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FLA Audit Profile
Country China
Name of Factory 530015611F
Independent External Monitoring Organization Level Works Ltd.
Date(s) in Facility June 12-13, 2007
FLA Affiliated Compan(ies) adidas-Group AG
Number of Workers 424
Product(s) Caps
Production Processes Cutting, knitting, sewing, linking, pressing, inspection, washing,
packing
FLA Code/Benchmark Compliance Status Describe noncompliance, risk of List sources/documentation used Cite and describe local and/or Describe notable features
noncompliance or uncorroborated for reference and corroborating country laws used for additional implemented by factory
evidence of noncompliance evidence (e.g. worker interviews, reference management or Company
factory walkthrough, records
review, etc.)
1. Code Awareness
Other Noncompliance Factory management and workers were Interviews with management and
unaware of the FLA and, according to workers and document review
factory management, the company did not
communicate its association with the FLA
to the factory.
2. Forced Labor
There will not be any use of forced labor, whether in the
form of prison labor, indentured labor, bonded labor or
otherwise.
3. Child Labor
No person will be employed at an age younger than 15 (or
14 where the law of the country of manufacture allows) or
younger than the age for completing compulsory education
in the country of manufacture where such age is higher
than 15.
4. Harassment or Abuse
Every employee will be treated with respect and dignity.
No employee will be subject to any physical, sexual,
psychological or verbal harassment of abuse.
5. Non-Discrimination
No person will be subject to any discrimination in
employment, including hiring, salary, benefits,
advancement, discipline, termination or retirement, on the
basis of gender, race, religion, age, disability, sexual
orientation, nationality, political opinion, or social or ethnic
origin.
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.
1
FLA Code/Benchmark Compliance Status Describe noncompliance, risk of List sources/documentation used Cite and describe local and/or Describe notable features
noncompliance or uncorroborated for reference and corroborating country laws used for additional implemented by factory
evidence of noncompliance evidence (e.g. worker interviews, reference management or Company
factory walkthrough, records
review, etc.)
H&S.8 Permits and Certificates Noncompliance 1. Boiler was not registered or inspected Document review and PRC Provisional Boiler and
by local labor bureau. management interview. Pressure Vessels Safety
2. Boiler operator had no license. Monitoring Regulation Article 9:
The operating unit of boiler and
pressure vessels has to apply to
the Boiler and Pressure Vessels
Safety Monitoring Authority for
registration and an operating
certificate before it is intended to
put the same to use. The
operating unit shall, according to
the quality and number of
equipment, set up a specialized
committee or specialized
technician to strengthen safety
management of the boiler and
pressure vessels, in order to
establish health and safety
management system. The
operating unit has to train and
evaluate operators. The
operator has to pass an
examination to obtain the
certificate of competency before
operating independently.
Special Appliance Quality Safety
Monitoring Regulation Article 28:
The operating unit with special
appliances should follow the
requirements of Quality
Technical Monitoring
Administration Department, to
apply for regularly inspection at
the Special Appliance inspection
unit one month before the expiry
date of the safety inspection
approval. After the application,
the Special Appliance inspection
unit shall follow the
requirements of the Quality
Technical Monitoring
Administration Department to
carry out the inspection on time.
The Special Appliance shall not
be used when it has not
undergone regular inspection or
if it failed the inspection.
2
FLA Code/Benchmark Compliance Status Describe noncompliance, risk of List sources/documentation used Cite and describe local and/or Describe notable features
noncompliance or uncorroborated for reference and corroborating country laws used for additional implemented by factory
evidence of noncompliance evidence (e.g. worker interviews, reference management or Company
factory walkthrough, records
review, etc.)
H&S.14 Material Safety Data Sheets/Worker Access and Noncompliance No MSDS was available for chemicals Factory tour and management Regulation of Chemical Safety
Awareness used in the washing department or interview. Usage in Workplace, Article 12:
chemical warehouse. The unit which uses chemicals
shall set up identification labels
for all chemicals in use. For
dangerous chemicals, a safety
label shall be applied and MSDS
be provided to the worker.
7. Freedom of Association and Collective Bargaining
Employers will recognize and respect the right of employees to freedom of association and collective bargaining. FLA Comment: The Chinese constitution guarantees Freedom of Association (FOA); however, the Trade
Union Act prevents the establishment of trade unions independent of the sole official trade union - the All China Federation of Trade Unions (ACFTU). According to the ILO, many provisions of the Trade Union Act are
contrary to the fundamental principles of FOA, including the non-recognition of the right to strike. As a consequence, all factories in China fall short of the ILO standards on the right to organize and bargain collectively.
However, the government has introduced new regulations that could improve the functioning of the labor relations mechanisms. The Amended Trade Union Act of Oct. 2001 stipulates that union committees have to be
democratically elected at members' assemblies and trade unions must be accountable to their members. The trade union has the responsibility to consult with management on key issues of importance to their members
and to sign collective agreements. Trade unions also have an enhanced role in dispute resolution. In Dec. 2003, the Collective Contracts Decree introduced the obligation
for representative trade unions and employers to negotiate collective agreements, in contrast to the previous system of non-negotiated administrative agreements.
8. Hours of Work
Except in extraordinary business circumstances,
employees will (i) not be required to work more than the
lesser of (a) 48 hours per week and 12 hours overtime or
(b) the limits on regular and overtime hours allowed by the
law of the country of manufacture or, where the laws of
such country will not limit the hours of work, the regular
work week in such country plus 12 hours overtime; and (ii)
be entitled to at least one day off in every seven day
period.
HOW.1 General Compliance Hours of Work Noncompliance The compliance status of "Overtime 1. As per broken needle records
Hours" and "Rest Days" could not be review, there were broken needle
verified due to inconsistencies noted records on May 13, 2007 (Sunday)
during this audit. but provided records indicated that
relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
issuing records reviewed and
relevant workers interviewed,
some workers had worked on
November 26, 2006, April 15,
2007 and May 1 and 27, 2007
(Sundays and public holiday) but
relevant workers were on rest on
these days.
3
FLA Code/Benchmark Compliance Status Describe noncompliance, risk of List sources/documentation used Cite and describe local and/or Describe notable features
noncompliance or uncorroborated for reference and corroborating country laws used for additional implemented by factory
evidence of noncompliance evidence (e.g. worker interviews, reference management or Company
factory walkthrough, records
review, etc.)
HOW.2 Rest Day Noncompliance The compliance status of "Rest Days" 1. As per broken needle records
could not be verified due to review, there were broken needle
inconsistencies noted during this audit. records on May 13, 2007 (Sunday)
but provided records indicated that
relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
issuing records reviewed and
relevant workers interviewed,
some workers had worked on
November 26, 2006, April 15,
2007 and May 1 and 27, 2007
(Sundays and public holiday) but
relevant workers were on rest on
these days.
HOW.6 Time Recording System Noncompliance The compliance status of "Overtime 1. As per broken needle records
Hours" and "Rest Days" could not be review, there were broken needle
verified due to inconsistencies noted records on May 13, 2007 (Sunday)
during this audit. but provided records indicated that
relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
issuing records reviewed and
relevant workers interviewed,
some workers had worked on
November 26, 2006, April 15,
2007 and May 1 and 27, 2007
(Sundays and public holiday) but
relevant workers were on rest on
these days.
9. Wages, Benefits and Overtime Compensation
WAGES AND BENEFITS: Employers recognize that
wages are essential to meeting employees’ basic needs.
Employers will pay employees, as a base, at least the
minimum wage required by local law or the prevailing
industry wage, whichever is higher, and will provide legally
mandated benefits.
4
FLA Code/Benchmark Compliance Status Describe noncompliance, risk of List sources/documentation used Cite and describe local and/or Describe notable features
noncompliance or uncorroborated for reference and corroborating country laws used for additional implemented by factory
evidence of noncompliance evidence (e.g. worker interviews, reference management or Company
factory walkthrough, records
review, etc.)
OVERTIME COMPENSATION: In addition to their
compensation for regular hours of work, employees will be
compensated for overtime hours at such premium rate as
is legally required in the country of manufacture or, in those
countries where such laws will not exist, at a rate at least
equal to their regular hourly compensation rate.
WBOT.1 General Compliance Wages, Benefits and Noncompliance The compliance status of "Minimum 1. As per broken needle records
Overtime Compensation Wages" and "Overtime Wages" could not review, there were broken needle
be verified due to inconsistencies noted records on May 13, 2007 (Sunday)
during this audit. but provided records indicated that
relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
issuing records reviewed and
relevant workers interviewed,
some workers had worked on
November 26, 2006, April 15,
2007 and May 1 and 27, 2007
(Sundays and public holiday) but
relevant workers were on rest on
these days.
WBOT.2 Minimum Wage Noncompliance The Compliance status of "Minimum 1. As per broken needle records
Wages" could not be verified due to review, there were broken needle
inconsistencies noted during this audit. records on May 13, 2007 (Sunday)
but provided records indicated that
relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
5
FLA Code/Benchmark Compliance Status Describe noncompliance, risk of List sources/documentation used Cite and describe local and/or Describe notable features
noncompliance or uncorroborated for reference and corroborating country laws used for additional implemented by factory
evidence of noncompliance evidence (e.g. worker interviews, reference management or Company
factory walkthrough, records
review, etc.)
WBOT.7 Payment for All Hours Worked Noncompliance The compliance status of "Minimum 1. As per broken needle records
Wages" and "Overtime Wages" could not review, there were broken needle
be verified due to inconsistencies noted records on May 13, 2007 (Sunday)
during this audit. but provided records indicated that
relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
issuing records reviewed and
relevant workers interviewed,
some workers had worked on
November 26, 2006, April 15,
2007 and May 1 and 27, 2007
(Sundays and public holiday) but
relevant workers were on rest on
these days.
WBOT.8 Calculation Basis for Overtime Payments Noncompliance The compliance status of "Minimum 1. As per broken needle records
Wages" and "Overtime Wages" could not review, there were broken needle
be verified due to inconsistencies noted records on May 13, 2007 (Sunday)
during this audit. but provided records indicated that
relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
issuing records reviewed and
relevant workers interviewed,
some workers had worked on
November 26, 2006, April 15,
2007 and May 1 and 27, 2007
(Sundays and public holiday) but
relevant workers were on rest on
these days.
6
FLA Code/Benchmark Compliance Status Describe noncompliance, risk of List sources/documentation used Cite and describe local and/or Describe notable features
noncompliance or uncorroborated for reference and corroborating country laws used for additional implemented by factory
evidence of noncompliance evidence (e.g. worker interviews, reference management or Company
factory walkthrough, records
review, etc.)
WBOT.10 Premium/Overtime Compensation Noncompliance The compliance status of "Minimum 1. As per broken needle records
Wages" and "Overtime Wages" could not review, there were broken needle
be verified due to inconsistencies noted records on May 13, 2007 (Sunday)
during this audit. but provided records indicated that
relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
issuing records reviewed and
relevant workers interviewed,
some workers had worked on
November 26, 2006, April 15,
2007 and May 1 and 27, 2007
(Sundays and public holiday) but
relevant workers were on rest on
these days.
WBOT.17 Accurate Calculation and Recording of Wage Noncompliance The compliance status of "Minimum 1. As per broken needle records
Compensation Wages", "Overtime Wages" and review, there were broken needle
"Overtime Hours" could not be verified records on May 13, 2007 (Sunday)
due to inconsistencies noted during this but provided records indicated that
audit. relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
issuing records reviewed and
relevant workers interviewed,
some workers had worked on
November 26, 2006, April 15,
2007 and May 1 and 27, 2007
(Sundays and public holiday) but
relevant workers were on rest on
these days.
7
FLA Code/Benchmark Compliance Status Describe noncompliance, risk of List sources/documentation used Cite and describe local and/or Describe notable features
noncompliance or uncorroborated for reference and corroborating country laws used for additional implemented by factory
evidence of noncompliance evidence (e.g. worker interviews, reference management or Company
factory walkthrough, records
review, etc.)
WBOT.19 False Payroll Records Noncompliance The compliance status of "Minimum 1. As per broken needle records
Wages", "Overtime Wages" and review, there were broken needle
"Overtime Hours" could not be verified records on May 13, 2007 (Sunday)
due to inconsistencies noted during this but provided records indicated that
audit. relevant workers were on rest this
day.
2. As per Fabric Sample Card
review and relevant workers
interviewed, some workers had
made sample cards on November
12, 2006 and January 28, 2007
(Sundays) but relevant workers
were on rest on both days.
3. As per material receiving and
issuing records reviewed and
relevant workers interviewed,
some workers had worked on
November 26, 2006, April 15,
2007 and May 1 and 27, 2007
(Sundays and public holiday) but
relevant workers were on rest on
these days.
10. Miscellaneous
Subcontracting, homework and other issues not covered by
above benchmarks and code requirements.
MISC.1 Illegal Subcontracting Noncompliance Computer embroidery operation was Management interview and
subcontracted out by the factory. document review
According to factory management, the
subcontractor is not approved by the
Company.
8
FLA Audit Profile
Country China
Name of Factory 530015611F
Independent External Monitoring Organization Level Works Ltd.
Date(s) in Facility June 12-13, 2007
FLA Affiliated Compan(ies) adidas-Group AG
Number of Workers 424
Product(s) Caps
Production Processes Cutting, knitting, sewing, linking, pressing, inspection, washing, packing
FLA Code/Benchmark Compliance Status Remediation Status
Description of noncompliance, risk of Company Company Remediation Plan Target Factory Response Company Follow-Up Documentation Completed, Pending,
noncompliance or uncorroborated evidence of Internal Audit Completion (optional) (cite date of follow- On-going
noncompliance Findings Date up)
(optional)
Other Noncompliance Factory management and workers were unaware of 1. Factory has trained all staff on the FLA On-going
the FLA and, according to factory management, the (photos about training and notice publication
company did not communicate its association with provided). Factory management must include a
the FLA to the factory. brief training on FLA in the regular orientation
training for new staff also.
H&S.8 Permits and Certificates Noncompliance 1. Boiler was not registered or inspected by local 1. Factory has indicated that the Quality Nov. 30,
labor bureau. Supervision Bureau will complete the process 2007
2. Boiler operator had no license. and get the certificate before the end of Nov.
2007.
2.The boiler operator took the required
professional trainings in August. The license will
be available in Nov. 2007.
H&S.14 Material Safety Data Sheets/Worker Noncompliance No MSDS was available for chemicals used in the 1. MSDS are hanging in the washing department Oct. 31,
Access and Awareness washing department or chemical warehouse. and the raw materials warehouse. Yet, MSDS are 2007
still not complete with all necessary information.
The factory is required to request their chemical
suppliers to get the full information for all MSDS.
2. In addition, trainings on chemical management
is being provided to operators.
HOW.1 General Compliance Hours of Work Noncompliance The compliance status of "Overtime Hours" and adidas' SEA Team has instructed and worked Oct. 31,
"Rest Days" could not be verified due to with factory management to improve the working 2007
inconsistencies noted during this audit. hour policy and procedures (to be included in the
new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
HOW.2 Rest Day Noncompliance The compliance status of "Rest Days" could not be adidas' SEA Team has instructed and worked as above
verified due to inconsistencies noted during this with factory management to improve the working
audit. hour policy and procedures (to be included in the
new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
HOW.6 Time Recording System Noncompliance The compliance status of "Overtime Hours" and adidas' SEA Team has instructed and worked as above
"Rest Days" could not be verified due to with factory management to improve the working
inconsistencies noted during this audit. hour policy and procedures (to be included in the
new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
WBOT.1 General Compliance Wages, Benefits and Noncompliance The compliance status of "Minimum Wages" and adidas' SEA Team has instructed and worked as above
Overtime Compensation "Overtime Wages" could not be verified due to with factory management to improve the working
inconsistencies noted during this audit. hour policy and procedures (to be included in the
new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
WBOT.2 Minimum Wage Noncompliance The Compliance status of "Minimum Wages" could adidas' SEA Team has instructed and worked as above
not be verified due to inconsistencies noted during with factory management to improve the working
this audit. hour policy and procedures (to be included in the
new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
WBOT.7 Payment for All Hours Worked Noncompliance The compliance status of "Minimum Wages" and adidas' SEA Team has instructed and worked as above
"Overtime Wages" could not be verified due to with factory management to improve the working
inconsistencies noted during this audit. hour policy and procedures (to be included in the
new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
WBOT.8 Calculation Basis for Overtime Payments Noncompliance The compliance status of "Minimum Wages" and adidas' SEA Team has instructed and worked as above
"Overtime Wages" could not be verified due to with factory management to improve the working
inconsistencies noted during this audit. hour policy and procedures (to be included in the
new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
9
FLA Code/Benchmark Compliance Status Remediation Status
Description of noncompliance, risk of Company Company Remediation Plan Target Factory Response Company Follow-Up Documentation Completed, Pending,
noncompliance or uncorroborated evidence of Internal Audit Completion (optional) (cite date of follow- On-going
noncompliance Findings Date up)
(optional)
WBOT.10 Premium/Overtime Compensation Noncompliance The compliance status of "Minimum Wages" and adidas' SEA Team has instructed and worked as above
"Overtime Wages" could not be verified due to with factory management to improve the working
inconsistencies noted during this audit. hour policy and procedures (to be included in the
new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
WBOT.17 Accurate Calculation and Recording of Noncompliance The compliance status of "Minimum Wages", adidas' SEA Team has instructed and worked as above
Wage Compensation "Overtime Wages" and "Overtime Hours" could not with factory management to improve the working
be verified due to inconsistencies noted during this hour policy and procedures (to be included in the
audit. new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
WBOT.19 False Payroll Records Noncompliance The compliance status of "Minimum Wages", adidas' SEA Team has instructed and worked as above
"Overtime Wages" and "Overtime Hours" could not with factory management to improve the working
be verified due to inconsistencies noted during this hour policy and procedures (to be included in the
audit. new version of workers' handbook) and has also
required the factory to hold regular training since
Oct. 2007 on wage and working hours policy.
MISC.1 Illegal Subcontracting Noncompliance Computer embroidery operation was subcontracted Taking the responsibility as a primary factory, the Completed
out by the factory. According to factory factory disclosed their subcontractor to the PC and on-
management, the subcontractor is not approved by years ago. Factory has conducted internal audits going
the Company. of the subcontractors and continues to do regular
follow-up on the remediation of noncompliance
issues in the subcontractors' factories. Factory
management has provided related
documentation to prove the actions. Since the PC
has assigned the responsibility of supervision of
the subcontractors' compliance performance to
the primary factories, primary factories are
required to audit the subcontractors regularly.
10
FLA Audit Profile
Country China
Name of Factory 530015611F
Independent External Monitoring Level Works Ltd.
Organization
Date(s) in Facility June 12-13, 2007
FLA Affiliated Compan(ies) adidas-Group AG
Number of Workers 424
Product(s) Caps
Production Processes Cutting, knitting, sewing, linking, pressing, inspection, washing, packing
FLA Code/Benchmark Compliance Status [Status] Description of noncompliance, risk of Updates (Cite Date of Follow-Up) Third-Party Verification Company Verification Follow-Up
Completed, noncompliance or uncorroborated Company Follow-Up Documentation External Documentation Company Follow-Up (cite Documentation
Pending, On- evidence of noncompliance Verification date of planned or follow-up
going (Date) visit, if appropriate)
Other Noncompliance 0 Factory management and workers
were unaware of the FLA and,
according to factory management, the
company did not communicate its
association with the FLA to the factory.
H&S.8 Permits and Certificates Noncompliance 0 1. Boiler was not registered or
inspected by local labor bureau.
2. Boiler operator had no license.
H&S.14 Material Safety Data Noncompliance 0 No MSDS was available for chemicals
Sheets/Worker Access and used in the washing department or
Awareness chemical warehouse.
HOW.1 General Compliance Hours of Noncompliance 0 The compliance status of "Overtime
Work Hours" and "Rest Days" could not be
verified due to inconsistencies noted
during this audit.
HOW.2 Rest Day Noncompliance 0 The compliance status of "Rest Days"
could not be verified due to
inconsistencies noted during this audit.
HOW.6 Time Recording System Noncompliance 0 The compliance status of "Overtime
Hours" and "Rest Days" could not be
verified due to inconsistencies noted
during this audit.
WBOT.1 General Compliance Wages, Noncompliance 0 The compliance status of "Minimum
Benefits and Overtime Compensation Wages" and "Overtime Wages" could
not be verified due to inconsistencies
noted during this audit.
WBOT.2 Minimum Wage Noncompliance 0 The Compliance status of "Minimum
Wages" could not be verified due to
inconsistencies noted during this audit.
WBOT.7 Payment for All Hours Noncompliance 0 The compliance status of "Minimum
Worked Wages" and "Overtime Wages" could
not be verified due to inconsistencies
noted during this audit.
11
FLA Code/Benchmark Compliance Status [Status] Description of noncompliance, risk of Updates (Cite Date of Follow-Up) Third-Party Verification Company Verification Follow-Up
Completed, noncompliance or uncorroborated Company Follow-Up Documentation External Documentation Company Follow-Up (cite Documentation
Pending, On- evidence of noncompliance Verification date of planned or follow-up
going (Date) visit, if appropriate)
WBOT.8 Calculation Basis for Noncompliance 0 The compliance status of "Minimum
Overtime Payments Wages" and "Overtime Wages" could
not be verified due to inconsistencies
noted during this audit.
WBOT.10 Premium/Overtime Noncompliance 0 The compliance status of "Minimum
Compensation Wages" and "Overtime Wages" could
not be verified due to inconsistencies
noted during this audit.
WBOT.17 Accurate Calculation and Noncompliance 0 The compliance status of "Minimum
Recording of Wage Compensation Wages", "Overtime Wages" and
"Overtime Hours" could not be verified
due to inconsistencies noted during this
audit.
WBOT.19 False Payroll Records Noncompliance 0 The compliance status of "Minimum
Wages", "Overtime Wages" and
"Overtime Hours" could not be verified
due to inconsistencies noted during this
audit.
MISC.1 Illegal Subcontracting Noncompliance 0 Computer embroidery operation was
subcontracted out by the factory.
According to factory management, the
subcontractor is not approved by the
Company.
12
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