                                                                                   Remediation
1. Code Awareness                                        Status              Description of noncompliance, risk of PC Internal      PC Remediation plan                         Target Completion Factory Response (Optional)            Company follow
                                                                             noncompliance or uncorroborated       audit findings                                               Date                                                     up (Cite date of
                                                                             evidence of noncompliance             (Optional)                                                                                                            follow up)


GEN 1: Establish and articulate clear, written workplace non compliance      FLA workplace Code of Conduct was                      Plant Manager received notification from    Dec 1, 08
standards. Formally convey those standards to                                found posted in the worker's lunch                     Corporate Licensing Administrator dated
                                                                                                                                    7/26/06.
Company factories as well as to licensees, contractors                       area. No formal communication
and suppliers.                                                               between Corporate office and this
                                                                             facility was evident.

GEN 2 Ensure that all Company factories as well as         non compliance    No training or code awareness                          FLA Code of Conduct is posted in the        Jul 30, 08
contractors and suppliers inform their employees about                       conducted on Company Obligations                       employee lunch area (Official Company
                                                                                                                                    Bulletin Board). In addition, FLA standards
the workplace standards orally and through the posting                       at this facility according to the
                                                                                                                                    will be reviewed with employees during
of standards in a prominent place (in the local languages                    management interviews                                  departmental meetings.
spoken by employees and managers) and undertake
other efforts to educate employees about the standards
on a regular basis.
GEN 3 Develop a secure communications channel, in a non compliance           Workers were not aware of any                          As stated in the Employee Handbook, an      Jun 15, 08        An electronic suggestion box has
manner appropriate to the culture and situation, to                          communication channel that exists                      open door policy is promoted whereby                          been established, and
                                                                                                                                    employees are encouraged to                                   communicated to all employees as a
enable Company employees and employees of                                    to report non-compliance to the
                                                                                                                                    report/discuss concerns with their                            secure, non-threatening means of
contractors and suppliers to report to the Company on                        Standard in a confidential manner.                     immediate supervisor or HR Manager                            communicating to management.
noncompliance with the workplace standards, with                                                                                    without fear of reprisal. The employee may                    Management generally responds
security that they shall not be punished or prejudiced for                                                                          also request a meeting with the Director of                   back within 2 weeks. Weekly
doing so.                                                                                                                           HR. Similarily, harassment or progressive                     department meetings, and monthly
                                                                                                                                    discipline concerns may also be directed to                   plant meetings are regularly held.
                                                                                                                                    Corporate HR. Health & Safety issues may                      With regards to confidential matters
                                                                                                                                    also be raised with department safety                         or counseling, the HR Mgr. serves
                                                                                                                                    committee members (hourly employees).                         as an employee advocate, as well
                                                                                                                                                                                                  as, assures that the on-going
                                                                                                                                                                                                  communication with our employees
                                                                                                                                                                                                  supports the company's belief in
                                                                                                                                                                                                  creating an atmosphere of employee-
                                                                                                                                                                                                  ownership, and maintaining open &
                                                                                                                                                                                                  honest lines of commincation.




4. Harassment or Abuse




                                                                                                                                                                                                                                                            4
                                             Compliance                                                                                                             Remediation
1. Code Awareness                            Status           Description of noncompliance, risk of PC Internal      PC Remediation plan                      Target Completion Factory Response (Optional)               Company follow
                                                              noncompliance or uncorroborated       audit findings                                            Date                                                        up (Cite date of
                                                              evidence of noncompliance             (Optional)                                                                                                            follow up)


H&A2 Discipline/Progressive Discipline       non compliance   The factory's policy on discipline is                  As posted on the Company Bulletin Board, Jun 16, 08        For orderly and efficient operation,
                                                              addressed in the Employee                              violations of any of the Group I and Group II              and for employees' well-being, the
                                                                                                                     rules may result in progressive or                         Company established "General
                                                              Handbook under the section of
                                                                                                                     disciplinary action up to an including                     Facility Rules" which have been
                                                              attendance. The policy addresses                       discharge.                                                 distributed to all employees, as well
                                                              absences and tardiness and provides                                                                               as, posted throughout the building.
                                                              for suspension or termination. The                                                                                These guidelines provide for
                                                              statement is made "We will enforce                                                                                consistent application of our
                                                              a progressive disciplinary schedule                                                                               progressive counseling procedures.
                                                              for excessive tardiness" however,                                                                                 These guidelines have been setup to
                                                                                                                                                                                in sure all employees are treated
                                                              this practice is not applicable
                                                                                                                                                                                with respect, yet allow for some
                                                              according to published                                                                                            flexibility based upon the nature or
                                                              documentation for other disciplinary                                                                              severity of the workplace infraction.
                                                              actions. The monitor is of the                                                                                    Progressive counseling steps
                                                              opinion that the company should                                                                                   include: oral warning, written
                                                              improve and expand on its                                                                                         warning, suspension (1-day or 3-
                                                              disciplinary system to include not                                                                                day), termination. Progressive
                                                                                                                                                                                counseling situations are
                                                              only attendance and tardiness but
                                                                                                                                                                                documented using a Coaching &
                                                              other types of corrective action.                                                                                 Counseling form, that are signed and
                                                              Disciplinary actions should be                                                                                    filed. Employees have the right to
                                                              progressive in nature and                                                                                         dispute any action taken by
                                                              communicated to workers.                                                                                          contacting the HR Manager or
                                                                                                                                                                                Director of HR at any step in the
                                                                                                                                                                                process. The HR Manager monitors
                                                                                                                                                                                our progressive disciplinary
                                                                                                                                                                                procedures, inconjunction with the
                                                                                                                                                                                Plant Superintendent and Plant
                                                                                                                                                                                Manager, to help ensure consistency
                                                                                                                                                                                across the facility.




6. Health and Safety
H&S9 Evacuation Requirements and Procedure   non compliance   Main aisles are demarcated with                        Pallets have been removed.               Jun 16, 08        The safety committee monitors the
                                                              yellow/black floor tape to designate                                                                              evacuation routes, to ensure they
                                                                                                                                                                                are clear of obstructions. This is part
                                                              passageways. In aisles along the
                                                                                                                                                                                of their monthly facility walk through.
                                                              designated evacuation routes (i.e.                                                                                Any infraction is noted on their
                                                              adjacent to shipping department,                                                                                  report, and the recorded in the safety
                                                              aisle separating cutting area from                                                                                minutes. Any necessary follow-up
                                                              packing area) various materials were                                                                              action is taken or monitored by the
                                                              found that encroach into the aisle.                                                                               Plant Superintendent.
                                                              Specifically of concern were wooden
                                                              pallets that are stacked upright,
                                                              leaning against walls (three and four
                                                              at a time) that may present a hazard
                                                              to workers in the event of an
                                                              emergency evacuation or normal
                                                              passage if the pallets were to be
                                                              disturbed. Pallets may fall and cause
                                                              injury to workers or entirely block
                                                              the passageway. Pallets should be
                                                              stored flat on the floor surface.




                                                                                                                                                                                                                                             5
                                                Compliance                                                                                                                 Remediation
1. Code Awareness                               Status           Description of noncompliance, risk of PC Internal      PC Remediation plan                          Target Completion Factory Response (Optional)             Company follow
                                                                 noncompliance or uncorroborated       audit findings                                                Date                                                      up (Cite date of
                                                                 evidence of noncompliance             (Optional)                                                                                                              follow up)


H&S10 Safety Equipment and First Aid Training   non compliance   Fire extinguishers were found to be                    New fire extinquishers are in place, and     Jun 16, 08        All supervisors are trained First Aid
                                                                 out of inspection for over one year.                   routine monthly inspections are underway.                      Responders, and certified in CPR.
                                                                 Management indicated that they
                                                                 have received quotations and
                                                                 approval for replacing all units in the
                                                                 facility.
Other                                           non compliance   There is a small, stand-alone                          Signage has been added to the storage         Jun 16, 08
                                                                 flammable storage unit on the                          unit. Two fire extinquishers are located just
                                                                                                                        inside the shipping dock doors.
                                                                 exterior of the building adjacent to
                                                                 the shipping docks that is used for
                                                                 storage of full and empty LP Gas
                                                                 cylinders (used by fork trucks). A
                                                                 garbage dumpster is located in close
                                                                 proximity to the storage unit. The
                                                                 monitor observed that the storage
                                                                 unit does not have any signage to
                                                                 indicate contents are flammable nor
                                                                 is there a "No Smoking" sign or a fire
                                                                 extinguisher within 10 feet. Fire
                                                                 extinguisher should be located near
                                                                 the structure to handle any sources
                                                                 of ignition.
7. Freedom of Association and Collective
Bargaining
FoA.24 Grievance Procedure                      non compliance   There is no grievance procedure                        An Open Door Policy exists and               Jun 16, 08        Management firmly believes in
                                                                 found in the factory                                   encouraged.                                                    employees rights, and ensures that
                                                                                                                                                                                       they are treated with respect.
                                                                                                                                                                                       Employees are encouraged to take
                                                                                                                                                                                       their complaints or issues to their
                                                                                                                                                                                       immediate supervisor for resolution.
                                                                                                                                                                                       If, however, they are not satisfied
                                                                                                                                                                                       with the resolution, the issue should
                                                                                                                                                                                       be brought to the attention of the HR
                                                                                                                                                                                       Mgr. &/or Director of HR, who will
                                                                                                                                                                                       then in-turn discuss it with uppper
                                                                                                                                                                                       management and follow-up with the
                                                                                                                                                                                       employee. The Plant Manager, in
                                                                                                                                                                                       conjunction with the HR Mgr., is
                                                                                                                                                                                       ultimately responsible for ensuring
                                                                                                                                                                                       that employees means of bringing
                                                                                                                                                                                       issues to managements attention
                                                                                                                                                                                       without reprisal.



9. Hours of Work
HoW.5     Time-recording System                 non compliance   Time recording system has not been                     As mentioned, our time clocks were           Jun 16, 08        New time clocks are full functional.
                                                                 operational for a period of 3 to 8                     damaged during a lightning strike, making it
                                                                                                                        necessary to troubleshoot/purchase new
                                                                 weeks
                                                                                                                        equipment. Repair/replacement of existing
                                                                                                                        time clocks are underway.




                                                                                                                                                                                                                                                  6
FLA Audit Profile
Country                                                      USA
Factory name                                                 170082586F
IEM                                                          Accordia Global Compliance Group
Date(s) in facility                                          8/21/2007
PC(s)                                                        Herff Jones Inc.
Number of workers                                            68
Product(s)                                                   Fine Paper Products - Diplomas, Announcements
Production processes                                         Cutting, Printing, Engraving, Assembly, Shipping

                                                                      [Status]              Updates (Cite Date of Follow up)        Third-Party Verification         Company Verification Follow up
FLA Code/Benchmark                                           Completed; Pending; On-      Company Follow up Documentation      External      Documentation     Company Follow up      Documentation
                                                             going                                                             Verification                    (Cite date of planned
                                                                                                                               (Date)                          or follow up visit, if
                                                                                                                                                               appropriate)
1. Code Awareness                                            ongoing


GEN 1: Establish and articulate clear, written workplace     ongoing
standards. Formally convey those standards to
Company factories as well as to licensees, contractors
and suppliers.


GEN 2 Ensure that all Company factories as well as        Completed
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.

GEN 3 Develop a secure communications channel, in a          Completed
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.
4. Harassment or Abuse
H&A2 Discipline/Progressive Discipline                       Completed
6. Health and Safety
H&S9 Evacuation Requirements and Procedure                   Completed
H&S10 Safety Equipment and First Aid Training                Completed
Other
7. Freedom of Association and Collective Bargaining
FoA.24 Grievance Procedure                                   Completed
9. Hours of Work
HoW.5       Time-recording System                            completed




                                                                                                                                                                                                      7
                              [Status]           Updates (Cite Date of Follow up)        Third-Party Verification         Company Verification Follow up
FLA Code/Benchmark   Completed; Pending; On-   Company Follow up Documentation      External      Documentation     Company Follow up      Documentation
                     going                                                          Verification                    (Cite date of planned
                                                                                    (Date)                          or follow up visit, if
                                                                                                                    appropriate)




                                                                                                                                                           8

								
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