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Sample Application Letter for Staff Nurse FLA Audit Profile Country

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					FLA Audit Profile
Country                       Bangladesh
Factory name                  38020586D                                                                          Factory Name: 38020586DV
IEM                           LIFT Standards Ltd.                                                                IEM: Phulki
Date(s) in facility           July 30- 31st & August 2 and 4, 2005                                               Dates of IEV: September 12, 2007
PC(s)                         Top of the World and Outdoor Cap Company                                           PC(s): Top of the World
Number of workers             948                                                                                FLA Comment: This report was submitted with a corresponding corrective action plan to the FLA and was reviewed by FLA
Product(s)                    Caps and Hats                                                                      staff. In an effort to improve the effectiveness of remediation, the FLA has provided feedback and recommendations to the
Production processes          Cutting, sewing and finishing                                                      company. The FLA has not yet received a response from the company. Therefore, the report is posted in its current state
                                                                                                                 and will be updated once a finalized report has been received.

                                                                                                                                                                                       IEM Findings                                                                                                                                                                                        Remediation                                                                                                                   Updates (Cite Date of Follow up)                                                Third Party Verification                                           Company Verification Follow up
FLA Code/ Compliance issue     Country Law/Legal Reference                    FLA Benchmark                                      Non-compliance                     Risk of Non-compliance       Evidence of Non-   If not corroborated,   Sources/Documentation         Notable                                PC Remediation plan                                  Target                  Factory Response (Optional)                 Company follow up (Cite date of follow         Documentation                   Company Follow up             Documentation                        Third Party Verification                        Documentation            Company Follow up (Cite       Documentation
                                                                                                                                                                                                    compliance           explain why        used for corroborating      Features                                                                                   Completion                                                                            up)                                                                                                                            (IEV: 12 September, 2007)                                                  date of planned or follow up
                                                                                                                                                                                                 (uncorroborated)                                                     implemented                                                                                     Date                                                                                                                                                                                                                                                                                             visit, if appropriate)
                                                                                                                                                                                                                                                                       by Factory
                                                                                                                                                                                                                                                                     Management or
                                                                                                                                                                                                                                                                        Company
1. Code Awareness
Worker/management                                             FLA Principle of Monitoring, Obligation of Workers are unaware about the code of                                                                                             Workers and                               Outdoor Cap and Top of the World (ODC/TOW) request factory to          1st week            Factory will send photos of the training of Code of    The factory sent photos of workers                                                                               Factory sent      Compliance officer produced schedules for trainings Review of training schedule,         Factory does periodic
awareness of Code                                             Companies: Ensure that all Company            conduct and its purpose contents. No formal                                                                                    management interview                      send your records of workers being trained in every work station.      of August           Conduct. They will also send notes of the training and completing training.                                                                                             photos of CoC     conducted during the last 12 months with the            interview with compliance        training--sign in sheets
                                                              factories as well as contractors and          training system exists                                                                                                         about the training and                    ODC/TOW require detailed notes of this training and signed             2006                signed documentation from workers that took the                                                                                                                         meetings held     signature of workers on them. But workers and           and welfare officer, workers     for training to be
                                                              suppliers inform their employees about the                                                                                                                                   records reviewed                          documentation of workers that attended the training. ODC/TOW                               training by the first week of August 2006.                                                                                                                              for employees     trainers in-charge informed the monitors that only fire interview.                       submitted to TOW 5/09.
                                                              workplace standards orally and through the                                                                                                                                                                             request factory to send picture of supervisor that trained workers and                                                                                                                                                                                             and signature     evacuation and fire fighting training were conducted
                                                              posting of standards in a prominent place (in                                                                                                                                                                          his signed documentation of training for our records.                                                                                                                                                                                                              sheets from all   on a regular basis. Workers are still not aware of the
                                                              the local languages spoken by employees                                                                                                                                                                                • Send us pictures of suggestion/grievance boxes for workers in the                                                                                                                                                                                                employees that    factory rules and Code of Conduct.
                                                              and managers) and undertake other efforts                                                                                                                                                                              factories and advise how many boxes are available and the location of                                                                                                                                                                                              attended.
                                                              to educate employees about the standards                                                                                                                                                                               these boxes.                                                                                                                                                                                                                                                       Received
                                                              on a regular basis.                                                                                                                                                                                                    • Advise who is in charge of collecting the suggestion/grievances from                                                                                                                                                                                             8/23/06 on file
                                                                                                                                                                                                                                                                                     these boxes and how often are they collected.                                                                                                                                                                                                                      at ODC and
                                                                                                                                                                                                                                                                                     • Send us procedures of how the suggestions/grievances are handled                                                                                                                                                                                                 TOW.
                                                                                                                                                                                                                                                                                     so that they can be resolved for the worker.

Confidential non-compliance                                   FLA Principle of Monitoring, Obligation of There is no confidential non- compliance                                                                                          workers and                               • ODC/TOW requests factory to send us pictures of                             1st week     Factory will send pictures of suggestion/grievance       The factory sent photos of                                                                                     Factory sent      The workers are not accustomed to dropping                Interviews with the workers    Workers can contact our
reporting channel                                             Companies: Develop a secure                   reporting channel that exists in the factory                                                                                   management interview                      suggestion/grievance boxes for workers in the factories and advise            of August    boxes, quantity of boxes, location of boxes along with   suggestion boxes.                                                                                              photos of         complaints/suggestions in the designated boxes.           and welfare officer, review of local auditor for
                                                              communications channel, in a manner                                                                                                                                          and recording system                      how many boxes are available and the location of these boxes.                 2006         documents of procedures of how                                                                                                                                          suggestion/grie   They considered that complaint boxes put in the           complaint register and         complaints. His
                                                              appropriate to the culture and situation, to                                                                                                                                 reviewed                                  • ODC/TOW requests factory to advise who is in charge of collecting                        suggestion/grievances are collected and handled.                                                                                                                        vance boxes in    toilet do not resolve the workers' problems.              complaint file.                telephone number and
                                                              enable Company employees and employees                                                                                                                                                                                 the suggestion/grievances from these boxes and how often are they                                                                                                                                                                                                  place and         Therefore they do not drop any complaints in the                                         email are posted at the
                                                              of contractors and suppliers to report to the                                                                                                                                                                          collected.                                                                                                                                                                                                                                                         procedures for    box. Monitors also noted that no complaint was                                           factory.
                                                              Company on noncompliance with the                                                                                                                                                                                      • ODC/TOW requests factory to send us procedures of how the                                                                                                                                                                                                        how               recorded in the complaint register for the last few
                                                              workplace standards, with security that they                                                                                                                                                                           suggestions/grievances are handled so that they can be resolved for                                                                                                                                                                                                suggestion/grie   months. Complaint and suggestion boxes were
                                                              shall not be punished or prejudiced for doing                                                                                                                                                                          the worker.                                                                                                                                                                                                                                                        vances are        opened by the welfare officer on a fortnightly basis,
                                                              so.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                       collected and     although as per remediation plan they have to be
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        handled.          opened by Worker Welfare Committee (WWC). The
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        These items       confidential non-compliance reporting channel was
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        are on file at    not functional.
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        the PCs.
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
Employment Records                                            Employers will maintain sufficient hiring and      Workers are not provided with appointment                                                                                  Workers interview and                    1. The factory must give each employee an appointment letter and               11/1/2005 1. The factory has already started to give each            1. The factory sent 5 copies of          1. The factory sent 5                                                                   All the personnel files contain appointment and           Review of worker personnel
                                                              employment records to demonstrate and              letter and confirmation letter. The letters are                                                                           management interview                      confirmation letter as required by local law. A copy of the letters will be              employee an appointment letter and confirmation letter     employee appointment/confirmation        copies of employee                                                                      confirmation letter (if probation period is completed)    files, management interview,
                                                              verify compliance with this Code provision         signed by the workers and only kept in the                                                                                and records of                            kept in the employee’s personnel files at all times. Management must                     as required by local law. The factory is also keeping a    letters on 10/31/05, showing             appointment/confirmation                                                                duly signed by the authorized personnel and the           interview with several newly
                                                                                                                 personnel files. Some Documents are not                                                                                   personnel file reviewed                   sign both the appointment letter and confirmation letter. The original                   copy of the letters in the employee's personnel files at   management signatures and                letters on 10/31/05,                                                                    workers. At present it takes almost one month to          recruited workers and review
                                                                                                                 consistent: 8 - No appointment letter, 1person -                                                                                                                    appointment and/or confirmation letters should include the statement,                    all times. Will send requested items by 11/1/05.           employee signatures.                     showing management                                                                      complete one personnel file. No workers were              of workers attendance
                                                                                                                 no confirmation letter, 5 appointment letter                                                                                                                        “I, employee name, have read and received a copy of this letter.”                                                                                                                            signatures and employee                                                                 terminated within the last 12 months.                     register.
                                                                                                                 without sign of management, Employment                                                                                                                              Have the employee sign and date the letter. Give a copy to the                                                                                                                               signatures.
                                                                                                                 contract does not contain signature from                                                                                                                            employee for their records. This is to be implemented immediately for
                                                                                                                 management, No settlement paper for the                                                                                                                             all appointments and new hires. The factory is to send at least 5
                                                                                                                 terminated workers. More over it takes at least                                                                                                                     copies of the newly signed confirmation/appointment letters to
                                                                                                                 3 months time to complete one personnel file.                                                                                                                       ToW/ODC by Nov 1, 2005.

Employment Records                                            Employers will maintain sufficient hiring and      It takes 3 months time to open and complete a                                                                             Personnel File review                     The factory shall immediately have the service book, appointment              11/1/2005    The factory is now giving the service book,              Factory has sent copies of services Copy of service book and                                                                     At present it takes almost one month to complete          Review of worker personnel     Verification of length of
                                                              employment records to demonstrate and              personnel file                                                                                                            and worker interviews                     letter including break-down of wages, an age and fitness certificate          &            appointment letter including break-down of wages, an     books, appointment letters, etc. to appointment letters kept                                                                     one personnel file.                                       files, management interview,   time to complete
                                                              verify compliance with this Code provision                                                                                                                                                                             completed upon hiring an employee. Send Top of the World/Outdoor              11/15/200    age and fitness certificate completed upon hiring an     satisfy this request. Dec. 05.      in files.                                                                                                                                              interview with several newly   personnel file--factory to
                                                                                                                                                                                                                                                                                     Cap 5 copies of new employees service books, appointment letters              5            employee. Will send requested items by 11/1/05.                                                                                                                                                                                                     recruited workers and review   supply copies of recent
                                                                                                                                                                                                                                                                                     including break-down of wages, an age and fitness certificate, by                                                                                                                                                                                                                                                                              of workers' attendance         personnel files 5/09.
                                                                                                                                                                                                                                                                                     November 1, 2005.                                                                                                                                                                                                                                                                                                                              register.
Employment Records                                            Employers will maintain sufficient hiring and      Contract papers are not complete. Reviewed                                                                                Attendance record                         The factory management must sign all employee contracts; the                  11/1/2005    Both the factory management and the employees are Factory has sent copies of services Copy of service book and                                                                            At present factory does not employ any persons on         Review of worker personnel
                                                              employment records to demonstrate and              and found 5 contract papers and 1 contract                                                                                review and                                employee must also sign the contract. Keep a copy of the contract in          &            signing all employee contracts. The factory is keeping books, appointment letters, etc to appointment letters kept                                                                        a contractual basis. The monitors found that no           files, interview with
                                                              verify compliance with this Code provision         collected where management signature does                                                                                 management interview                      the employee’s files and give a copy of the contract to the employee.         11/15/200    a copy of the contract in the employee’s files and     satisfy this request. Dec. 05.     in files.                                                                                       workers were employed on a contractual basis              management and workers.
                                                                                                                 not exist. Documents are not consistent: 8 - No                                                                           and personnel files                       This is to go into effect immediately. Please send Top of the                 5            giving a copy of the contract to the employee. Will                                                                                                                                       during the last 12 months.
                                                                                                                 appointment letter, 1person - no confirmation                                                                             reviewed, worker                          World/Outdoor Cap 5 copies of employee contracts with employee and                         send requested items by 11/1/05.
                                                                                                                 letter, 5 appointment letter without sign of                                                                              interview                                 management signatures by November 1, 2005.
                                                                                                                 management, Employment contract does not
                                                                                                                 contain signature from management, No
                                                                                                                 settlement paper for the terminated workers.

3. Child Labor
No person will be employed at an age younger than 15 (or 14 where the law of the country of
manufacture allows) or younger than the age for completing compulsory education in the country of
manufacture where such age is higher than 15.
Age Documentation                                             Employers will maintain proof of age               Workers age certificate is issued after the job                                                                           Personnel files and                        The factory must make age determination prior to the employees                11/1/2005 Factory Response:                                          The factory sent 5 copies of age         The factory sent 5 copies                                                               Monitors found that up until December 2005 all the     Interview with workers &
                                                              documentation for all workers, such as a           application date and joining date.                                                                                        age documentation                         joining date with the factory. This age determination must be                            In our factory, child labor is strictly prohibited.        determination certificates. We are       of age determination                                                                    age verification certificates from doctors were        nurse; review of workers'
                                                              birth certificate, which verifies date of birth.                                                                                                                             reviewed and                              documented in the employee files. This is to be implemented                              Normally the factory takes age determination               requesting a policy and procedure        certificates on 10/31/05.                                                               issued after the worker started working. During the    personnel files.
                                                                                                                                                                                                                                           interviewed the                           immediately for all new hires. Send Top of the World/Outdoor Cap 5                       certificate prior to the employees joining date. This      from the factory stating that age        Factory gave TOW                                                                        period of January to December 2006 some age
                                                                                                                                                                                                                                           certification process                     copies of age determination of newly hired employees by November 1,                      age determination also documented in the employee          determination must be made prior to      copies of policy and                                                                    verification certificate were issued upon hire and
                                                                                                                                                                                                                                           with management and                       2005.                                                                                    files. We will send all requested items by 11/1/05.        an employee’s start date. Please         procedures December                                                                     some 2/3 days later. But since January 2007 the
                                                                                                                                                                                                                                           nurse                                                                                                                                                                                         send by December 15, 2005.               05.                                                                                     age certificate of newly recruited workers has been
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          issued on or before the joining date of the respective
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                          workers.

Childcare facilities          Childcare facility need to be   Childcare facilities will not physically overlap Childcare facility is inside the factory premises                                                                           Visual inspection and                     The factory must ensure that the childcare facility is clearly away from       11/1/2005 Factory Response:                                          The factory did not send                                             ODC to discuss child care issue with                        Welfare officer has not provided any information on       Workers Interview,             Childcare center has
                              in a separate building/place    with production areas, and children will not     on 4th floor.                                                                                                               workers interview and                     any production area. The childcare facility must be kept clear of all                    Now it is impossible to us for shifting the childcare      remediation items by 11/1/05,                                        factory management at Feb. 06 visit                         childcare facility to workers. Some workers know          Management Interview and       been cleared but is still
                              other than the production       have access to production areas.                 The childcare facility is not functional and used                                                                           training system quarry                    obstacles that are not related to childcare. The factory must now                        center from the production floor. But in the future, we    asking that it be given to TOW on                                    ODC toured child care facility which is                     that there is a room for childcare but it is not used     Visual Inspection.             not in use. Target
                              floor.                                                                           as informal store - dresses/ uniforms of the                                                                                with management                           promote the use of the child care facility to the employees. We                          shall try to shift child care from the production floor.   December visit. Factory is no                                        located in the production facility, no                      for that purpose. Childcare facility was still not                                       completion 11/09
                                                                                                               workers are kept in it.                                                                                                                                               recommend the factory contract with Lift-Standards to complete a                         Now the factory promotes the use of the child care         longer using room for storage, but                                   children are enrolled in child care                         moved to a different location.
                                                                                                               No child was available in the center and                                                                                                                              consultancy training to help bring many different areas of the factory                   facility to the employees. We are taking the necessary     not utilizing as child care room at                                  facility at this time. No updates have
                                                                                                               workers are unaware about the facility and its                                                                                                                        into compliance, by doing this the female workers will be asked what                     actions to make day care center functional. We shall       this time either, Dec. 05                                            been made as of 10/17/06.
                                                                                                               advantages.                                                                                                                                                           would make the child care acceptable for them and then this                              send information about the day care center by
                                                                                                                                                                                                                                                                                     information would be brought to management for further discussion.                       11/1/2005.
                                                                                                                                                                                                                                                                                     Send Top of the World/Outdoor Cap the training date that is confirmed
                                                                                                                                                                                                                                                                                     with Lift-Standards for the consultancy training by November 1, 2005,
                                                                                                                                                                                                                                                                                     see attached information regarding this program.




                                                                                                                                                                                                                                                                                                                                                            1
                                                                                                                                                                                           IEM Findings                                                                                                                                                                                        Remediation                                                                                                                Updates (Cite Date of Follow up)                                           Third Party Verification                                             Company Verification Follow up
FLA Code/ Compliance issue    Country Law/Legal Reference                   FLA Benchmark                                     Non-compliance                           Risk of Non-compliance          Evidence of Non-   If not corroborated,   Sources/Documentation         Notable                               PC Remediation plan                                 Target                  Factory Response (Optional)               Company follow up (Cite date of follow         Documentation                  Company Follow up             Documentation                   Third Party Verification                         Documentation             Company Follow up (Cite       Documentation
                                                                                                                                                                                                          compliance           explain why        used for corroborating      Features                                                                                 Completion                                                                          up)                                                                                                                      (IEV: 12 September, 2007)                                                    date of planned or follow up
                                                                                                                                                                                                       (uncorroborated)                                                     implemented                                                                                   Date                                                                                                                                                                                                                                                                                       visit, if appropriate)
                                                                                                                                                                                                                                                                             by Factory
                                                                                                                                                                                                                                                                           Management or
                                                                                                                                                                                                                                                                              Company
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.
Progressive Discipline                                      Employers will utilize progressive discipline, No formal disciplinary system i.e. policy and                                                                                         Management interview                      The factory will attend a training of supervisors/management on             11/1/2005 Factory Response:                                         The factory has chosen not to hire       Copies of the policy and   ODC to discuss when training will be   Factory will     The factory has developed a policy and procedure      Review of policies and              Factory does periodic
                                                            e.g., escalating discipline using steps such     procedure exists.                                                                                                                   and workers interview                     treatment of employees and disciplinary actions. We are sending the                   The factory is arranging training programs for            Lift Standards Ltd. for the training.    procedures are kept in     given to the workers.                  send signed      on disciplinary action. However, the factory has not training schedule,                   training--sign in sheets
                                                            as verbal warning, written warning,                                                                                                                                                                                            training outline from Lift-Standards and we, Top of the World/Outdoor                 supervisors/management on treatment of employees          They have hired a person to help         files at ODC and TOW.                                             documentation    hired any outside consultant to provide training on   management and workers              for training to be
                                                            suspension, termination. Any exceptions to                                                                                                                                                                                     Cap, fully recommend that [factory] contract with Lift-Standards Ltd. to              and disciplinary actions. We will send revised policies   the factory become compliant. The                                                                          from the         treatment of employees and disciplinary action as     interview.                          submitted to TOW 5/09.
                                                            this rule, e.g., immediate termination for theft                                                                                                                                                                               complete this training program which consist of 2 days disciplinary and               and procedures and a confirmed training date by           factory did not send remediation                                                                           workers by       per PC remediation plan. Compliance officer
                                                            or assault, shall be in writing and clearly                                                                                                                                                                                    CoC training and a consultancy 4 months program. See attached list of                 11/1/05.                                                  items by 11/1/05, asking that it be                                                                        August 1,        informed that they conducted training for
                                                            communicated to the workers.                                                                                                                                                                                                   disciplinary procedures as a reference of what your system should                                                                               given to TOW on December visit.                                                                            2006.            supervisor/management on issues mentioned above.
                                                                                                                                                                                                                                                                                           resemble. Please send Top of the World/Outdoor Cap the factory’s                                                                                Factory has established and posted                                                                                          But monitors could not find training schedule on this
                                                                                                                                                                                                                                                                                           revised policies and procedures relating to discipline by and a set date                                                                        disciplinary policy and procedures.                                                                                         specific issue.
                                                                                                                                                                                                                                                                                           for the training November 1, 2005.                                                                                                              Training has occurred for
                                                                                                                                                                                                                                                                                                                                                                                                                                           management. Training to be
                                                                                                                                                                                                                                                                                                                                                                                                                                           provided to the workers the month
                                                                                                                                                                                                                                                                                                                                                                                                                                           of July 2006.
Progressive Discipline                                      Employers will utilize progressive discipline, Workers are terminated for continuous absent                                                                                          Personnel files and                        According to the law “The Employment of Labor (Standing Orders) Act,                    We shall immediately start complying with local law    The factory has chosen not to hire       Copies of the policy and   ODC to discuss when training will be   Factory will     The factory did not update the workers hand book by Interview workers and           Factory does periodic
                                                            e.g., escalating discipline using steps such     from work for 3 – 4 days.                                                                                                           warning letter and                        1965”, the employer is authorized to terminate a worker if s/he is                       and shall amend our employee handbook. We shall        Lift Standards Ltd. for the training.    procedures are kept in     given to workers.                      send signed      including “The Employment of Labor (Standing         management; review workers training--sign in sheets
                                                            as verbal warning, written warning,                                                                                                                                                  termination cases                         absent from work for more than 10 days without prior permission or                       send all requested items by 11/1/2005.                 They have hired a person to help         files at ODC and TOW.                                             documentation    Orders) Act, 1965” as per PC remediation plan.       personnel file, leave register for training to be
                                                            suspension, termination. Any exceptions to                                                                                                                                                                                     information to the management. This includes that upon the return the                                                                           the factory become compliant. The                                                                          from workers     Management continues to distribute the old hand      and workers hand book.         submitted to TOW 5/09
                                                            this rule, e.g., immediate termination for theft                                                                                                                                                                               workers is not able to give a justified explanation. In this case a                                                                             factory did not send remediation                                                                           by August 1,     book to the workers. Records show that during the
                                                            or assault, shall be in writing and clearly                                                                                                                                                                                    registered letter will be sent to the temporary and permanent address                                                                           items by 11/1/05, asking that it be                                                                        2006.            last 12 months no workers were terminated for 3 or
                                                            communicated to workers.                                                                                                                                                                                                       of the worker with the information of loss of lien and request to report                                                                        given to TOW on December visit.                                                                                             more days of continuous absence from work. But
                                                                                                                                                                                                                                                                                           with a given date. If his report does not happened as outlined in a                                                                             Factory has established and posted                                                                                          from the worker interview we have got information
                                                                                                                                                                                                                                                                                           registered letter, s/he can be lawful terminated. The factory shall                                                                             disciplinary policy and procedures.                                                                                         that the management still verbally communicated that
                                                                                                                                                                                                                                                                                           immediately starting complying with local law and shall amend your                                                                              Training has occurred for                                                                                                   the workers should be terminated in case of 3 or
                                                                                                                                                                                                                                                                                           employee handbook to state as such. Please send Top of the                                                                                      management. Training to be                                                                                                  more days of continuous absence from work.
                                                                                                                                                                                                                                                                                           World/Outdoor Cap a copy of the revised employee handbook                                                                                       provided to the workers the month
                                                                                                                                                                                                                                                                                           translated into English and in local language highlighting this change.                                                                         of July 2006.

Disciplinary Practices                                      Employers will utilize consistent written        No disciplinary policies and procedures are                                                                                         Workers interview and                     The factory will attend a training of supervisors/management on             11/1/2005 Factory Response:                                         The factory has chosen not to hire Copies of the policy and         ODC to discuss when training will be   Factory will     The factory has developed a policy and procedure         Review of the policies and       Factory does periodic
                                                            disciplinary practices that are applied fairly   found and not practiced in the factory. Only                                                                                        personnel warning                         treatment of employees and disciplinary actions. We are sending the                   The factory is arranging training programs for            Lift Standards for the training. They procedures are kept in        given to workers.                      send signed      on disciplinary action. However, the factory has not     training schedule, interview     training--sign in sheets
                                                            among all workers                                paper maintained on disciplinary action is the                                                                                      letters                                   training outline from Lift Standards Ltd. and we, Top of the                          supervisors/management on treatment of employees          have hired a person to help the       files at ODC and TOW.                                                documentation    hired any outside consultant to provide training on      with management and              for training to be
                                                                                                             warning letter. Some warning letter found where                                                                                                                               World/Outdoor Cap, fully recommend that [factory] contract with Lift                  and disciplinary actions. We will send revised policies   factory become compliant.                                                                                  from workers     treatment of employees and disciplinary action as        workers, review of workers'      submitted to TOW 5/09.
                                                                                                             the reason of issuing the warning letter is not                                                                                                                               Standards Ltd. to complete this training program which consist of a 2                 and procedures and a confirmed training date by           The factory did not send                                                                                   by August 1,     per PC remediation plan. Compliance officer              personnel files.
                                                                                                             mentioned or ticked, at a time 3 warning is                                                                                                                                   day disciplinary and CoC training and a consultancy 4 months program.                 11/1/05.                                                  remediation items by 11/1/05,                                                                              2006.            informed that they conducted training for
                                                                                                             given in one letter and terminated without verify                                                                                                                             See attached list of disciplinary procedures as a reference of what                                                                             asking that it be given to TOW on                                                                                           supervisor/management on said issues but monitors
                                                                                                             the reason.                                                                                                                                                                   your system should resemble. Please send Top of the World/Outdoor                                                                               December visit. Factory has                                                                                                 could not find training schedule on this specific
                                                                                                                                                                                                                                                                                           Cap the factory’s revised policies and procedures relating to discipline                                                                        established and posted disciplinary                                                                                         issue. The monitors did not find evidence of three
                                                                                                                                                                                                                                                                                           by and a set date for the training November 1, 2005.                                                                                            policy and procedures. Training has                                                                                         times warning policy, either, but found some warning
                                                                                                                                                                                                                                                                                                                                                                                                                                           occurred for management. Training                                                                                           letters with workers' responses on them. No worker
                                                                                                                                                                                                                                                                                                                                                                                                                                           will be provided to the workers by                                                                                          was terminated during the last 12 months as a result
                                                                                                                                                                                                                                                                                                                                                                                                                                           the Social Compliance manager the                                                                                           of disciplinary action.
                                                                                                                                                                                                                                                                                                                                                                                                                                           month of July.




Training of Management in                                   Employers will provide training to managers      No formal training is provided on disciplinary                                                                                      management and                            The factory will attend a training of supervisors/management on             11/1/2005 Factory Response:                                         The factory has chosen not to hire Copies of the policy and         ODC to discuss when training will be   Factory will     As per PC remediation plan the factory did not hire   Review the training schedule, Factory does periodic
Disciplinary Practices                                      and supervisors in appropriate disciplinary      systems                                                                                                                             workers interview                         treatment of employees and disciplinary actions. We are sending the                   The factory is arranging training programs for            Lift Standards for the training. They procedures are kept in        given to workers.                      send signed      any outside consultant to provide training on         interview management/         training--sign in sheets
                                                            practices                                                                                                                                                                                                                      training outline from Lift-Standards and we, Top of the World/Outdoor                 supervisors/management on treatment of employees          have hired a person to help the       files at ODC and TOW.                                                documentation    treatment of employees and disciplinary action.       supervisor and workers.       for training to be
                                                                                                                                                                                                                                                                                           Cap, fully recommend that [factory] contract with Lift-Standards to                   and disciplinary actions. We will send revised policies   factory become compliant. The                                                                              from workers     Compliance officer informed that they conducted                                     submitted to TOW 5/09.
                                                                                                                                                                                                                                                                                           complete this training program which consist of a 2 day disciplinary                  and procedures and a confirmed training date by           factory did not send remediation                                                                           by August 1,     training for supervisor/management on above
                                                                                                                                                                                                                                                                                           and CoC training and the a consultancy 4 month program See attached                   11/1/05.                                                  items by 11/1/05, asking that it be                                                                        2006.            mention issues. But monitors did not find a record of
                                                                                                                                                                                                                                                                                           list of disciplinary procedures as a reference of what your system                                                                              given to TOW on December visit.                                                                                             Disciplinary Practices on the training schedule.
                                                                                                                                                                                                                                                                                           should resemble. Please send Top of the World/Outdoor Cap the                                                                                   Factory has established and posted
                                                                                                                                                                                                                                                                                           factory’s revised policies and procedures relating to discipline by and a                                                                       disciplinary policy and procedures.
                                                                                                                                                                                                                                                                                           set date for the training November 1, 2005.                                                                                                     Training has occurred for
                                                                                                                                                                                                                                                                                                                                                                                                                                           management. Training still needs to
                                                                                                                                                                                                                                                                                                                                                                                                                                           be provided to the workers.

Records Maintenance                                          Employers will maintain written records of      No written records maintained for the number of                                                                                     Management interview                      The factory will attend a training of supervisors/management on             11/1/2005 Factory Response:                                         The factory has chosen not to hire       Copies of the policy and   ODC has requested signed               Factory will     Records were maintained for the disciplined or           Review workers personnel
                                                            disciplinary actions taken.                      disciplined workers or separated or fired                                                                                           and personnel file                        treatment of employees and disciplinary actions. We are sending the                   The factory is arranging training programs for            Lift Standards for the training. They    procedures are kept in     documentation of training by the       send signed      migrant workers on a monthly basis. Warning letter       file,
                                                                                                             workers per month, the steps and procedures                                                                                         check                                     training outline from Lift-Standards and we Top of the World/Outdoor                  supervisors/management on treatment of employees          have hired a person to help the          files at ODC and TOW.      manager.                               documentation    was issued and also maintained properly in               migrants/terminated/newly
                                                                                                             of disciplinary actions. Only warning letter is                                                                                                                               Cap fully recommend that [factory] contract with Lift-Standards to                    and disciplinary actions. We will send revised policies   factory become compliant.                                                                                  from workers     respective files. Reviewing the workers' personnel       workers list, interview
                                                                                                             issues and also maintained properly with                                                                                                                                      complete this training program which consist of a 2 days disciplinary                 and procedures and a confirmed training date by           The factory did not send                                                                                   by August 1,     files we did not find any evidence of termination        management and workers.
                                                                                                             respective files. Warning come termination                                                                                                                                    and CoC training and the a consultancy 4 months program . We are                      11/1/05.                                                  remediation items by 11/1/05,                                                                              2006.            resulting from warning.
                                                                                                             letter was found but no personnel file/ any                                                                                                                                   also sending you a list of disciplinary procedures as a reference of                                                                            asking that it be given to TOW on
                                                                                                             paper of that person was available.                                                                                                                                           what your system should resemble. Please send Top of the                                                                                        December visit. Factory has
                                                                                                                                                                                                                                                                                           World/Outdoor Cap the factory’s revised policies and procedures                                                                                 established and posted disciplinary
                                                                                                                                                                                                                                                                                           relating to discipline and a confirmed training date by November 1,                                                                             policy and procedures. Training has
                                                                                                                                                                                                                                                                                           2005.                                                                                                                                           occurred for management. Training
Verbal abuse                                                Employers will prohibit screaming,               Verbal abuse occurs in case of fail to achieve                                                                                      workers and                               The factory will attend a training of supervisors/management on             11/1/2005 Factory Response:                                         The factory has chosen not tothe
                                                                                                                                                                                                                                                                                                                                                                                                                                           to be provided to the workers hire    Copies of the policy and ODC has requested signed                    Factory will     The factory has developed a policy and procedure         Focus group discussion,          Factory does periodic
                                                            threatening, or demeaning verbal language.       the production target, unauthorized absent and                                                                                      supervisors interview                     treatment of employees and disciplinary actions. We are sending a                     The factory is arranging training programs for            Lift Standards for the training. They procedures are kept in   documentation of training by the            send signed      on disciplinary action. However, the factory has not     workers and management           training--sign in sheets
                                                                                                             mistake in works. Workers has to stand in front                                                                                     and group discussion.                     training outlined from Lift-Standards and we Top of the World/Outdoor                 supervisors/management on treatment of employees          have hired a person to help the       files at ODC and TOW     manager.                                    documentation    hired any outside consultant to provide training on      interview and factory tour.      for training to be
                                                                                                             of the sewing line for half and hour because of                                                                                                                               Cap fully recommend that [factory] contract with Lift-Standards to                    and disciplinary actions. We will send revised policies   factory become compliant.             and employee interviews.                                             from workers     treatment of employees and disciplinary action as                                         submitted to TOW 5/09
                                                                                                             absent.                                                                                                                                                                       complete this training program. Please send Top of the                                and procedures and a confirmed training date by           The factory did not send                                                                                   by August 1,     per PC remediation plan. Compliance officer
                                                                                                                                                                                                                                                                                           World/Outdoor Cap the factory’s revised policies and procedures                       11/1/05.                                                  remediation items by 11/1/05,                                                                              2006.            informed that they conducted training for
                                                                                                                                                                                                                                                                                           relating to discipline and a confirmed training date by November 1,                                                                             asking that it be given to TOW on                                                                                           supervisor/management on said issues but monitors
                                                                                                                                                                                                                                                                                           2005.                                                                                                                                           December visit. Factory has                                                                                                 could not find a record of this specific issue on the
                                                                                                                                                                                                                                                                                                                                                                                                                                           established and posted disciplinary                                                                                         training schedule. Verbal abuse persists. One of the
                                                                                                                                                                                                                                                                                                                                                                                                                                           policy and procedures. Training has                                                                                         supervisors was observed to be screaming at a
                                                                                                                                                                                                                                                                                                                                                                                                                                           occurred for management Thru                                                                                                worker during the factory tour.
                                                                                                                                                                                                                                                                                                                                                                                                                                           worker interviews, no evidence of
Monetary Fines and                                          Employers will not use monetary fines and        Workers attendance was omitted from the                                                                                             worker and supervisor                     The factory will immediately STOP the practice of omitting workers          ######## Factory Response:                                          continued verbal abuse was
                                                                                                                                                                                                                                                                                                                                                                                                                                           The factory has stopped the found. Copy of attendance                                                                       There was no evidence of omissions with the              Workers and management
Penalties                                                   penalties for poor performance                   attendance register and result into salary                                                                                          interview and                             attendance from the attendance register; this is a form of informal                  The factory will immediately STOP the practice of          practice of omitting workers          register kept in files.                                                               attendance book-keeping and there were no salary         interview, time records and
                                                                                                             deduction because of doing wrong / mistake in                                                                                       attendance and                            punishment. Please send Top of the World/Outdoor a copy of the                       omitting workers attendance from the attendance            attendance from attendance                                                                                                  deduction for doing a mistake with the job.              payroll sheets review.
                                                                                                             the work                                                                                                                            payment record                            attendance record for the embroidery section for the months of                       register. The factory shall send a copy of the             register.
                                                                                                                                                                                                                                                 reviewed                                  September and October 2005 and a letter from top management that                     attendance register record for the embroidery section
                                                                                                                                                                                                                                                                                           this practice has immediately been corrected by November 15, 2005.                   as requested for the months of Sept. and Oct. 2005
                                                                                                                                                                                                                                                                                                                                                                                and a letter from management stating as such by
                                                                                                                                                                                                                                                                                                                                                                                11/15/2005.

Monetary Fines and                                          Employers will not use monetary fines and        Workers attendance is turned into absent                                                                                            Attendance record                         The factory will immediately STOP the practice of omitting workers          11/1/2005 The factory will immediately STOP the practice of         The factory has stopped the              1. Copy of attendance                                                              From record review of last 12 months as well as          Workers and management
Penalties                                                   penalties for poor performance                   because of doing wrong which results into                                                                                           review and                                attendance from the attendance register; this is a form of informal                   omitting workers attendance from the attendance           practice of omitting workers             register kept in files.                                                            worker interviews we did not find any evidence or        interview, time records, leave
                                                                                                             wages deduction. Approved leave is also                                                                                             management interview                      punishment. Please send Top of the World/Outdoor a copy of the                        register. The factory shall send a copy of the            attendance from attendance                                                                                                  heard any complaints from workers regarding the          register, workers personnel
                                                                                                             deducted from the salary if special permission                                                                                      and personnel files                       attendance record for the embroidery section for the months of                        attendance register record for the embroidery section     register.                                                                                                                   recording of working hours or salary deductions due      files and payroll sheets
                                                                                                             for leave with pay is given by the production in                                                                                    reviewed, worker                          September and October 2005 and a letter from top management that                      as requested for the months of Sept. and Oct. 2005                                                                                                                                    to mistakes with the job. Nor did we find any            review.
                                                                                                             charge from the floor                                                                                                               interview.                                this practice has immediately been corrected by November 15, 2005.                    and a letter from management stating as such by                                                                                                                                       evidence of salary deductions for approved leave.
                                                                                                                                                                                                                                                                                                                                                                                 11/15/2005.
Other (Grievance                                                                                                                                                 Worker handbook is not provided                                                 Attendance record                         The factory shall immediately give all workers a worker handbook, also 11/1/2005 Factory Response:                                              The factory provided copy of             Copy of handbook kept in ODC reviewing and working with                            Workers hand book has been distributed to workers        Workers interview, focus         Factory to provide copy
Procedure)                                                                                                                                                       to all the workers- Workers are                                                 review and                                the factory shall post their grievance and disciplinary policies on notice &          The factory shall immediately give all workers a worker   handbook. Currently the factory is       files.                   factory on revised handbook and                           as per remediation plan but hand book was the old        group discussion. Interview      of new handbook 5/09.
                                                                                                                                                                 not aware about the grievance and                                               management interview                      boards through out the factory and we recommend that you have the          11/15/200 handbook, also the factory shall post their grievance      in the process of updating their                                  training of workers.                                      one. The workers are not accustomed to dropping          with compliance and welfare
                                                                                                                                                                 disciplinary system and procedure.                                              and personnel files                       WWC start collecting the suggestion box comments, review the               5          and disciplinary polices on notice boards through out     handbook and will submit a new                                                                                              complaints/suggestions in the designated boxes.          officer, review of the
                                                                                                                                                                 Some of the workers only know                                                   reviewed, worker                          complaints/suggestions, and give to management. Management                            the factory. The factory will send photos of the posted   handbook by Feb. 15, 2006.                                                                                                  They considered that complaint boxes put in the          complaint register and
                                                                                                                                                                 about the existence of suggestion                                               interview and WWC                         should respond back to the WWC within a specified period of time and                  policies and a new procedure for the involvement of       Outdoor Cap to check for new                                                                                                toilet do not resolve the workers' problems. Monitors    complaint file.
                                                                                                                                                                 box but they are not clear and                                                  member interview                          the WWC can post the resolutions to the problems or comment on a                      the WWC is in the process by 11/1/05.                     handbook on Feb 06 visit.                                                                                                   also found that no complaint was recorded in the
                                                                                                                                                                 confident about the credibility and                                                                                       notice board soothe employees can see the effectiveness of this                                                                                                                                                                                                             complaint register for the last few months. Complaint
                                                                                                                                                                 effectiveness of the suggestion                                                                                           communication system. Send Top of the World/Outdoor Cap photos of                                                                                                                                                                                                           and suggestion boxes were opened by the Welfare
                                                                                                                                                                 box                                                                                                                       the posted grievance and disciplinary policies and a new procedure for                                                                                                                                                                                                      Officer on a fortnightly basis. Although as per
                                                                                                                                                                                                                                                                                           the involvement of the WWC in this process by November 1, 2005.                                                                                                                                                                                                             remediation plan they have to be opened by WWC.




                                                                                                                                                                                                                                                                                                                                                                2
                                                                                                                                                                                     IEM Findings                                                                                                                                                                                       Remediation                                                                                                                        Updates (Cite Date of Follow up)                                            Third Party Verification                                            Company Verification Follow up
FLA Code/ Compliance issue      Country Law/Legal Reference                   FLA Benchmark                                     Non-compliance                    Risk of Non-compliance       Evidence of Non-   If not corroborated,   Sources/Documentation         Notable                                PC Remediation plan                                 Target                  Factory Response (Optional)                 Company follow up (Cite date of follow           Documentation                      Company Follow up             Documentation                    Third Party Verification                        Documentation             Company Follow up (Cite       Documentation
                                                                                                                                                                                                  compliance           explain why        used for corroborating      Features                                                                                  Completion                                                                            up)                                                                                                                             (IEV: 12 September, 2007)                                                   date of planned or follow up
                                                                                                                                                                                               (uncorroborated)                                                     implemented                                                                                    Date                                                                                                                                                                                                                                                                                               visit, if appropriate)
                                                                                                                                                                                                                                                                     by Factory
                                                                                                                                                                                                                                                                   Management or
                                                                                                                                                                                                                                                                      Company
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
Fire Safety Health and                                          Employer will comply with applicable health    There is no fire fighting team trained on the                                                                             Management interview,                     1. The factory shall contact the local fire marshal and have a training      11/1/2005 Factory Response:                                           1. The factory did not send                1. The factory has            Factory sent copy of The Letter of                       The factory has posted the names of fire fighting         Communication with              Updated fire team notice
Safety legal compliance                                         and safety laws and regulations. In any        issue only 3 persons name are written as fire                                                                             records reviewed and                      conducted with the current fire fighting team. Also, have the local fire               1. The factory shall contact the local fire marshal and     remediation items by 11/1/05,              established and trained a     Appointment of a part-time doctor that                   team members on the notice board of the production        Compliance Officer, interview   boards posted--factory to
                                                                case where laws and code of conduct are        fighter for the full factory who are not trained                                                                          workers interview                         fighting team Keep meeting notes from this training on file. Training                  have a training conducted with the current fire fighting    asking that it be given to TOW on          fire fighting team, Dec.      started on 4/16/06 that will be in the                   floor, but some of these team members had already         with firefighting team and      supply photos of notice
                                                                contradictory, the higher standards will       and workers also recognize these persons as                                                                                                                         should be done quarterly. The factory will train all employees on who                  team. The factory will keep meeting notes from this         December visit.                   2.       05. Meeting notes and         factory 2 days a week and on call.                       left the factory. Firefighting team is not known to the   workers. Inspection of the      boards 5/09.
                                                                apply. The factory will possess all legally    responsible for fire fighter.                                                                                             Personnel files                           the fire fighting team members are on a quarterly basis. Meeting notes                 training on file. The factory will send photos of the       The factory sent a copy of their first     photos of the members         Advised factory by law that a doctor                     workers. Photos of the firefighting team were not         fire fighting equipment and
                                                                required permits                                                                                                                                                         reviewed                                  are to be kept. Photos on the fire fighting team need to be posted in                  posted fire fighting team photos at the factory by          aid policy on 10/31/05. We are             were sent.                    should be on the premises at all times                   posted in the canteen and production area. The            the notice board on the
                                                                                                                                                                                                                                                                                   the canteen, production area, at all entrances and any place                           11/1/2005.                                                  requesting a procedure from the            2. The factory sent a         but this is a step in the right direction.               factory has a first aid policy and it was posted.         production floor.
                                                                                                                                                                                                                                                                                   employees gather. The training will be completed by November 1,                                                                                    factory stating who is responsible         copy of their first aid       Also sent was nurse's certificate.                       There is no full-time qualified medical staff. The
                                                                                                               No first aid policy and no doctor found, only a                                                                                                                     2005 and meeting notes sent to Top of the World/Outdoor Cap. Send                         2. The factory has already created a first aid policy.   for maintaining the first aid boxes by     policy on 10/31/05. The                                                                factory doctor comes in twice a week (Wednesday
                                                                                                               nurse (without professional academic and                                                                                                                            photos of the fire fighting team photos as they are posted in all areas                   The factory will hire a qualified medical practitioner   December 15, 2005.          The factory    factory sent 2 letters from                                                            & Saturday) for 2-3 hours.
                                                                                                               experience certificate) found, no first aid team                                                                                                                    of the factory by November 1, 2005.                                                       and at least one qualified compounder and nurse as       did not send evidence of an                hospital personnel for
                                                                                                               found in the facility                                                                                                                                               2. Per the Bangladesh Factories Rules, 1979; The ambulance room or                        soon as possible. The factory will send us evidence      appointed medical practitioner that        Mrs. *** *** (***) from ***
                                                                                                                                                                                                                                                                                   dispensary shall be in charge of a qualified medical practitioner                         this has been completed as soon as possible.             is to be on-call at all times during       Hospital, as evidence she
                                                                                                                                                                                                                                                                                   assisted by at least one qualified compounder and nurse and such                                                                                   factory hours. Please send medical         has been certified.
                                                                                                                                                                                                                                                                                   subordinate staff as the Chief Inspector may direct. The medical                                                                                   certificate and contract of the
                                                                                                                                                                                                                                                                                   practitioner shall always be available on call during working hours.                                                                               appointment by December 15,
                                                                                                                                                                                                                                                                                   The factory shall create a first aid policy immediately. The factory shall                                                                         2005.
                                                                                                                                                                                                                                                                                   hire a qualified medical practitioner and at least one qualified
Evacuation Procedure                                          All applicable legally required or               Fire safety policy is not in local language and                                                                           Management interview                      In accordance with Section 22 of the Factories Act, 1965, and                11/1/2005 Factory Response:                                           The factory did not send              Confirmed thru worker                                                                       Fire safety policy written in local language and      Communication with
                                                              recommended elements of safe evacuation          not posted and not available for workers. Fire                                                                            and visual inspection.                    Instruction Number F.S.O. CD/4409/4(120) dated 9/11/97 of the Fire                     Fire safety policy already been made and posted in          remediation items by 11/1/05,         interviews, copies of                                                                       posted on the notice board. The factory arranges fire Compliance Officer, interview
                                                              (such as posting of evacuation plans,            drill is not arranged every months as mentioned                                                                           Records and register                      Service, each factory shall conduct at least 1 fire escape drill every                 the notice board. Fire drills are now kept in a log. Will   asking that it be given to TOW on     notes kept in files.                                                                        drills on a monthly basis and keeps a log. Workers    with firefighting team and
                                                              unblocked aisles/exits, employee education,      in the factory internal policy. Workers are not                                                                           reviewed                                  month, and maintain proper details of the drill. The factory shall start               send copy of log and photos of monthly drill for the        December visit. Factory has now                                                                                                   corroborated with this information.                   workers. Inspection of the
                                                              evacuation procedures, etc.) shall be            trained on fire safety and first aid policy.                                                                                                                        immediately adhering to local law by conducting a monthly fire drill.                  month of Sept and Oct. 2005 by 11/1/2005.                   posted the fire safety policy in the                                                                                                                                                    fire fighting equipment and
                                                              complied with and workers shall be trained in                                                                                                                                                                        These fire drills should be kept in a log. Please send Top of the                                                                                  local language. Factory conducts                                                                                                                                                        the notice board on the
                                                              proper safety, first aid, and evacuation                                                                                                                                                                             World/Outdoor Cap a copy of the fire drill log and photos of the drill for                                                                         monthly fire drill - confirmed by TOW                                                                                                                                                   production floor.
                                                              procedures                                                                                                                                                                                                           the month of September and October 2005 by November 1, 2005.                                                                                       through worker interviews, Dec. 05.



Safety Equipment                                              All safety and medical equipment (such as        First aid kits are not well-stocked and no one                                                                            Visual inspection and                     According to the Factories Act 1965, Section 44, and Factories Rules         11/1/2005 Factory Response:                                           The factory did not send                                                 ODC to check all first aid kits at                       The monitors randomly checked 4 first-aid boxes         Interview nurse, compliance       First aid boxes are now
                                                              fire fighting equipment, first aid kits, etc.)   supervise the first aid boxes                                                                                             management interview                      1979, Section 55 every factory shall provide and maintain at least 1                   The factory has already created a policy and                remediation items by 11/1/05,                                            factory during Feb. visit. ODC found                     during walk-through and found two boxes empty.          officer and general workers,      locked to prevent theft.
                                                              shall be in place, maintained as prescribed                                                                                                                                                                          first aid box with its prescribed contents for every 150 workers, in the               procedure for the kits to be checked weekly for re-         asking that it be given to TOW on                                        first aid kits to be stocked well. Also                  There were only Nuspa tab – 2 nos., Abomine tab – check the first aid boxes.              All floor supervisors have
                                                              and accessible to the employees                                                                                                                                                                                      charge of a person trained in the use of first aid. The factory shall                  stocking. The factory will send photos of the               December visit. TOW found that                                           was told that the factory will model                     2 nos. and a piece of dirty cotton in the two first-aid                                   keys to boxes.
                                                                                                                                                                                                                                                                                   comply with local law and properly stock all first aid kits at the factory             completely stocked kits and a copy of the new policy        first aid kits still not well stocked in                                 their first aid kits as the one TOW                      boxes of the 3rd floor. Supervisor informed that a
                                                                                                                                                                                                                                                                                   as stated above and create a policy and procedure for the kits to be                   and procedures for re-stocking by 11/1/05.                  Dec. 05, TOW will send a fully                                           sends.                                                   requisition was prepared by nurse to buy the
                                                                                                                                                                                                                                                                                   checked weekly for re-stocking. Please send Top of the                                                                                             stocked first aid kit as an example                                                                                               medicine. Nurse showed the requisition paper to the
                                                                                                                                                                                                                                                                                   World/Outdoor Cap photos of the completely stocked first aid kits and                                                                              by 2-15-06. Outdoor Cap to check                                                                                                  monitors during the medical center visit. First-aids
                                                                                                                                                                                                                                                                                   a copy of the new policy and procedures for re-stocking of the first aid                                                                           on February 19 factory follow-up                                                                                                  kits were not well-stocked. Monitors also did not find
                                                                                                                                                                                                                                                                                   kits by November 1, 2005.                                                                                                                          visit.                                                                                                                            any evidence of weekly checking for re-stocking.

PPE                                                           Workers shall wear appropriate protective        PPE are not provided to the workers (hand                                                                                 Visual inspection and                     The factory shall immediately supply all PPE to necessary employees          11/1/2005 Factory Response:                                           The factory did not send                                                 ODC to check for PPE used by                             Factory management supplied sufficient PPE (hand Interview with the section       On location auditor to
                                                              equipment (such as gloves, eye protection,       gloves- iron section, mask - overlock machine,                                                                            management interview                      and train the employees on the use of the protective equipment.                        The factory shall supply all PPE to necessary               remediation items by 11/1/05,                                            workers on factory tour. ODC toured                      gloves in iron section, mask for the over-lock       personnel in-charge, Workers confirm use of PPE 5/09
                                                              hearing protection, respiratory protection,      ear plug - Kanasi special and bartek machine)                                                                             and workers interview                     Please send photos of employees wearing required PPE by November                       employees as soon as possible and train the                 asking that it be given to TOW on                                        the factory and saw workers using                        machine and mask and hand gloves to protect          and management interview,
                                                              etc.) to prevent unsafe exposure (such as        and no training on the use of PPE is provided                                                                                                                       1, 2005.                                                                               employees on the use of the protective equipment.           December visit. TOW found again                                          PPE. Several photos were taken and                       thinner hazard). But hand gloves were not used in    floor visit.
                                                              inhalation or contact with solvent vapors,       to workers                                                                                                                                                                                                                                                 The factory will send photos as soon as possible            that PPE was not provided to                                             on file.                                                 the ironing section. Monitors found that enough hand
                                                              noise, dust, etc.) to hazardous elements                                                                                                                                                                                                                                                                                                                                workers Dec. 05. Outdoor Cap to                                                                                                   gloves were stocked in a room very close to the
                                                              including medical waste.                                                                                                                                                                                                                                                                                                                                                check again on Feb. 19th visit.                                                                                                   ironing section. Masks were not used for the over-
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        lock machine. Thinner was not used during the audit
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        process.

Chemical Management                                           All chemicals and hazardous substances           Thinner is used without labeling and taking any                                                                           Visual inspection                         The factory shall immediately label all chemical in the local language       11/1/2005 Factory Response:                                           The factory did not send           Tour of factory.                                                                               The monitoring team found that thinner was                Floor visit, review of the
                                                              should be properly labeled and stored in         safe measure                                                                                                                                                        and English and post Material Safety Data Sheets (MSDS) for all                        The factory has already labeled all chemicals in the        remediation items by 11/1/05,                                                                                                     appropriately marked and labeled. MSDS was                MSDS of thinner, worker and
                                                              accordance with applicable laws. Workers                                                                                                                                                                             chemicals. Send Top of the World/Outdoor Cap photos of the labeled                     local language and English. They have posted MSDS           asking that it be given to TOW on                                                                                                 properly posted in the spot remover section and           management interview.
                                                              should receive training, appropriate to their                                                                                                                                                                        chemical containers and copies of the MSDS sheets by October 1,                        sheets for all chemicals. The factory will send photos      December visit. Follow-up audit in                                                                                                thinner store room.
                                                              job responsibilities, in the safe use of                                                                                                                                                                             2005.                                                                                  of the labeled containers and copies of the MSDS            Dec. 05 showed thinner marked and
                                                              chemicals and other hazardous substances                                                                                                                                                                                                                                                                    sheets within short time.                                   MSDS checks being followed.




                                                                                                                                                                                                                                                                                                                                                          3
                                                                                                                                                                                            IEM Findings                                                                                                                                                                                        Remediation                                                                                                                     Updates (Cite Date of Follow up)                                             Third Party Verification                                           Company Verification Follow up
FLA Code/ Compliance issue    Country Law/Legal Reference                  FLA Benchmark                                       Non-compliance                            Risk of Non-compliance        Evidence of Non-   If not corroborated,   Sources/Documentation         Notable                                PC Remediation plan                                 Target                  Factory Response (Optional)                    Company follow up (Cite date of follow          Documentation                 Company Follow up             Documentation                    Third Party Verification                          Documentation           Company Follow up (Cite       Documentation
                                                                                                                                                                                                          compliance           explain why        used for corroborating      Features                                                                                  Completion                                                                               up)                                                                                                                       (IEV: 12 September, 2007)                                                   date of planned or follow up
                                                                                                                                                                                                       (uncorroborated)                                                     implemented                                                                                    Date                                                                                                                                                                                                                                                                                            visit, if appropriate)
                                                                                                                                                                                                                                                                             by Factory
                                                                                                                                                                                                                                                                           Management or
                                                                                                                                                                                                                                                                              Company
Machinery Maintenance                                       All production machinery and equipment shall Eye guard with the overlock and bartek                                                                                                  Visual inspection                         The factory shall immediately supply all PPE to necessary employees          11/1/2005 Factory Response:                                              The factory did not send                                            ODC to check for PPE used by                            The eye guard was not fixed for the over-lock and   Floor visit, worker and               Proper guards are on all
                                                            be maintained, properly guarded, and         machine is not used and some cases the guard                                                                                                                                      and train the employees on the use of the protective equipment.                        The factory shall supply all PPE to necessary                  remediation items by 11/1/05,                                       workers on factory tour. ODC toured                     bartek machine. When the monitor asked about the management interview.                    machines. To be
                                                            operated in a safe manner                    are not found fixed with the machines                                                                                                                                             Please send photos of employees wearing required PPE by November                       employees as soon as possible and train the                    asking that it be given to TOW on                                   the factory and saw workers using                       eye guard the worker showed it under the table.                                           reconfirmed by on
                                                                                                                                                                                                                                                                                           1, 2005.                                                                               employees on the use of the protective equipment.              December visit. TOW found again                                     PPE. Several photos were taken and                      Workers and supervisors did not receive any                                               location auditor 5/09.
                                                                                                                                                                                                                                                                                                                                                                                  The factory will send photos as soon as possible               that PPE was not provided to                                        on file.                                                training on the importance of machine guard and the
                                                                                                                                                                                                                                                                                                                                                                                                                                                 workers Dec. 05. Outdoor Cap to                                                                                             necessity of its use. New findings: No needle guard
                                                                                                                                                                                                                                                                                                                                                                                                                                                 check again on Feb. 19th visit.                                                                                             on the sewing machine.



Sanitation in Facilities                                    All facilities including factory buildings,       Number of male toilet is sufficient and                                                                                            Visual inspection and                     1. We suggest that the factory re-allocated the number of restrooms          11/1/2005 Factory Response:                                              The factory did not send                                            The factory has realigned the # of                      The factory allocated 41 toilets for female workers        Inspection of the toilets,     Per [internal monitor]
                                                            toilets, canteens, kitchens, and clinics, shall   according the local law. But female toilet need                                                                                    records review, group                     between male and female, you have too many for the men and not                         1. We will take action for this and will send you our          remediation items by 11/1/05,                                       bathrooms for women and men to                          and 15 for male workers. Water supply was                  group discussion and           factory provides soap
                                                            be kept clean and safe and be in compliance       to be - 36 for 900 female workers but factory                                                                                      discussion with                           enough for the females. The total number of female toilets required by                 plans to comply with local law by 11/1/2005.                   asking that it be given to TOW on                                   ensure enough for women giving the                      available during the factory tour but washing facility     interview with workers,        and sandals but both are
                                                            with applicable laws                              has 5 female toilet per floor and total - 15                                                                                       workers                                   law should be increased from 15 to 36 by November 1, 2005. If after                                                                                   December visit.                   1.                                women 41 and the men 15.                                was overcrowded. The dinning rooms (canteen) of            review of records/notice       often missing due to theft.
                                                                                                              toilets                                                                                                                                                                      re-allocation of the bathrooms, you still do not have enough for the                      2. We have taken necessary action for this. We will         December 05 follow-up audit found                                                                                           2nd, 3rd , 4th and 5th floor are spacious enough for       board.
                                                                                                                                                                                                                                                                                           women, then you will have to install new facilities for the women to                      send all information by 11/1/2005 as requested.             the factory still in the process of                                                                                         the workers. The dinning room of the 1st floor was
                                                                                                              The canteen are not spacious enough to                                                                                                                                       bring your total to 36. Please send Top of the World/Outdoor Cap                                                                                      increasing the number of toilets to                                                                                         used by both the ground floor and 1st floor workers.
                                                                                                              accommodate all the workers, as a result some                                                                                                                                your plans to comply with local law by increasing the number of female                                                                                the required level. IN an effort to                                                                                         At present factory management provides lunch in 2
                                                                                                              workers take their lunch sitting on the floor.                                                                                                                               totals to 36 by November 1, 2005.                                                                                                                     fulfill this requirement the factory                                                                                        seating for the workers of these two floors and
                                                                                                              Sometimes water supply and washing facility is                                                                                                                                                                                                                                                                                     has opened the 4th floor toilets to                                                                                         therefore the space was appropriate for the workers.
                                                                                                              not available and sufficient during lunch hour.                                                                                                                              2. We recommend that the factory stagger the lunch times to                                                                                           the workers.                   2. The                                                                                       New Findings: The toilets were clean but sandal
                                                                                                                                                                                                                                                                                           accommodate all workers comfortable during lunch breaks if possible,                                                                                  factory is now staggering the lunch                                                                                         and soap were not there. Workers went to the toilet
                                                                                                                                                                                                                                                                                           otherwise you will need to enlarge the canteen to accommodate all the                                                                                 times to alleviate over full canteen                                                                                        bare foot.
                                                                                                                                                                                                                                                                                           workers, and to supply water and washing facilities in the canteen area                                                                               area.
                                                                                                                                                                                                                                                                                           for the employees. Send Top of the World/Outdoor Cap your plans to
Worker Participation                                        Workers should be involved in planning for        No workers safety committee found and no                                                                                           Workers and                               The factory shall create and appoint some employees to a worker              11/1/2005 Factory Response:                                              The factory did not send                   Photos of members sent                                                           The factory formed a fire safety committee and it       Review fire drill register,       Current fire team posted.
                                                            safety, including through worker safety           involvement or workers found                                                                                                       management interview                      safety committee by November 1, 2005. This committee shall meet at                     The factory shall create a worker safety committee by          remediation items by 11/1/05,              and kept in file.                                                                has posted the name of fire safety team on the          workers interview, visual
                                                            committees                                                                                                                                                                                                                     least quarterly and meeting notes must be kept. Please send Top of                     11/1/05. This committee shall meet at least quarterly          asking that it be given to TOW on                                                                                           notice board in the production floor but some team-     inspection and focus group
                                                                                                                                                                                                                                                                                           the World/Outdoor Cap a list of all members of the committee and a                     and meeting notes must be kept. The factory will send          December visit. The factory has                                                                                             members already left the factory. Management also discussion.
                                                                                                                                                                                                                                                                                           plan of upcoming meetings for this committee by November 1, 2005.                      a list of all members of the committee and a plan of           established a workers safety                                                                                                acknowledged it. General workers were not familiar
                                                                                                                                                                                                                                                                                                                                                                                  upcoming meeting by 11/1/05.                                   committee.                                                                                                                  with the fire fighting teams. Photos of the fire safety
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             team were not posted in the canteen and production
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             area.



Other (Childcare facility)                                                                                    Child care facility in not functional, workers are                                                                                 Visual inspection and                     The factory must ensure that the childcare facility is clearly away from     11/1/2005 Factory Response:                                              The factory did not send                                            ODC to discuss child care issue with                    The child care centre is still not functional and it has   Worker and management          Child care center has
                                                                                                              not aware about the facility. Child care room is                                                                                   worker interview                          any production area. The childcare facility must be kept clear of all                  Now it is impossible to us for shifting the childcare          remediation items by 11/1/05,                                       factory management at Feb. 06 visit                     yet to be moved to a different location.                   interviews, visual Inspection. been cleared but still not
                                                                                                              in the main building where production is                                                                                                                                     obstacles that are not related to childcare. The factory must now                      center from the production floor. But in the future, we        asking that it be given to TOW on                                   ODC toured child care facility which is                                                                                                           in use. Target completion
                                                                                                              ongoing not in a separate building                                                                                                                                           promote the use of the child care facility to the employees. We                        shall try to shift child care from the production floor.       December visit. The factory is no                                   located in the production facility, no                                                                                                            by 11/09.
                                                                                                                                                                                                                                                                                           recommend the factory contract with Lift-Standards to complete a                       Now the factory promotes the use of the child care             longer using the facility for uniform                               children are enrolled in child care
                                                                                                                                                                                                                                                                                           consultancy training to help bring many different areas of the factory                 facility to the employees. We are taking the                   storage. Employees are aware                                        facility at this time.
                                                                                                                                                                                                                                                                                           into compliance, by doing this the female workers will be asked what                   necessary action to make day care center functional.           other facility exists and is functional,
                                                                                                                                                                                                                                                                                           would make the child care acceptable for them and then this                            We shall send information about the daycare center by          however it is not being used.
                                                                                                                                                                                                                                                                                           information would be brought to management for further discussion.                     11/1/2005.                                                     Outdoor Cap will check at Feb.
                                                                                                                                                                                                                                                                                           Send Top of the World/Outdoor Cap the training date that is confirmed                                                                                 follow-up audit.
                                                                                                                                                                                                                                                                                           with Lift-Standards for the consultancy training by November 1, 2005,
                                                                                                                                                                                                                                                                                           see attached information regarding this program.
Other (Qualification of the                                                                                   Technical staff (nurse and electrician i.e. in-                                                                                    Personnel File review                     The factory shall create a first aid policy immediately. The factory shall   11/1/2005    The factory has already created a first aid policy. The     The factory sent a copy of their first                              ODC to discuss with factory                             The personnel file maintained by the nurse contains        Interview with nurse and       On location auditor to
Medical Practitioner)                                                                                         charge of safety and health matters) do not                                                                                                                                  hire a qualified medical practitioner and at least one qualified             &            factory will hire a qualified medical practitioner and at   aid policy on 10/31/05. We are                                      management about hiring a medical                       job application, appointment letter, employment            other technical persons,       confirm personnel files for
                                                                                                              have any academic and professional certificate                                                                                                                               compounder and nurse as required by local law by October 1, 2005.            11/15/200    least one qualified compounder and nurse as soon as         requesting a procedure from the                                     practitioner, factory has hired a                       contract, nationality and character certificate. The       review of personnel file,      technical persons 5/09
                                                                                                              and degree. They have only experience of                                                                                                                                     Send Top of the World/Outdoor Cap a copy of the first aid policy and         5            possible. The factory will send us evidence this has        factory stating who is responsible                                  medical practitioner part-time.                         nurse has completed only three and half months             management interview.
                                                                                                              working in their respective field but even those                                                                                                                             copies of the medical staff’s certificates and photos by November 1,                      been completed as soon as possible.                         for maintaining the first aid boxes by                                                                                      course on "Theoretical and practical nurse training
                                                                                                              experience certificate is not maintained in the                                                                                                                              2005 as evidence.                                                                                                                                     December 15, 2005. The factory did                                                                                          course" from Khulna Surgical & Medical Hospital
                                                                                                              personnel file                                                                                                                                                                                                                                                                                                                     not send evidence of an appointed                                                                                           (Pvt.) Ltd and the certificate was available in the
                                                                                                                                                                                                                                                                                                                                                                                                                                                 medical practitioner that is to be on-                                                                                      personnel file. The factory management could not
                                                                                                                                                                                                                                                                                                                                                                                                                                                 call at all times during factory hours.                                                                                     provide us personnel file for other technical persons.
                                                                                                                                                                                                                                                                                                                                                                                                                                                 Please send medical certificate and
                                                                                                                                                                                                                                                                                                                                                                                                                                                 contract of the appointment by
7. Freedom of Association and Collective Bargaining
Employers will recognize and respect the right of employees to freedom of association and collective
bargaining
Other                                                                                                                                                              A Worker Welfare Committee has                                                Attendance record                         The factory shall request the WWC to have monthly meetings starting 11/1/2005             The WWC is now arranging meetings and help to               TOW found evidence of increased                                     ODC reviewing and working with                          The Worker Welfare Committee (WWC) consisted       Focus group discussion,                On location auditor to
                                                                                                                                                                   been selected during Jan 05. But                                              review and                                immediately, document the meetings and help to promote this           &                   promote this committee with the workers. The factory        maternity benefits and financial                                    factory on revised handbook and                         of 17 members. Compliance officer is the Chairman management and worker                   confirm WWC meeting
                                                                                                                                                                   the committee is ineffective and                                              management interview                      committee with the workers. Post photos of the WWC members in all 11/15/200               shall send meeting notes for Oct. and photos of the         assistance for housing for workers                                  training of workers.                                    of this committee. The factory posted the photo of interview, visual inspection.          5/09
                                                                                                                                                                   workers are not familiar with the                                             and personnel files                       areas of the factory where employee may gather, so the general        5                   WWC members posted at the factory by 11/15/2005.            through the WWC involvement                                                                                                 WWC members on the notice board in the
                                                                                                                                                                   members and their activities.                                                 reviewed, worker                          employees can identify who their WWC committee members are.                                                                                           during worker interviews in Dec. 05.                                                                                        production floor. But most of the members had left
                                                                                                                                                                                                                                                 interview and WWC                         Send Top of the World/Outdoor Cap meeting notes in the local                                                                                                                                                                                                                      the factory. Workers are not aware of the role and
                                                                                                                                                                                                                                                 members interview                         language and translated into English for the October 2005 meeting and                                                                                                                                                                                                             responsibilities of WWC. Factory did not arrange
                                                                                                                                                                                                                                                                                           photos of the WWC members posted at the factories by November 15,                                                                                                                                                                                                                 WWC meetings on monthly basis and keep the
                                                                                                                                                                                                                                                                                           2005.                                                                                                                                                                                                                                                                             WWC’s meeting minutes as per the remediation plan
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             of PC. Workers are still not familiar with this
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             committee, but were aware that Compliance Officer
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             and Welfare Officer were members of WWC.




                                                                                                                                                                                                                                                                                                                                                                  4
                                                                                                                                                                                                IEM Findings                                                                                                                                                                                         Remediation                                                                                                                    Updates (Cite Date of Follow up)                                            Third Party Verification                                            Company Verification Follow up
FLA Code/ Compliance issue    Country Law/Legal Reference                   FLA Benchmark                                       Non-compliance                              Risk of Non-compliance          Evidence of Non-   If not corroborated,   Sources/Documentation         Notable                                PC Remediation plan                                 Target                  Factory Response (Optional)                  Company follow up (Cite date of follow         Documentation                   Company Follow up             Documentation                    Third Party Verification                         Documentation            Company Follow up (Cite       Documentation
                                                                                                                                                                                                               compliance           explain why        used for corroborating      Features                                                                                  Completion                                                                             up)                                                                                                                        (IEV: 12 September, 2007)                                                   date of planned or follow up
                                                                                                                                                                                                            (uncorroborated)                                                     implemented                                                                                    Date                                                                                                                                                                                                                                                                                           visit, if appropriate)
                                                                                                                                                                                                                                                                                  by Factory
                                                                                                                                                                                                                                                                                Management or
                                                                                                                                                                                                                                                                                   Company
8. Wages and Benefits
Employers recognize that wages are essential to meeting employees’ basic needs. Employers will pay
employees, as a base, at least the minimum wage required by local law or the prevailing industry wage,
whichever is higher, and will provide legally mandated benefits
Wage Benefits Awareness                                     Employers will communicate orally and in           workers are not aware about the salary                                                                                                 worker and                                The factory shall immediately start communicating with the employees         11/1/2005 Factory Response:                                            The factory did not send                 Meeting notes from                                                                  Workers are still not aware of the salary scale and       Worker and management         Factory conducts
                                                            writing to all employees in the language of        fixation, incentive system, entitlement and                                                                                            management interview                      in writing and hold an employee meeting to explain the employee’s                      The factory shall immediately start communicating with       remediation items by 11/1/05,            benefits and wage                                                                   benefits they are entitled to by law. Workers             interview, review of payroll  periodic training--sign in
                                                            the worker the wages, incentive systems,           benefits they are supposed to get                                                                                                      and group discussion                      wages, incentives systems, benefits and bonuses that each employee                     the employees in writing and hold an employee                asking that it be given to TOW on        meeting and attendance                                                              informed that factory did not arrange any training for    sheets and training schedule. sheets from training to be
                                                            benefits and bonuses to which all workers                                                                                                                                                 with workers                              is entitled to by law. Send Top of the World/Outdoor Cap a copy of the                 meeting to explain the employee’s wages, incentives          December visit. The factory              sheet kept in files.                                                                workers on wages, incentive system, benefits and                                        provided to TOW 5/09
                                                            are entitled in that company and under the                                                                                                                                                                                          meeting notes and photos from the employee meetings by November                        systems, benefits and bonuses that each employee is          provided TOW with employee                                                                                                   bonus. Management produced a training schedule
                                                            applicable law                                                                                                                                                                                                                      1, 2005.                                                                               entitled to by law. The factory will send a copy of the      meeting notes on training of wages                                                                                           where there was mention of factory Code of
                                                                                                                                                                                                                                                                                                                                                                                       meeting notes and photos of the meetings held by             and benefits. Also signed                                                                                                    Conduct. No specific training schedule was found
                                                                                                                                                                                                                                                                                                                                                                                       11/1/05.                                                     attendance sheet from the meeting,                                                                                           focusing on above mentioned issues.
                                                                                                                                                                                                                                                                                                                                                                                                                                                    Dec. 05.


Payroll Reporting                                           Accurate and reliable payroll reporting,           Payroll is not in local language, double                                                                                               Sample payroll check                      The factory will change the payroll system to be in the local language       ######## Factory Response:                                             The factory did not send                 Letter is kept in factory                                                           Payroll sheets still not in local language. We have Management and worker                 On location auditor to
                                                            including pay stubs will be provided               attendance record keeping and payment is                                                                                               and documentation                         starting October, 2005. Please send a copy of the payroll records for                 The factory is trying to change the payroll system in         remediation items by 11/1/05,            file.                                                                               checked the time records, payroll sheets and        interview, review payroll             confirm payroll sheet in
                                                                                                               practiced, no payment date is mentioned on the                                                                                         check, management                         October by November 15th to Top of the World/Outdoor Cap. Double                      the local language. Double record keeping is fully            asking that it be given to TOW on                                                                                            interview with some workers. We did not find any    sheet & time records..                local language--copies to
                                                                                                               payroll,                                                                                                                               interview                                 record keeping is not an acceptable practice. This must be stopped                    stopped now.                                                  December visit. The factory                                                                                                  evidence of double record keeping or discrepancies                                        be sent to TOW 5/09
                                                                                                                                                                                                                                                                                                immediately. Please have upper management draft a letter to Top of                                                                                  submitted a letter from upper                                                                                                between records and actual payments made. Payroll
                                                                                                                                                                                                                                                                                                the World and Outdoor Cap stating they will no longer keep double                                                                                   management stating that the                                                                                                  sheets indicate the date of the payment.
                                                                                                                                                                                                                                                                                                books to hire overtime hours in the future.                                                                                                         practice of double books to hide
                                                                                                                                                                                                                                                                                                                                                                                                                                                    overtime has stopped and will not
                                                                                                                                                                                                                                                                                                                                                                                                                                                    continue to occur, Dec. 05.
Pay statement                                               Employers will provide workers a pay               Deduction amount for absenteeism is not                                                                                                Payroll checked and                       The factory will change the payroll system to be in the local language       ######## Factory Response:                                             The factory did not send                 Letter is kept in factory                                                           On the payroll sheet there is an item in the last         Review of payroll sheets &      On location auditor to
                                                            statement each pay period, which will show         clearly mentioned in the payroll                                                                                                       management interview                      starting October, 2005. Please send a copy of the payroll records for                 The factory is trying to change the payroll system in         remediation items by 11/1/05,            file.                                                                               column of the sheet, "Deducted Amount" but no             time records, management        confirm payroll sheet
                                                            earned wages, regular and overtime pay,                                                                                                                                                                                             October by November 15th to Top of the World/Outdoor Cap. Double                      the local language. Double record keeping is fully            asking that it be given to TOW on                                                                                            specification regarding the deduction.                    interview.                      contains detailed
                                                            bonuses and all deductions                                                                                                                                                                                                          record keeping is not an acceptable practice. This must be stopped                    stopped now.                                                  December visit. The factory                                                                                                                                                                                            deduction--copies to be
                                                                                                                                                                                                                                                                                                immediately. Please have upper management draft a letter to Top of                                                                                  submitted a letter from upper                                                                                                                                                                                          sent to TOW 5/09
                                                                                                                                                                                                                                                                                                the World and Outdoor Cap stating they will no longer keep double                                                                                   management stating that the
                                                                                                                                                                                                                                                                                                books to hire overtime hours in the future.                                                                                                         practice of double books to hide
                                                                                                                                                                                                                                                                                                                                                                                                                                                    overtime has stopped and will not
                                                                                                                                                                                                                                                                                                                                                                                                                                                    continue to occur, Dec. 05.
Time-recording system                                       Time worked by all employees, regardless of        Time recording is manual and maintained in the                                                                                         visual inspection and                     The factory has initiated a thumb reader time keeping system, but it is      ######## Factory Response:                                             The factory did not send                                                                                                     Time recording is still done manually and recorded        Review of payroll sheet &       On location auditor
                                                            compensation system, will be documented            register and in the full control of the supervisor                                                                                     worker and                                not currently operating. Until this system is operating correctly, the                The employees are using time cards to clock in and            remediation items by 11/1/05,                                                                                                on the time card only. Supervisor has full control        time records, management        confirms thumb print time
                                                            by time cards or other accurate and reliable       or line in charge, workers have no authority in                                                                                        management and                            factory will need to have alternative reliable system in place, such as               out until the thumb reader system is operational. The         asking that it be given to TOW on                                                                                            over it. Workers only put their signature on the time     interview.                      recorder in addition to
                                                            recording systems such as electronic swipe         recording the in and out time in the factory.                                                                                          worker interview                          time cards that the employees punch, not the supervisors. Please                      factory will send time cards for 10 employees for the         December visit. The factory has                                                                                              cards and have no personal control over the                                               manual time cards,
                                                            cards                                              (Factory has initiated the thumb reader                                                                                                                                          confirm you will have the employees start using time cards to clock in                month of October by 11/15/05.                                 completely installed and is currently                                                                                        recording of their in and out time.                                                       however time is still
                                                                                                               electronic system but it is not functional and will                                                                                                                              and out until the thumb reader system is operational. Please send Top                                                                               using the finger print system for                                                                                                                                                                                      calculated from manual
                                                                                                               take more two months time)                                                                                                                                                       of the World/Outdoor Cap copies of time cards for 10 employees for                                                                                  recording time. Outdoor Cap to                                                                                                                                                                                         time cards.
                                                                                                                                                                                                                                                                                                the month of October 2005, by November 15th.                                                                                                        check on visit in February 06.

Legal benefits                                              Employers will provide all legally mandated        Leave benefit is not practiced properly. Earn                                                                                          Worker interview and                      Based on local laws concerning leave, the factory shall immediately          11/1/2005 Factory Response:                                  The factory did not send                           Factory has provided        ODC working with factory on revised                     Leave benefit is still not practiced properly. Earned Workers interview; review of On location auditor to
                                                            benefits to all eligible workers                   leave is not given to workers, festival leave is                                                                                       records review and                        start following local law and giving the employees the legally required                The factory has already started to give sick leave and
                                                                                                                                                                                                                                                                                                                                                                                                                                          remediation items by 11/1/05,                      copies of paperwork,        handbook. Once finalized asking                         leave is not given to workers, but factory            time records, leave register, confirm leave benefit
                                                                                                               paid only with the two eid holidays (5+5) days,                                                                                        management interview                      leaves as stated for annual leave, festival leave, casual and sick leave                                                                  asking that it be given to TOW on
                                                                                                                                                                                                                                                                                                                                                                                       maternity leave. They shall immediately start following                                               Dec. 05.                    factory to confirm training of workers.                 management informed that the earned leave of 2006 workers' personnel files and practiced properly 5/09
                                                                                                               Casual leave is some times paid and some                                                                                                                                         and maternity leave. Management shall revise the employee handbook                                                                        December visit. The factory has
                                                                                                                                                                                                                                                                                                                                                                                       local law and giving the employees the legally required                                                                                                                                   will be given at the end of 2007. Festival leave is   payroll sheets.
                                                                                                               times not depending on the superiors, Maternity                                                                                                                                  to state the above policies and send Top of the World/Outdoor Cap a                    leaves as stated above for annual leave, festival  established a log for leave and                                                                                                        given in the form of two Eid holiday days. Casual
                                                                                                               leave is allowed but not paid. Even maternity                                                                                                                                    copy of the revised handbook in the local language and in English by                                                                      maternity leave. Factory has
                                                                                                                                                                                                                                                                                                                                                                                       leave and casual leave. The factory will send a copy                                                                                                                                      leave, sick leave and maternity leave is given in
                                                                                                               leave is encouraged to avail two months                                                                                                                                          November 1, 2005.                                                                      of the revised handbook by 11/1/2005.              provided copies of paperwork, Dec.                                                                                                     compliance with the local law.
                                                                                                               instead of 12 weeks.                                                                                                                                                                                                                                                                                                       05. Still need a copy of revised
                                                                                                                                                                                                                                                                                                                                                                                                                                          worker handbook, Outdoor Cap to
                                                                                                                                                                                                                                                                                                                                                                                                                                          check on Feb. 2006 visit.
Legal Compliance for                                        Workers will be paid for holidays and leave        Friday work is paid as overtime but not                                                                                                Worker and                                The factory shall immediately start giving all employees who work on a ######## Factory Response:                                         The factory did not send                           Documents kept in                                                                   Work on weekly off day is compensated as overtime Workers interview; review of On location auditor to
holiday/leave                                               as required by law                                 compensated with another day off with in three                                                                                         management interview                      weekly holiday a substitute day off within the legally subscribed 3 days            The factory has started to give all employees who     remediation items by 11/1/05,                      factory files.                                                                      but no compensatory day off is given within three time records, leave register, confirm compensated day
                                                                                                               days according the law                                                                                                                 and records review.                       of the weekly holiday. Send Top of the World/Outdoor Cap 10                         work on a weekly holiday a substitute day off within  asking that it be given to TOW on                                                                                                      days as per law.                                  workers' personnel files and off is given 5/09
                                                                                                                                                                                                                                                                                                employee time cards, attendance records and salary sheets for the                   the legally subscribed 3 days of the weekly holiday.  December visit. The factory sent                                                                                                                                                         payroll sheets.
                                                                                                                                                                                                                                                                                                month of October 2005 by November 15th as evidence this has been                    The factory will send 10 time cards, attendance       time cards, attendance records and
                                                                                                                                                                                                                                                                                                corrected.                                                                          records and salary sheets for the month of October by salary sheets showing that they are
                                                                                                                                                                                                                                                                                                                                                                                    11/15/05.                                             providing employees with
                                                                                                                                                                                                                                                                                                                                                                                                                                          appropriate pay and time off, Dec.
                                                                                                                                                                                                                                                                                                                                                                                                                                          05. Outdoor Cap to ask for records
                                                                                                                                                                                                                                                                                                                                                                                                                                          for January 06 to review.
False Payroll Records                                       Employers will not use hidden or multiple     Factory maintains hidden or multiple payroll                                                                                                Management interview                      Double record keeping is not an acceptable practice. This must be         11/1/2005 Factory Response:                                     The factory did not send                           Letter is kept in factory                                                           The factory did not maintain any hidden or multiple       Review of payroll sheet &
                                                            payroll records in order to hide overtime, to records in order to hide overtime, to falsely                                                                                               and records reviewed                      stopped immediately. Please have upper management draft a letter to                 Double record keeping has already been stopped.       remediation items by 11/1/05,                      file.                                                                               payroll records in order to hide overtime or to falsify   time records, interview with
                                                            falsely demonstrate hourly wages, or for any demonstrate hourly wages                                                                                                                                                               Top of the World and Outdoor Cap stating they will no longer keep                                                                         asking that it be given to TOW on                                                                                                      hourly wages.                                             management.
                                                            other fraudulent reason.                                                                                                                                                                                                            double books to hire overtime hours in the future.                                                                                        December visit. The factory
                                                                                                                                                                                                                                                                                                                                                                                                                                          submitted a letter from upper
                                                                                                                                                                                                                                                                                                                                                                                                                                          management stating that the
                                                                                                                                                                                                                                                                                                                                                                                                                                          practice of double books to hide
                                                                                                                                                                                                                                                                                                                                                                                                                                          overtime has stopped and will not
                                                                                                                                                                                                                                                                                                                                                                                                                                          continue to occur, Dec. 05.
Accurate benefit                                            All employees will be credited with all time       Some of the daily workers are working in the                                                                                           Attendance record                         The factory shall immediately recognize the time each employee has       11/1/2005 Factory Response:                                      The factory submitted records                      Records kept in the                                                                 Approximately 11-20 daily laborers are working in         Interview with management
compensation                                                worked for an employer for purposes of             factory for a long time regularly (even maximum                                                                                        review and                                worked with the company and pay them according to local law. Please &               The daily workers don’t work regularly. Most of them showing the immediate recording of                  factory files.                                                                      different floors 3 to 4 days a week. The workers are      and daily laborers, review of
                                                            calculating length of service to determine the     up to 4 years continuously and almost                                                                                                  management interview                      send Top of the World/Outdoor Cap a complete record of all               11/15/200 work 3 days / 4 days in a week. So the factory has     new employee's attendance, time                                                                                                        working for long hours but not continuously. The          daily laborer records and
                                                            benefits to which workers are entitled             regularly) but have not been absorbed as                                                                                               and personnel files                       employees showing the date of hire and the current pay scale and the 5              not absorbed them as regularized workers.             cards and salary sheets, Dec. 05.                                                                                                      payment is made on a weekly basis but the records         daily payment sheet.
                                                                                                               regularized workers.                                                                                                                   reviewed, workers                         gradation pay scale required by local law by November 15, 2005.                                                                                                                                                                                                                  are maintained on a daily basis through daily
                                                                                                                                                                                                                                                      interview                                                                                                                                                                                                                                                                                                                  payment sheet.


Other                                                                                                                                                                Newly joined workers name and                                                    Supervisors and                           The factory shall immediately have all new employees listed on all           ######## Factory Response:                                             The factory did not send                 Records kept in factor                                                              During the floor visit we found a time-card of a   Review of payroll sheet &              On location auditor to
                                                                                                                                                                     attendance record are not                                                        workers interview.                        attendance records starting from the date of hire. Send Top of the                    The factory is now keeping all new employees                  remediation items by 11/1/05,            files.                                                                              worker who had joined on September 1, 2007 but no time records, floor visit,              confirm all workers are
                                                                                                                                                                     maintained immediately after their                                               Interview new workers                     World/Outdoor Cap 5 complete sets of new employee’s records,                          attendance records from the date of hire. The factory         asking that it be given to TOW on                                                                                            record/entry of any working time on the time card. interview with newly recruited         receiving credit for time
                                                                                                                                                                     joining. Workers found started                                                   and attendance                            showing their applications, contracts, and for the month of October                   will send 5 complete sets of new employee records,            December visit. The factory                                                                                                                                                     workers.                               worked. 5/09
                                                                                                                                                                     working from 17th of the month but                                               records reviewed and                      2005, their attendance records, time cards and salary sheets by                       showing their applications, contracts, and for Oct.           submitted records showing the
                                                                                                                                                                     till the end of the month their name                                             full process reviewed                     November 15, 2005.                                                                    attendance record, time cards and salary sheets by            immediate recording of new
                                                                                                                                                                     and attendance is not recorded in                                                                                                                                                                                11/15/2005.                                                   employee's attendance, time cards
                                                                                                                                                                     the attendance register. If the                                                                                                                                                                                                                                                and salary sheets, Dec. 05.
                                                                                                                                                                     workers continue to come or
                                                                                                                                                                     become regular than their
                                                                                                                                                                     attendance is recorded by the line
                                                                                                                                                                     chief to prepare the monthly
                                                                                                                                                                     wages.
Other                                                                                                                                                                Wages is also deducted                                                           Worker, Management                        Based on local laws concerning leave, the factory shall immediately          11/1/2005    The factory has already started to give sick leave and    The factory has established a log        Copies of log kept in                                                               From review of records for the last 12 months as          Worker interviews; review of
                                                                                                                                                                     sometimes though leave is applied                                                interviews and review                     start following local law and giving the employees the legally required      &            maternity leave. They shall immediately start following   for leave and maternity leave.           factory files.                                                                      well as worker interviews we found no evidence or         time records, leave register,
                                                                                                                                                                     and approved by the management                                                   of personnel files and                    leaves as stated for annual leave, festival leave, casual and sick leave     11/15/200    local law and giving the employees the legally required   Factory provided copies of                                                                                                   heard no complaints from workers regarding wages          workers' personnel files and
                                                                                                                                                                                                                                                      attendance records                        and maternity leave. Management shall revise the employee handbook           5            leaves as stated above for annual leave, festival         paperwork.                                                                                                                   deductions for approved leave.                            payroll sheets.
                                                                                                                                                                                                                                                                                                to state the above policies and send Top of the World/Outdoor Cap a                       leave and casual leave. The factory will send a copy
                                                                                                                                                                                                                                                                                                copy of the revised handbook in the local language and in English by                      of the revised handbook by 11/1/2005.
                                                                                                                                                                                                                                                                                                November 1, 2005.
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

Overtime Limitations                                        Except in extraordinary business                   Daily and weekly and monthly working hour with                                                                                         Worker interview and                      According to the Factories Act, 1965, Sections 51 & 53, where                ######## Factory Response:                                             The factory did not send             Records kept in factory                                                                 Factory did not follow the rules of overtime hours for    Workers interview, review       Overtime is an on-going
                                                            circumstances, employees will (i) not be           overtime is not maintained. Daily overtime is                                                                                          documents review with                     overtime is paid, no adult worker is allowed to work more than 60                     The factory is trying to follow our local law. The            remediation items by 11/1/05,        files.                                                                                  daily, weekly and monthly work as per the local law       time records; leave register,   challenge…working with
                                                            required to work more than the lesser of (a)       some times 4 hours a day and monthly more                                                                                              management                                hours per week or 56 per week on an average in a year. According to                   factory will send 10 employee time cards, attendance          asking that it be given to TOW on                                                                                            and PC remediation plan. In some cases daily              workers personnel file and      the factory by altering
                                                            48 hours per week and 12 hours overtime or         than 75 hours in June'05 and July'05. In                                                                                                                                         local law, a worker is expected to work up to 60 hours a week (8 hours                records, salary sheets for October by 11/15/05.               December visit. The factory                                                                                                  overtime was as long as 10 hours a day and a              payroll sheets.                 order schedules to
                                                            (b) the limits on regular and overtime hours       December'04 the overtime crosses 100 hours                                                                                                                                       normal shift + 2 hours overtime/day x 6 days/week = 60 hours). The                                                                                  submitted time cards, attendance                                                                                             maximum of 89 hours were recorded in April 07, 119                                        alleviate necessity of
                                                            allowed by the law of the country of               a month.                                                                                                                                                                         factory must comply with local law and our code of conduct concerning                                                                               records, salary sheets in Dec. 05,                                                                                           hours in May 07, 122 hours in June 07and 112                                              overtime. On location
                                                            manufacture or, where the laws of such                                                                                                                                                                                              hours of work. Send Top of the World/Outdoor Cap 10 employee’s                                                                                      showing that are giving workers the                                                                                          hours in July 07. Workers worked continuously from                                        auditor to review
                                                            country will not limit the hours of work, the      Continuous work happened in December'04,                                                                                                                                         time cards, attendance records, salary sheets for the month of                                                                                      appropriate time off. The factory is                                                                                         5th-20th, May 07.                                                                         overtime work 5/09
                                                            regular work week in such country plus 12          6th and 20th May'05, 29th July'05                                                                                                                                                October 2005 by November 15, 2005.                                                                                                                  still working OT weekly about 6
                                                            hours overtime; and (ii) be entitled to at least                                                                                                                                                                                                                                                                                                                                        hours over. TOW/ODC will continue
                                                            one day off in every seven day period. An                                                                                                                                                                                                                                                                                                                                               to work with factory to get their OT
                                                            extraordinary business circumstance is a                                                                                                                                                                                                                                                                                                                                                in legal limits.
                                                            temporary period of extra work that could not
                                                            have been anticipated or alleviated by other
                                                            reasonable efforts
Reduce Mandated OT                                          The employer will demonstrate a commitment         No prove or documents of recording OT as                                                                                               management interview                      All overtime should be voluntary and a sign up sheet should be posted        ######## Factory Response:                                    The factory did not send               Records kept in factory                Factory provided voluntary OT sign up                   Factory maintained a sheet with workers' signatures Worker and management                 Factory to provide
                                                            to reduce mandated overtime and to enact a         voluntary                                                                                                                              and records review                        for all overtime work. The factory will update its worker handbook to                 The factory is now maintaining a sign up sheet to    remediation items by 11/1/05,          files.                                 sheets for ODC to review.                               to document workers' consent for voluntary          interview, floor visit , time &       updated handbook to
                                                            voluntary overtime system to meet                                                                                                                                                                                                   reflect this policy and start it by October 1, 2005. Send Top of the                  prove all overtime is voluntary. Besides this, the   asking that it be given to TOW on                                                                                                     overtime, but not on a regular basis. Management    other records review.                 TOW 5/09
                                                            unforeseen situations                                                                                                                                                                                                               World/Outdoor Cap a copy of the revised handbook and a sign up                        factory informs workers every day for their OT hours December visit. The factory                                                                                                           did not post any advance notice to ensure voluntary
                                                                                                                                                                                                                                                                                                sheet from October by November 15, 2005.                                                                                                   provided copies of voluntary OT
                                                                                                                                                                                                                                                                                                                                                                                      before starting their OT. The factory will send a copy                                                                                                                                     work. The factory distributed old hand books, which
                                                                                                                                                                                                                                                                                                                                                                                      of the revised handbook and a sign up sheet for Oct. sign up sheets. TOW found no                                                                                                          were printed before August’05 and therefore do not
                                                                                                                                                                                                                                                                                                                                                                                      by 11/15/05.                                         evidence of forced OT through                                                                                                         include this issue.
                                                                                                                                                                                                                                                                                                                                                                                                                                           interviews during the follow-up audit.
                                                                                                                                                                                                                                                                                                                                                                                                                                           Outdoor Cap to check on Feb. 06
Explanation of continued                                     If the employer repeatedly requires overtime No explanation of continued required OT is                                                                                                  management interview                      Employers shall be able to provide explanation for all periods when the      ######## Factory Response:                                    The factory did not send                                                      Factory provided voluntary OT sign up                   Factory does not maintain any documents regarding Management interview and                On location auditor to
required OT                                                 in order to respond to the same situation,     maintained                                                                                                                                 and records review                        extraordinary business circumstances exception has been used.                         The factory shall immediately start documenting all  remediation items by 11/1/05,                                                 sheets for ODC to review.                               explanation for continued required Overtime.      record review.                          verify factory maintaining
                                                            the employer will explain why it will not have                                                                                                                                                                                      Employers shall take reasonable steps to inform workers about the                     overtime hours worked and why. The factory will send asking that it be given to TOW on                                                                                                                                                                                               documents regarding
                                                            sufficient staff on hand to avoid the                                                                                                                                                                                               nature and expected duration of the circumstances. The factory shall                  a copy of this register for October by 11/15/05.     December visit. Outdoor Cap to                                                                                                                                                                                                  explanation for continued
                                                            necessity of overtime.                                                                                                                                                                                                              immediately start documenting all overtime hours worked and why.                                                                           check on February Visit 06.                                                                                                                                                                                                     required OT 5/09
                                                                                                                                                                                                                                                                                                This register shall be kept at all times and be available to any inspector
                                                                                                                                                                                                                                                                                                as required. Please send Top of the World/Outdoor Cap a copy of this
                                                                                                                                                                                                                                                                                                register for the month of October 2005 by November 15, 2005.


Overtime Explanation                                        Employers shall be able to provide                 No record maintained as overtime reason                                                                                                management interview                      Employers shall be able to provide explanation for all periods when the ######## Factory Response:                                                  The factory did not send                                             Factory provided voluntary OT sign up                   Workers did not know the reason for overtime work.        Worker and management         On location auditor to
                                                            explanation for all periods when the               explanation                                                                                                                            and records review                        extraordinary business circumstances exception has been used.                    The factory shall immediately start documenting all                remediation items by 11/1/05,                                        sheets for ODC to review.                               Still no record is maintained for explanation of          interview and records review. verify factory maintaining
                                                            extraordinary business circumstances                                                                                                                                                                                                Employers shall take reasonable steps to inform workers about the                overtime hours worked and why. The factory will send               asking that it be given to TOW on                                                                                            reasons for overtime but the management                                                 documents regarding
                                                            exception has been used. Employers shall                                                                                                                                                                                            nature and expected duration of the circumstances. The factory shall             a copy of this register for October by 11/15/05.                   December visit. Outdoor Cap to                                                                                               maintained a sheet with the workers' signature as a                                     explanation for continued
                                                            take reasonable steps to inform workers                                                                                                                                                                                             immediately start documenting all overtime hours worked and why.                                                                                    check on February Visit 06.                                                                                                  proof of worker consent to do overtime work.                                            required OT 5/09
                                                            about the nature and expected duration of                                                                                                                                                                                           This register shall be kept at all times and be available to any inspector
                                                            the circumstances                                                                                                                                                                                                                   as required. Please send Top of the World/Outdoor Cap a copy of this
                                                                                                                                                                                                                                                                                                register for the month of October 2005 by November 15, 2005.

Legal compliance with                                       The factory will comply with all applicable        Women work is carried out more than the legal                                                                                          Records reviewed and                      The factory shall immediately comply with local law and not allow            ######## Factory Response:                                             The factory did not send                                                                                                     Women workers still worked more than the legal limit Workers and management               On location auditor to
protected workers                                           laws governing work hours, including those         limit i.e.. more than 8 pm and sometimes up to                                                                                         worker interview                          women to work past 8pm and not before 7 am. Send Top of the                           The factory is trying not to allow women to work past         remediation items by 11/1/05,                                                                                                i.e. later than 8pm and sometimes from 8am till 7am interview and visit floor.            verify women are working
                                                            regulating or limiting the nature and volume       10 pm.                                                                                                                                                                           World/Outdoor Cap 10 women employee salary records, including                         8pm. The factory will send 10 women’s employee                asking that it be given to TOW on                                                                                            next day.                                                                                 no more than legal limit
                                                            of work performed by women or workers                                                                                                                                                                                               timecards, attendance records, and salary sheets for the month of                     salary records, time cards and attendance records for         December visit. TOW found not                                                                                                                                                                                          5/09
                                                            under the age of 18                                                                                                                                                                                                                 October 2005, by November 15, 2005 as evidence this has been                          Oct. by 11/15/05.                                             evidence of women work carried
                                                                                                                                                                                                                                                                                                corrected.                                                                                                                                          out more than legal limit through
                                                                                                                                                                                                                                                                                                                                                                                                                                                    interviews during follow-up audit in
Voluntary OT                                                Overtime hours worked in excess of code            no recording system of voluntary overtime                                                                                              Records reviewed and                      All overtime should be voluntary and a sign up sheet should be posted        ######## Factory Response:                                             The 05.
                                                                                                                                                                                                                                                                                                                                                                                                                                                    Dec.factory did not send               Records kept in factory                                                               Factory maintained a sheet with workers' signatures Workers and management
                                                            standard will be voluntary                         system                                                                                                                                 worker interview                          for all overtime work. The factory will update its worker handbook to                 The factory is now maintaining a sign up sheet to             remediation items by 11/1/05,          files.                                                                                to document workers' consent for voluntary          interview, floor visit and
                                                                                                                                                                                                                                                                                                reflect this policy and start it by October 1, 2005. Send Top of the                  prove all overtime is voluntary. Besides this, the            asking that it be given to TOW on                                                                                            overtime, but not on a regular basis.               review of time other records.
                                                                                                                                                                                                                                                                                                World/Outdoor Cap a copy of the revised handbook and a sign up                        factory informs workers every day for their OT hours          December visit. The factory
                                                                                                                                                                                                                                                                                                sheet from October by November 15, 2005.                                              before starting their OT. The factory will send a copy        provided copies of voluntary OT
                                                                                                                                                                                                                                                                                                                                                                                      of the revised handbook and a sign up sheet for Oct.          sign up sheets. TOW found no
                                                                                                                                                                                                                                                                                                                                                                                      by 11/15/05.                                                  evidence of forced OT through
                                                                                                                                                                                                                                                                                                                                                                                                                                                    interviews during the follow-up audit.
                                                                                                                                                                                                                                                                                                                                                                                                                                                    Outdoor Cap to check on Feb. 06
                                                                                                                                                                                                                                                                                                                                                                                                                                                    visit.
10. Overtime Compensation
In addition to their compensation for regular hours of work, employees will be compensated for overtime
hours at such premium rate as is legally required in the country of manufacture or, in those countries
where such laws will not exist, at a rate at least equal to their regular hourly compensation rate.




                                                                                                                                                                                                                                                                                                                                                                       5
                                                                                                                                                                                   IEM Findings                                                                                                                                                                                    Remediation                                                                                                                 Updates (Cite Date of Follow up)                                          Third Party Verification                                             Company Verification Follow up
FLA Code/ Compliance issue   Country Law/Legal Reference                 FLA Benchmark                                  Non-compliance                          Risk of Non-compliance         Evidence of Non-   If not corroborated,   Sources/Documentation         Notable                              PC Remediation plan                              Target                  Factory Response (Optional)                  Company follow up (Cite date of follow         Documentation                Company Follow up             Documentation                   Third Party Verification                        Documentation             Company Follow up (Cite       Documentation
                                                                                                                                                                                                  compliance           explain why        used for corroborating      Features                                                                             Completion                                                                             up)                                                                                                                    (IEV: 12 September, 2007)                                                   date of planned or follow up
                                                                                                                                                                                               (uncorroborated)                                                     implemented                                                                               Date                                                                                                                                                                                                                                                                                       visit, if appropriate)
                                                                                                                                                                                                                                                                     by Factory
                                                                                                                                                                                                                                                                   Management or
                                                                                                                                                                                                                                                                      Company
Accurate recording of OT                                   Employees will be paid for all hours worked As the working hour and overtime recording                                                                                        Management interview                      Employees will be paid for all hours worked in a workweek. Calculation ######## Factory Response:                                              The factory did not send                                           ODC to get records from newly                          From the record review and worker interviews, we        Worker interview, visit floor,
hours worked                                               in a workweek. Calculation of hours worked system is manual and maintained by supervisor                                                                                      and attendance                            of hours worked must include all time that the employer allows or               The factory is using time cards for all records of time        remediation items by 11/1/05,                                      installed thumb reader. Records                        did not find any evidence of manipulation of the OT     interview time executive and
                                                           must include all time that the employer allows there is evidence of manipulating the OT data                                                                                  records review and                        requires the worker to work. The factory shall immediately start using          worked until the thumb reader electronic system is in          asking that it be given to TOW on                                  received and factory has now                           records by the floor level management as a              review time cards.
                                                           or requires the worker to work                 by the floor level management as a punishment                                                                                  payroll reviewed                          time cards for all record of time worked until the thumb reader                 place and operating correctly. The factory will send 10        December visit. The factory has                                    changed from thumb reader to card                      punishment for mistake in the work.
                                                                                                          of mistake in the work                                                                                                                                                   electronic system is in place and operating correctly, so the                   time cards for Oct. by 11/15/05.                               installed and is currently using the                               swipe because of accuracy. ODC
                                                                                                                                                                                                                                                                                   supervisors will not have control of any documents that can be                                                                                 finger print time recording system.                                witnessed employees swiping cards.
                                                                                                                                                                                                                                                                                   manipulated. Please send Top of the World/Outdoor Cap copies of                                                                                TOW/ODC are monitoring this and
                                                                                                                                                                                                                                                                                   time cards for 10 employees for the month of October 2005, by                                                                                  will receive records from the
                                                                                                                                                                                                                                                                                   November 15th.                                                                                                                                 system. ODC to check on Feb. 06
                                                                                                                                                                                                                                                                                                                                                                                                                                  visit.

OT Compensation                                            Workers shall be informed about overtime     Workers are not aware about the overtime rate                                                                                    Worker interview                          The factory shall starting in October 2005, provide a pay statement     ######## Factory Response:                                             The factory did not send                                                                                                  Workers are aware of their overtime hours and           Interview with workers;
Awareness                                                  compensation rates, by oral and printed      and calculation system                                                                                                                                                     that will show the employees earned wages, regular and overtime pay              The factory is now providing a pay statement that will        remediation items by 11/1/05,                                                                                             overtime compensation.                                  review of workers' hand
                                                           means                                                                                                                                                                                                                   and hours, any bonuses and all deductions taken from their pay. Send             show the employee wages, regular and overtime pay             asking that it be given to TOW on                                                                                                                                                 books, orientation program
                                                                                                                                                                                                                                                                                   Top of the World/Outdoor Cap 10 employees pay statements, time                   and hours, any bonuses and all deductions taken from          December visit. Tow found no                                                                                                                                                      and schedules.
                                                                                                                                                                                                                                                                                   cards, salary sheets and attendance records for the month of October             their pay. The factory will send 10 employees pay             issues thru interviews with workers
                                                                                                                                                                                                                                                                                   2005, by November 15, 2005.                                                      statements, time cards, salary sheets and attendance          in Dec. 05. Outdoor Cap will check
                                                                                                                                                                                                                                                                                                                                                                    records for Oct. by 11/15/05.                                 for pay statements showing
                                                                                                                                                                                                                                                                                                                                                                                                                                  employee wages, OT and reg. pay,
                                                                                                                                                                                                                                                                                                                                                                                                                                  etc. in Feb 06 visit.
Miscellaneous
Other (new and fired                                                                                                                                      Factory does not maintain the                                                  Attendance record                         The factory shall immediately have all new employees and fired           11/1/2005   Factory Response:                                         The factory did not send                 Records kept in factory                                                          Records were maintained for the disciplined or          Review of workers' personnel
workers)                                                                                                                                                  number and the list of fired and                                               reviewed and                              workers listed on all attendance records starting from the date of hire. &           The factory now keeps all new employees and fired         remediation items by 11/1/05,            files.                                                                           migrant workers on a monthly basis.                     files,
                                                                                                                                                          newly recruited workers per month.                                             management interview                      Send Top of the World/Outdoor Cap 5 complete sets of new                 11/15/200   workers listed on all attendance records starting from    asking that it be given to TOW on                                                                                                                                                 migrants/terminated/newly
                                                                                                                                                          On the request of auditor factory                                              and personnel files                       employees' & fired workers' records, showing their application,          5           the date of hire. The factory shall send 5 complete       December visit. The factory                                                                                                                                                       recruited workers list,
                                                                                                                                                          could only provide records for new                                             reviewed, workers                         contract, and for the month of October 2005, their attendance records,               sets of new employees' & fired workers' records,          submitted records showing the                                                                                                                                                     interview with management
                                                                                                                                                          recruits on a monthly basis but                                                interview                                 time cards and salary sheets by November 15, 2005.                                   showing their application, contract, and for Oct. their   immediate recording of new                                                                                                                                                        and workers.
                                                                                                                                                          failed to provide the record for                                                                                                                                                                              attendance records, time cards and salary sheets by       employee's attendance, time cards
                                                                                                                                                          fired workers.                                                                                                                                                                                                11/15/05.                                                 and salary sheets, Dec. 05.




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Description: Sample Application Letter for Staff Nurse document sample