Workplace Discrimination Laws

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					FLA Audit Profile
Country                                                    Turkey
Name of Factory                                            400076655F
Independent External Monitoring Organization               CSCC
Date(s) in Facility                                        November 29 - 30, 2007
FLA Affiliated Compan(ies)                                 Asics
Number of Workers                                          269
Product(s)                                                 Towels & Bathrobes
Production Processes                                       Weaving, cutting, sewing, pressing, packaging & finishing

FLA Code/Benchmark                                         Compliance Status Describe noncompliance, risk of                List sources/documentation used     Cite and describe local and/or   Describe notable features
                                                                             noncompliance or uncorroborated                for reference and corroborating     country laws used for additional implemented by factory
                                                                             evidence of noncompliance                      evidence (e.g. worker interviews,   reference                        management or Company
                                                                                                                            factory walkthrough, records
                                                                                                                            review, etc.)
1. Code Awareness
GEN 2: Ensure that all Company factories as well as Noncompliance              Asics Code is not provided to the factory.   Factory walkthrough, worker &
contractors and suppliers inform their employees                                                                            management interviews
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, Noncompliance                  The employees do not have any non-           Worker & management interviews
in a manner appropriate to the culture and situation,                          compliance reporting channel to Asics.
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.


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.

5. Non-Discrimination
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.
                                                                                                                1
FLA Code/Benchmark                                   Compliance Status Describe noncompliance, risk of            List sources/documentation used     Cite and describe local and/or   Describe notable features
                                                                       noncompliance or uncorroborated            for reference and corroborating     country laws used for additional implemented by factory
                                                                       evidence of noncompliance                  evidence (e.g. worker interviews,   reference                        management or Company
                                                                                                                  factory walkthrough, records
                                                                                                                  review, etc.)
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&S.5 Health and Safety Management System               Noncompliance   OHS Technician or Engineer is missing in Management interview             Turkish Labor Law, Article 82
                                                                        the facility.
H&S.6 Communication to Workers                       Noncompliance      The employees are not trained by facility Worker & management interviews; Regulation regarding
                                                                        doctor.                                    documentation review           Occupational Physicians and
                                                                                                                                                  Workplace Health Unit, Article
                                                                                                                                                  22
H&S.7 Notification and Record Maintenance            Noncompliance      Risk analysis has not been conducted and Management interview &           Turkish Labor Law, Article 77
                                                                        accident reports are not maintained in the document review                Regulation regarding
                                                                        facility.                                                                 Occupational Physicians and
                                                                                                                                                  Workplace Health Unit, Article
                                                                                                                                                  14 & 16
H&S.8 Permits and Certificates                       Noncompliance      Working environment tests regarding       Management interview                OHS Regulation Articles18, 20,
                                                                        noise, thermal comfort, dust                                                  21, 22 & 76
                                                                        concentration, chemicals concentration
                                                                        are not conducted.
H&S.9 Evacuation Requirements and Procedure          Noncompliance      Evacuation route is erased on the work    Factory walkthrough                 Regulation regarding the
                                                                        floors.                                                                       Protection of Buildings Against
                                                                        Emergency doors sliding instead of                                            Fire, Article 30 & 47
                                                                        opening outwards.

H&S.10 Safety Equipment and First Aid Training       Noncompliance      Alarm button, fire hose & extinguishers   Factory walkthrough                 Regulation regarding hazardous
                                                                        are blocked in warehouse.                                                     material, Article 59
                                                                        Fire hose’s pipe is missing in cutting                                        Regulation regarding the
                                                                        section.                                                                      Protection of Buildings Against
                                                                        Fire extinguishers are not mounted.                                           Fire, Article 94

H&S.11 Personal Protective Equipment                 Noncompliance      Noise level is not tested in accordance   Factory walkthrough &               Noise Regulation, Article 6
                                                                        with the new regulation dated 12/23/2006. documentation review                OHS Regulation, Article 78/4,
                                                                        Ear audiogram is not conducted.                                               78/5
                                                                        Proper ear plugs are not provided to the                                      Regulation regarding the Use of
                                                                        employees.                                                                    Personal Protectors in
                                                                                                                                                      Workplaces, Article 6
H&S.12 Use of Personal Protective Equipment          Noncompliance      Proper protective equipment is not      Factory walkthrough &                 Regulation regarding the Use of
                                                                        provided to the employees in accordance documentation review                  Personal Protectors in
                                                                        with the workplace tests.                                                     Workplaces, Article 6 & 7

H&S.13 Chemical Management and Training              Noncompliance      Chemical storage is not in separate area. Factory walkthrough                 Regulation regarding
                                                                        Labels on chemicals are not proper.                                           Occupational Health and Safety
                                                                                                                                                      Measures in Dealing with
                                                                                                                                                      Chemicals, Article 7
                                                                                                                                                      Dangerous Chemicals
                                                                                                                                                      Regulation, Article 6, 8, 9 & 16


                                                                                                        2
FLA Code/Benchmark                                   Compliance Status Describe noncompliance, risk of              List sources/documentation used     Cite and describe local and/or   Describe notable features
                                                                       noncompliance or uncorroborated              for reference and corroborating     country laws used for additional implemented by factory
                                                                       evidence of noncompliance                    evidence (e.g. worker interviews,   reference                        management or Company
                                                                                                                    factory walkthrough, records
                                                                                                                    review, etc.)
H&S.14 Material Safety Data Sheets/Worker Access Noncompliance          MSDS sheets are not posted in chemical      Factory walkthrough                 Dangerous Chemicals
and Awareness                                                           related sections.                                                               Regulation, Article 12 & 13
                                                                        MSDS sheets are not considered while                                            Regulation regarding
                                                                        selecting PPE.                                                                  Occupational Health and Safety
                                                                                                                                                        Measures in Dealing with
                                                                                                                                                        Chemicals, Article 8




H&S.17 Ventilation/Electrical/Facility Installation and Noncompliance   Ventilation is not adequate.                 Factory walkthrough                Occupational Health and Safety
Maintenance                                                             Electrical installations are not checked                                        Regulation, Article 76/1 & 191
                                                                        periodically.                                                                   Regulations regarding the
                                                                        Leakage of water to electrical installations                                    Workplace Safety, Article 8/d &
                                                                        in warehouse and in stain removal section                                       1-3
                                                                        were observed.                                                                  Regulation regarding Hazardous
                                                                        Exproof lighting system is not provided in                                      Material, Article 23
                                                                        the facility.

H&S.18 Machinery Maintenance and Worker              Noncompliance      5 lower pulley guards are missing, several Factory walkthrough                  Machine Safety Regulation,
Training                                                                are broken.                                                                     Article 1.4



H&S.19 Proper Use of Machinery                       Noncompliance      Stain removal machine’s ventilation is      Factory walkthrough                 Occupational Health and Safety
                                                                        broken.                                                                         Regulation, Article 191 & 200

H&S.20 Bodily Strain                                 Noncompliance      The employees are not trained by facility   Worker & management interviews; Regulation regarding
                                                                        doctor regarding bodily strain.             documentation review            Occupational Physicians and
                                                                                                                                                    Workplace Health Unit, Article
                                                                                                                                                    22
H&S.21 Medical Facilities                            Noncompliance      The facility doctor does not receive        Factory walkthrough             Workplace doctor certification
                                                                        periodical trainings as per workplace                                       Regulation regarding
                                                                        doctor certificate requirement.                                             Occupational Physicians and
                                                                        Workplace nurse is missing certificate.                                     Workplace Health Unit, Article
                                                                        Clinic is not adequate and water is not                                     4, 7 & 27
                                                                        provided in clinic.




H&S.22 Sanitation in Factory Facilities              Noncompliance      Changing room is not sanitary and not       Factory walkthrough                 Occupational Health and Safety
                                                                        heated.                                                                         Regulation, Article 41 & 44

H&S.25 Food Preparation                              Noncompliance      Periodical health checks of the cafeteria   Document review                     Regulation of Ministry of Health
                                                                        employees are not conducted properly.                                           No 2005/9

7. Freedom of Association and Collective
Bargaining
Employers will recognize and respect the right of
employees to freedom of association and collective
bargaining.
8. Hours of Work

                                                                                                         3
FLA Code/Benchmark                                          Compliance Status Describe noncompliance, risk of          List sources/documentation used     Cite and describe local and/or   Describe notable features
                                                                              noncompliance or uncorroborated          for reference and corroborating     country laws used for additional implemented by factory
                                                                              evidence of noncompliance                evidence (e.g. worker interviews,   reference                        management or Company
                                                                                                                       factory walkthrough, records
                                                                                                                       review, etc.)
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.2 Rest Day                                              Noncompliance     Several employees worked 7 days per      Worker interview & documentation Turkish Labor Law, Article 46
                                                                              week in September 2007.                  review

HOW.6 Time Recording System                                 Noncompliance     The in-house subcontractor's attendance Worker interview & documentation
                                                                              sheets are simply recorded by supervisors review
                                                                              using the mark 'X' for the days worked.


HOW.14 Annual Leave                                         Noncompliance     Annual leave committee is missing in the Worker & management interviews; Turkish Labor Law, Article 54
                                                                              facility and nearly 50 employees' annual documentation review            Regulation regarding Paid
                                                                              leaves are still pending from the previous                               Annual Leave, Article 15-19
                                                                              years.

9. Wages, Benefits and Overtime Compensation

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.

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.


WBOT.10 Premium/Overtime Compensation                       Noncompliance     The employees worked on national         Worker & management interviews; Turkish Labor Law, Article 47
                                                                              holiday on October 29, 2007 and were     documentation review
                                                                              compensated 50% more than the hourly
                                                                              rate instead of 100% according to the
                                                                              payroll documentation provided.

WBOT.19 False Payroll Records                               Noncompliance     In-house subcontracting firm keeps two   Worker interviews & document        Social Security Law, Article 77
                                                                              sets of payroll documentation.           review

10. Miscellaneous

                                                                                                             4
FLA Code/Benchmark                              Compliance Status Describe noncompliance, risk of           List sources/documentation used     Cite and describe local and/or   Describe notable features
                                                                  noncompliance or uncorroborated           for reference and corroborating     country laws used for additional implemented by factory
                                                                  evidence of noncompliance                 evidence (e.g. worker interviews,   reference                        management or Company
                                                                                                            factory walkthrough, records
                                                                                                            review, etc.)
Subcontracting, homework and other issues not
covered by above benchmarks and code
requirements.
MISC.1 Illegal Subcontracting                   Noncompliance     An in-house subcontracting firm is used   Worker & management interviews; Turkish Labor Law, Article 2
                                                                  for sewing and pressing processes.        documentation review




                                                                                                 5
FLA Audit Profile
Country                                           Turkey
Name of Factory                                   400076655F
Independent External Monitoring Organization      CSCC
Date(s) in Facility                               November 29 - 30, 2007
FLA Affiliated Compan(ies)                        Asics
Number of Workers                                 269
Product(s)                                        Towels & Bathrobes
Production Processes                              Weaving, cutting, sewing, pressing, packaging & finishing

FLA Code/Benchmark                                Compliance Status                                               Remediation                                                                                                                                Status
                                                                        Description of noncompliance, risk of     Company Remediation Plan         Target         Factory Response (optional)      Company Follow-Up                         Documentation   Completed, Pending,
                                                                        noncompliance or uncorroborated                                            Completion                                      (13&14, November, 2008)                                   On-going
                                                                        evidence of noncompliance                                                  Date


GEN 2: Ensure that all Company factories as well as Noncompliance       Asics Code is not provided to the factory. Code of Conduct will be         01/02/2008     We have received the posters     Asics Code of Conduct was posted on Factory tour &        Completed
contractors and suppliers inform their employees                                                                   provided ASAP.                                 and have hung them where all     announcement boards. The               Asics Code of
about the workplace standards orally and through                                                                                                                  personnel and workers can        management stated that the COC was Conduct.
the posting of standards in a prominent place (in the                                                                                                             see.                             provided 1 month after the audit date.
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, Noncompliance           The employees do not have any non-        Set up a reporting channel.                     We have received the posters     The contact information to report the     Factory tour &   Ongoing
in a manner appropriate to the culture and situation,                   compliance reporting channel to Asics.                                                    and have hung them where all     non-compliances at the factory to their   Asics Code of
to enable Company employees and employees of                                                                                                                      personnel and workers can        customer (Asics) was posted on the        Conduct. The
contractors and suppliers to report to the Company                                                                                                                see.                             audit day. Factory has also established   election
on noncompliance with the workplace standards,                                                                                                                                                     worker representative system. They will   procedure for
with security that they shall not be punished or                                                                                                                                                   negotiate and inform the worker           worker
prejudiced for doing so.                                                                                                                                                                           representatives regarding contact         representative
                                                                                                                                                                                                   information data of Asics for non-        system and
                                                                                                                                                                                                   compliance reporting channel at the       election result
                                                                                                                                                                                                   monthly meeting. Factory has              records. Worker
                                                                                                                                                                                                   suggestion boxes as well.                 representatives'
                                                                                                                                                                                                                                             monthly meeting
                                                                                                                                                                                                                                             minutes.




H&S.5 Health and Safety Management System         Noncompliance         OHS Technician or Engineer is missing     OHS Technician or Engineer       01/03/2008     Please can you inform us of      Related law issue was cancelled by        Related Law     Pending
                                                                        in the facility.                          must be hired.                                  the specifications of the OHS    court decision # 2006/2159. To be         decision
                                                                                                                                                                  Technician or Engineer so we     further investigated through related      #2006/2159.
                                                                                                                                                                  can follow accordingly. We       regulation and industry practices in
                                                                                                                                                                  already have a full time nurse   Turkey.
                                                                                                                                                                  and a doctor coming in at a
                                                                                                                                                                  regular basis to the factory.



H&S.6 Communication to Workers                    Noncompliance         The employees are not trained by facility Employees must receive           01/03/2008     The employees are planned to The workers were trained by company           Training records Completed
                                                                        doctor.                                   training accordingly.                           be trained by the factory       doctor on first aid, occupational          with workers
                                                                                                                                                                  doctor. We are trying to set up illnesses and appropriate PPE using.       signatures and
                                                                                                                                                                  a date for the training.                                                   worker
                                                                                                                                                                                                                                             interviews.


H&S.7 Notification and Record Maintenance         Noncompliance         Risk analysis has not been conducted      Risk analysis has to be           01/03/2008    All accidents reports are        The company management stated that Management             Ongoing
                                                                        and accident reports are not maintained   conducted and the factory                       already maintained; we can       they will conduct the risk analysis by interview.
                                                                        in the facility.                          management must maintain all                    provide documentation.           31st December 2008.
                                                                                                                  accident reports in the facility.


H&S.8 Permits and Certificates                    Noncompliance         Working environment tests regarding       Factory management must          Periodically   We have made amendments          The noise inspection was conducted on Noise inspection Ongoing
                                                                        noise, thermal comfort, dust              conduct working environment                     regarding this issue; we can     January 2008. However, the thermal     records.
                                                                        concentration, chemicals concentration    tests regarding noise, thermal                  provide documentation.           comfort, dust concentration, chemical
                                                                        are not conducted.                        comfort, dust concentration                                                      concentration tests were not conducted
                                                                                                                  and chemicals concentration.                                                     yet. The management stated that they
                                                                                                                                                                                                   will conduct related issues by 31st
                                                                                                                                                                                                   December 2008.



                                                                                                                                     6
FLA Code/Benchmark                                   Compliance Status                                                Remediation                                                                                                                                 Status
                                                                         Description of noncompliance, risk of        Company Remediation Plan         Target         Factory Response (optional)      Company Follow-Up                          Documentation   Completed, Pending,
                                                                         noncompliance or uncorroborated                                               Completion                                      (13&14, November, 2008)                                    On-going
                                                                         evidence of noncompliance                                                     Date


H&S.9 Evacuation Requirements and Procedure          Noncompliance       Evacuation route is erased on the work       Make a clear evacuation route. At all times     The evacuation routes have       Evacuation routes were quite clear on      Factory tour.   Completed
                                                                         floors.                                                                                      been repainted to make           the audit day. The direction of the
                                                                         Emergency doors sliding instead of                                                           clearer; we can provide          evacuation doors were revised as
                                                                         opening outwards.                                                                            pictures accordingly.            required by the law.

H&S.10 Safety Equipment and First Aid Training       Noncompliance       Alarm button, fire hose & extinguishers      Be sure that all alarm buttons, At all times    All these areas have been        Alarm buttons, fire hoses & fire           Factory tour.   Completed
                                                                         are blocked in warehouse.                    fire hose and extinguishers are                 arranged so that they are not    extinguishers were not blocked on the
                                                                         Fire hose’s pipe is missing in cutting       not blocked at all times.                       blocked. All staff have been     audit day. All fire hose pipes were
                                                                         section.                                                                                     warned about this issue.         properly mounted; no missing hose
                                                                         Fire extinguishers are not mounted.                                                                                           pipe noted. All fire extinguishers were
                                                                                                                                                                                                       mounted on the wall.


H&S.11 Personal Protective Equipment                 Noncompliance       Noise level is not tested in accordance      Noise levels should be tested    Periodically   Noise levels have been tested    The noise measurement was                  The noise         Completed
                                                                         with the new regulation dated                according to new regulations                    according to the new             conducted on January 2008 and the          measurement
                                                                         12/23/2006.                                  and proper protective gear                      regulations and the proper       workers were wearing appropriate PPE       inspection
                                                                         Ear audiogram is not conducted.              should be provided.                             gear has been provided to all    as ear plugs. The audiogram check          records, factory
                                                                         Proper ear plugs are not provided to the                                                     workers; we can supply           was conducted for all workers who are      tour and
                                                                         employees.                                                                                   documentation regarding          working in weaving area.                   periodical health
                                                                                                                                                                      noise level tests.                                                          check records
                                                                                                                                                                                                                                                  for audiogram.


H&S.12 Use of Personal Protective Equipment          Noncompliance       Proper protective equipment is not      Proper protective equipment           At all times   The proper equipment has         Workers were wearing appropriate        Factory tour.      Completed
                                                                         provided to the employees in accordance must be provided to all                              been provided to all             PPE while working such as steel
                                                                         with the workplace tests.               employees.                                           employees. They have been        gloves at cutting section and ear plugs
                                                                                                                                                                      retrained to use these at all    at weaving section.
                                                                                                                                                                      times.
H&S.13 Chemical Management and Training              Noncompliance       Chemical storage is not in separate area. Chemicals should be stored in At all times         The chemicals were already       Factory has designed a new, separate Factory tour.         Completed
                                                                         Labels on chemicals are not proper.       separate area and all                              stored in a separate area in     room for chemicals which are used at
                                                                                                                   chemicals should be properly                       the next block of weaving.       the factory with appropriate labeling.
                                                                                                                   labeled.                                           Now we have made a
                                                                                                                                                                      separate room for these.


H&S.14 Material Safety Data Sheets/Worker Access Noncompliance           MSDS sheets are not posted in chemical       MSDS sheets must be posted At all times         MSDS sheets have been            The MSDS were posted on the wall           MSDS for        Completed
and Awareness                                                            related sections.                            in chemical related sections.                   posted in chemical related       where the chemicals are stored and         chemicals and
                                                                         MSDS sheets are not considered while         MSDS sheets must be                             sections. The workers have       used.                                      factory tour.
                                                                         selecting PPE.                               considered while selecting                      been reminded usage
                                                                                                                      PPE.                                            accordingly.

H&S.17 Ventilation/Electrical/Facility Installation and Noncompliance    Ventilation is not adequate.                 Proper ventilation of the facility 01/03/2008   We do have proper ventilation    The dust measurement was conducted         The dust        Ongoing
Maintenance                                                              Electrical installations are not checked     must be arranged. All electrical                in the workplace. We have        at the factory. As per dust                measurement
                                                                         periodically.                                installations much be checked                   periodic checks for electrical   measurement report, the values are         inspection
                                                                         Leakage of water to electrical               periodically. The facility must                 equipment and we have forms      higher than normal standards. Factory      record,
                                                                         installations in warehouse and in stain      have exproof lighting system.                   relating to this (Can be         shall have an administrative decision to   management
                                                                         removal section were observed.                                                               supplied).                       make the ventilation better till 1st of    interview,
                                                                         Exproof lighting system is not provided in                                                                                    January 2009. However, electrical          machine
                                                                         the facility.                                                                                                                 installation checks are conducted          maintenance
                                                                                                                                                                                                       periodically. The factory repaired the     records and
                                                                                                                                                                                                       leakage of water to electrical             factory tour.
                                                                                                                                                                                                       installations in warehouse and stain
                                                                                                                                                                                                       removal section. The lighting system
                                                                                                                                                                                                       was provided outside of the factory.




H&S.18 Machinery Maintenance and Worker              Noncompliance       5 lower pulley guards are missing,           Check that all lower pulley      01/02/2008     These have been checked          The missing parts were replaced and        Factory tour.   Completed
Training                                                                 several are broken.                          guards are in good conditions                   and missing parts have been      broken ones repaired.
                                                                                                                      and that they are complete.                     replaced.



H&S.19 Proper Use of Machinery                       Noncompliance       Stain removal machine’s ventilation is       Repair the stain removal         01/02/2008     This has been repaired.          Stain removal machine ventilation was Factory tour.        Completed
                                                                         broken.                                      machine's ventilation.                                                           repaired.



                                                                                                                                          7
FLA Code/Benchmark                        Compliance Status                                               Remediation                                                                                                                                  Status
                                                              Description of noncompliance, risk of       Company Remediation Plan        Target         Factory Response (optional)       Company Follow-Up                         Documentation     Completed, Pending,
                                                              noncompliance or uncorroborated                                             Completion                                       (13&14, November, 2008)                                     On-going
                                                              evidence of noncompliance                                                   Date


H&S.20 Bodily Strain                      Noncompliance       The employees are not trained by facility Provide proper training to        01/03/2008     We are arranging a date with      The workers were trained by company       The training      Completed
                                                              doctor regarding bodily strain.           employees.                                       the doctor regarding the          doctor regarding bodily strain.           records with
                                                                                                                                                         training.                                                                   workers'
                                                                                                                                                                                                                                     signatures.

H&S.21 Medical Facilities                 Noncompliance       The facility doctor does not receive        The facility doctor and the     01/03/2008     The facility doctor has           The factory doctor and the nurse, who     The doctor's and Ongoing
                                                              periodical trainings as per workplace       nurse should receive proper                    certificates regarding working    is lately employed at the factory, have   nurse's
                                                              doctor certificate requirement.             training and have all necessary                in the facility and doctor        necessary certificates. However, the      certificates,
                                                              Workplace nurse is missing certificate.     certificates.                                  certificates. The nurse does      water was not provided for health unit    additionally
                                                              Clinic is not adequate and water is not                                                    have a nurse certificate. We      yet. As per management interview,         nurse's
                                                              provided in clinic.                                                                        have applied for the other        they stated that they will move the       graduation
                                                                                                                                                         certificate required.             health unit by 31 December 2008           records. Factory
                                                                                                                                                                                           where all necessary items are             tour and
                                                                                                                                                                                           provided.                                 management
                                                                                                                                                                                                                                     interview.



H&S.22 Sanitation in Factory Facilities   Noncompliance       Changing room is not sanitary and not       Improve the conditions in the   Immediately    The changing room has been        The changing room was clean, but the      Factory tour and Ongoing
                                                              heated.                                     changing room. It should be                    cleaned accordingly on a          heating system was not provided yet.      management
                                                                                                          clean and properly heated.                     regular basis. Also, electrical   The management stated that they will      interview.
                                                                                                                                                         heaters have been placed in       arrange a heating system in one
                                                                                                                                                         this room.                        month.


H&S.25 Food Preparation                   Noncompliance       Periodical health checks of the cafeteria   Conduct periodical health       By the next    The periodical health checks      Periodical health checks against          Health check      Completed
                                                              employees are not conducted properly.       checks of the cafeteria         check          for the staff in the cafeteria    continuous diseases were conducted        records against
                                                                                                          employees according to                         have been made (Can be            for kitchen and cafeteria personnel.      continuous
                                                                                                          regulations. Please inform                     supplied).                                                                  diseases for
                                                                                                          when they are taking place.                                                                                                kitchen
                                                                                                                                                                                                                                     personnel.

HOW.2 Rest Day                            Noncompliance       Several employees worked 7 days per         All employees must have rest    01/01/2008     These rest days have been         As per reviewed 27 time card records Time card          Completed
                                                              week in September 2007.                     days according to the law.                     added to these workers'           from October 2007 to October 2008,    records and
                                                                                                                                                         annual leave.                     no consecutive 7 or more working days worker interview.
                                                                                                                                                                                           noted.

HOW.6 Time Recording System               Noncompliance       The in-house subcontractor's attendance Factory should have a proper        01/03/2008     Subcontractor workers have        Subcontractor workers recording their     Time card         Completed
                                                              sheets are simply recorded by           time recording system for all                      been given cards to track time    time by swipe card system which was       records and
                                                              supervisors using the mark 'X' for the  the employees.                                     and date of entrance to and       integrated into factory's swipe card      worker interview.
                                                              days worked.                                                                               exit from the factory.            system.


HOW.14 Annual Leave                       Noncompliance       Annual leave committee is missing in the Annual leave should be taken                      Workers have taken their          The management stated that they will      The annual        Ongoing
                                                              facility and nearly 50 employees' annual by all employees.                                 annual leave.                     establish the annual leave committee      leave records
                                                              leaves are still pending from the previous                                                                                   by 31 December 2008, and all workers      and
                                                              years.                                                                                                                       shall receive their annual leaves by      management
                                                                                                                                                                                           31st December 2008.                       interview.


WBOT.10 Premium/Overtime Compensation     Noncompliance       The employees worked on national      Employees must be properly            At all times   The workers have been             As per reviewed time cards with           Time card         Completed
                                                              holiday on October 29, 2007 and were  compensated when working                             reimbursed the amount.            payment records, the workers were         records,
                                                              compensated 50% more than the hourly during holidays.                                                                        paid their overtime rate as required by   payment
                                                              rate instead of 100% according to the                                                                                        the law for national holidays.            records,
                                                              payroll documentation provided.                                                                                                                                        management
                                                                                                                                                                                                                                     interview and
                                                                                                                                                                                                                                     worker interview.

WBOT.19 False Payroll Records             Noncompliance       In-house subcontracting firm keeps two      In-house subcontracting firm   Immediately     We have taken over the            The in-house subcontracting firm does Time card         Completed
                                                              sets of payroll documentation.              should not have double payroll                 payroll and now we handle         not keep double booking on payrolls   records,
                                                                                                          information.                                   these instead of                  anymore.                              payment
                                                                                                                                                         subcontractor.                                                          records,
                                                                                                                                                                                                                                 management
                                                                                                                                                                                                                                 interview and
                                                                                                                                                                                                                                 worker interview.



                                                                                                                             8
FLA Code/Benchmark              Compliance Status                                             Remediation                                                                                                                              Status
                                                    Description of noncompliance, risk of     Company Remediation Plan        Target        Factory Response (optional)      Company Follow-Up                         Documentation   Completed, Pending,
                                                    noncompliance or uncorroborated                                           Completion                                     (13&14, November, 2008)                                   On-going
                                                    evidence of noncompliance                                                 Date


MISC.1 Illegal Subcontracting   Noncompliance       An in-house subcontracting firm is used   Please provide information      Immediately   This is a subcontractor          As per the law, the factories shall not   Management      Ongoing
                                                    for sewing and pressing processes.        regarding this subcontractor.                 working with us from time to     use subcontractors in any one of their    interview.
                                                                                                                                            time. All workers are trained    main processes. The subcontractor is
                                                                                                                                            accordingly and fully socially   still operating at the factory. The
                                                                                                                                            secured.                         management stated that they will
                                                                                                                                                                             discuss and shall have a strategically
                                                                                                                                                                             decision on this issue by 31st
                                                                                                                                                                             December 2008.




                                                                                                                  9
FLA Audit Profile
Country                                           Turkey
Name of Factory                                   400076655F
Independent External Monitoring Organization      CSCC
Date(s) in Facility                               November 29 - 30, 2007
FLA Affiliated Compan(ies)                        Asics
Number of Workers                                 269
Product(s)                                        Towels & Bathrobes
Production Processes                              Weaving, cutting, sewing, pressing, packaging & finishing

FLA Code/Benchmark                                Compliance Status         [Status]                          Description of noncompliance, risk of     Updates (Cite Date of Follow-Up)        Third-Party Verification     Company Verification Follow-Up
                                                                            Completed, Pending, On-going      noncompliance or uncorroborated           Company Follow-Up         Documentation External     Documentation   Company Follow-Up (cite      Documentation
                                                                                                              evidence of noncompliance                                                         Verification                 date of planned or follow-up
                                                                                                                                                                                                (Date)                       visit, if appropriate)
GEN 2: Ensure that all Company factories as well as Noncompliance           Completed                         Asics Code is not provided to the
contractors and suppliers inform their employees                                                              factory.
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 Noncompliance            Ongoing                           The employees do not have any non-
a manner appropriate to the culture and situation, to                                                         compliance reporting channel to Asics.
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.

H&S.5 Health and Safety Management System         Noncompliance             Pending                           OHS Technician or Engineer is missing
                                                                                                              in the facility.
H&S.6 Communication to Workers                    Noncompliance             Completed                         The employees are not trained by
                                                                                                              facility doctor.

H&S.7 Notification and Record Maintenance         Noncompliance             Ongoing                           Risk analysis has not been conducted
                                                                                                              and accident reports are not
                                                                                                              maintained in the facility.

H&S.8 Permits and Certificates                    Noncompliance             Ongoing                           Working environment tests regarding
                                                                                                              noise, thermal comfort, dust
                                                                                                              concentration, chemicals concentration
                                                                                                              are not conducted.

H&S.9 Evacuation Requirements and Procedure       Noncompliance             Completed                         Evacuation route is erased on the work
                                                                                                              floors.
                                                                                                              Emergency doors sliding instead of
                                                                                                              opening outwards.

H&S.10 Safety Equipment and First Aid Training    Noncompliance             Completed                         Alarm button, fire hose & extinguishers
                                                                                                              are blocked in warehouse.
                                                                                                              Fire hose’s pipe is missing in cutting
                                                                                                              section.
                                                                                                              Fire extinguishers are not mounted.




H&S.11 Personal Protective Equipment              Noncompliance             Completed                         Noise level is not tested in accordance
                                                                                                              with the new regulation dated
                                                                                                              12/23/2006.
                                                                                                              Ear audiogram is not conducted.
                                                                                                              Proper ear plugs are not provided to
                                                                                                              the employees.

H&S.12 Use of Personal Protective Equipment       Noncompliance             Completed                         Proper protective equipment is not
                                                                                                              provided to the employees in
                                                                                                              accordance with the workplace tests.


H&S.13 Chemical Management and Training           Noncompliance             Completed                         Chemical storage is not in separate
                                                                                                              area.
                                                                                                              Labels on chemicals are not proper.




                                                                                                                                   10
FLA Code/Benchmark                                        Compliance Status   [Status]                       Description of noncompliance, risk of      Updates (Cite Date of Follow-Up)        Third-Party Verification     Company Verification Follow-Up
                                                                              Completed, Pending, On-going   noncompliance or uncorroborated            Company Follow-Up         Documentation External     Documentation   Company Follow-Up (cite      Documentation
                                                                                                             evidence of noncompliance                                                          Verification                 date of planned or follow-up
                                                                                                                                                                                                (Date)                       visit, if appropriate)
H&S.14 Material Safety Data Sheets/Worker Access          Noncompliance       Completed                      MSDS sheets are not posted in
and Awareness                                                                                                chemical related sections.
                                                                                                             MSDS sheets are not considered while
                                                                                                             selecting PPE.


H&S.17 Ventilation/Electrical/Facility Installation and   Noncompliance       Ongoing                        Ventilation is not adequate.
Maintenance                                                                                                  Electrical installations are not checked
                                                                                                             periodically.
                                                                                                             Leakage of water to electrical
                                                                                                             installations in warehouse and in stain
                                                                                                             removal section were observed.
                                                                                                             Exproof lighting system is not provided
                                                                                                             in the facility.



H&S.18 Machinery Maintenance and Worker Training Noncompliance                Completed                      5 lower pulley guards are missing,
                                                                                                             several are broken.

H&S.19 Proper Use of Machinery                            Noncompliance       Completed                      Stain removal machine’s ventilation is
                                                                                                             broken.

H&S.20 Bodily Strain                                      Noncompliance       Completed                      The employees are not trained by
                                                                                                             facility doctor regarding bodily strain.


H&S.21 Medical Facilities                                 Noncompliance       Ongoing                        The facility doctor does not receive
                                                                                                             periodical trainings as per workplace
                                                                                                             doctor certificate requirement.
                                                                                                             Workplace nurse is missing certificate.
                                                                                                             Clinic is not adequate and water is not
                                                                                                             provided in clinic.




H&S.22 Sanitation in Factory Facilities                   Noncompliance       Ongoing                        Changing room is not sanitary and not
                                                                                                             heated.

H&S.25 Food Preparation                                   Noncompliance       Completed                      Periodical health checks of the
                                                                                                             cafeteria employees are not conducted
                                                                                                             properly.

HOW.2 Rest Day                                            Noncompliance       Completed                      Several employees worked 7 days per
                                                                                                             week in September 2007.

HOW.6 Time Recording System                               Noncompliance       Completed                      The in-house subcontractor's
                                                                                                             attendance sheets are simply recorded
                                                                                                             by supervisors using the mark 'X' for
                                                                                                             the days worked.

HOW.14 Annual Leave                                       Noncompliance       Ongoing                        Annual leave committee is missing in
                                                                                                             the facility and nearly 50 employees'
                                                                                                             annual leaves are still pending from the
                                                                                                             previous years.

WBOT.10 Premium/Overtime Compensation                     Noncompliance       Completed                      The employees worked on national
                                                                                                             holiday on October 29, 2007 and were
                                                                                                             compensated 50% more than the
                                                                                                             hourly rate instead of 100% according
                                                                                                             to the payroll documentation provided.


WBOT.19 False Payroll Records                             Noncompliance       Completed                      In-house subcontracting firm keeps two
                                                                                                             sets of payroll documentation.

MISC.1 Illegal Subcontracting                             Noncompliance       Ongoing                        An in-house subcontracting firm is used
                                                                                                             for sewing and pressing processes.




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