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					FLA Audit Profile
Country                         China                                                                                     China
Factory Name                    02021526D                                                                                 02021526DV
IEM                             SGS-CSTC Standard Technical Services Co., Ltd                                             Independent External
                                                                                                                          Verification (IEV) by ALGI
Date(s) in Facility             27 - 28 July 2005                                                                         16-Oct-08
PC(s)                           Eddie Bauer, PUMA                                                                         Puma
Number of Workers               2000                                                                                      1200
Product(s)                      Garments
Production                      Cutting - Embroidering - Sewing - Ironing - Trimming -
Processes                       Packaging

                                                                                                                                                                                                                 IEM Findings                                                                                                                                                                                                               Remediation                                                                                                                                      Status                    Third-Party Verification                                Company Verification Follow up
FLA Code/ Compliance            Country Law/Legal Reference               FLA Benchmark                                   Non-Compliance                            Risk of Non-compliance                     Evidence of     If not        Sources/Documentation used for           Notable Features   PC Remediation Plan                                      Target         Company Follow Up                        Documentation      Company Follow up                                    Documentati Company Follow up                                        Documentation      Complete External Verification (Date)   Documentation                          Company Follow up Documentation
Issue                                                                                                                                                                                                         Non-compliance corroborated,   corroborating                            implemented by                                                              Completion          November 10, 2005                                                     (May 10, 2006)                        on                       (November 17, 2006)                                            d;        Independent External                                                 (Mar.3rd, 2008)
                                                                                                                                                                                                              (uncorroborated) explain why                                            Factory                                                                     Date                                                                                                                                                                                                                    Pending; Verification (IEV)
                                                                                                                                                                                                                                                                                      Management or                                                                                                                                                                                                                                                                                       On-going conducted by ALGI on
                                                                                                                                                                                                                                                                                      Company                                                                                                                                                                                                                                                                                                       October 16, 2008
1. Code Awareness
Confidential Non-               Nil.                                      FLA Principle of Monitoring,                    There was not a confidential                                                                                       According to site overservation and                         The objective of the PCs is to strengthen the                         Puma provided copies of Code of                               Flow chart for the grievance procedures already      document       Policies and procedures for the grievance            document            pending   Corrected: Puma came to           Documents Review (CoC of           Base on follow-up visit Documents review,
Compliance Reporting                                                      Obligation of Companies: Develop a              communication channel for the                                                                                      interview with workers & the                                internal grievance systems of their contract                          Conduct with sticker labels for the                           developed but there were no written policies and     review,        mechanism have not yet been developed. No            review,                       the facility six times after      Puma, training records);           on Mar.3rd. 2008,       inspection, interviews
Channel                                                                   secure communications channel, in a             workers to raise complaint on labor                                                                                managements, auditors found that no                         manufacturers. In alignment with this objective,                      communication channel for                                     procedures to go with it. Need to brief workers      inspection,    evidence of worker-management dialogue               inspection,                   July, 2005, to conduct            Management Interview.              PUMA COC was
                                                                          manner appropriate to the culture and           issues to FLA PC company of Eddie                                                                                  complaint telephone number was                              direct communication with the PCs should be                           confidential reporting of issues of non-                      on the polcies and procedures once available.        interview                                                           interview                     internal social compliance                                           posted in workplace,
                                                                          situation, to enable Company employees          Bauer and Puma.                                                                                                    written on the posted codes of Eddie                        considered a last resort for factory employees.                       compliance. Factory to conduct                                                                                                                                                                             completed audits and offer relevant                                            and workers are
                                                                          and employees of contractors and                                                                                                                                   Bauer and Puma. The factory did not                         The PCs will ask the factory to establish a formal                    training of workers on the Code of                            Complaint / suggestion boxes not enough;                            Suggestion box installed in the canteen but the                                    trainings if necessary. The                                          aware of this
                                                                          suppliers to report to the Company on                                                                                                                              have confidential way for workers to                        system of dialog between the management and                           Conduct in December 2005.                                     additional units should be installed at easily                      procedure for using it was not posted.                                             latest one was in March,                                             communication
                                                                          noncompliance with the workplace                                                                                                                                   report the non-compliance to FLA PC                         workers in order to allow workers to voice                            Needs further follow up                                       accessible areas including toilets (at present,                                                                                                        2008 from a Puma regional                                            channel.
                                                                          standards, with security that they shall                                                                                                                           company.                                                    workplace grievances, develop internal procedures                                                                                   there is only one unit installed at the gate)                                                                                                          Office. The hotline numbers
                                                                          not be punished or prejudiced for doing                                                                                                                                                                                        for resolving workplace disputes, and resolve                                                                                                                                                           Policies relative to the code elements already                           pending   of the Puma regional Office
                                                                          so.                                                                                                                                                                                                                            grievances in good faith. Puma will also attach                                                                                     Training of workers on the Code of Conduct not                      made and orientation training of workers is being                                  were found to be posted
                                                                                                                                                                                                                                                                                                         sticker labels onto its posters for the                                                                                             yet done (needs further follow up)                                  done every month. Training module included all                                     throughout the workplace of
                                                                                                                                                                                                                                                                                                         communication channel for confidential reporting of                                                                                                                                                     elements of the code.                                                              facility. The information of
                                                                                                                                                                                                                                                                                                         non-compliance with the code of conduct.                                                                                            Interviewed workers were given copy of the                                                                                                             contact person has been
                                                                                                                                                                                                                                                                                                                                                                                                                                             Puma S.A.F.E. Pocket Guide which contained a                                                                                                           updated twice.
                                                                                                                                                                                                                                                                                                                                                                                                                                             brief discussion of the code elements and also the
                                                                                                                                                                                                                                                                                                                                                                                                                                             contact number for reporting non-compliance
                                                                                                                                                                                                                                                                                                                                                                                                                                             issues



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
Other: Legal Compliance         Article 24 of The Implemention                                                            During the recruitment, workers                                                                                    Tool using deposit record and worker                        Workers should be provided free of charge with                        Practice of requiring deposit has                             The issue of requiring deposit was in fact not yet   interview;     According to new workers who were                    interview;          pending    Corrected: Employees do          Documents Review (factory          According to              interviews, documents
                                Provisions on China Labour Law: no                                                        lodged RMB50 for uniform fee. The                                                                                  and management interview confirmed                          uniforms or any tool necessary to the performance                     been stopped since August 2005.                               stopped. Refund of such deposits has also not        documents      interviewed, the requirement of deposit had          documents                      not need to pay any kind of      internal regulation, personnel     interviews, workers       review
                                any form of deposit shall be lodged                                                       fee would not be returned to workers                                                                               it.                                                         of their job. Factory should discontinue the practice                 Refund of deposits previously                                 yet been done (no documents shown that refund        review         been stopped. According to the old workers,          review                         deposit before or after          files and labor contracts);        are not requried to
                                at the time of signing labour contract.                                                   until they left the factory.                                                                                                                                                   of requiring a deposit from workers for these items                   required was not yet effected.                                of previous deposits was made).                                     their previous deposit had been refunded.                                           employment.                      Management and workers             pay deposit for
                                                                                                                          Workers needed to lodge RMB10-30                                                                                                                                               and immediately return deposits to workers. The                       Needs further follow up                                                                                                           However, no documents to prove the refund of                                                                         Interview.                         uniforms or tools.
                                                                                                                          as tool using deposit, the tool deposit                                                                                                                                        factory may charge a reasonable fee (equal or less                                                                                  Factory was told to complete this item by May                       deposit were presented.
                                                                                                                          would not be returned to workers                                                                                                                                               than the value of the item) to replace items lost by                                                                                31, 2006
                                                                                                                          until workers returned the tools (i.e.                                                                                                                                         employees.                                                                                                                                                                                              Need documentary evidence for the refund
                                                                                                                          knives, scissors etc).
                                                                                                                          It violated Article 24 of The
                                                                                                                          Implemention Provisions on China
                                                                                                                          Labour Law.
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               Nil.                                      Employers will maintain proof of age            About 10% workers personnel files                                                                                  Document review and management                              The factory should have an established procedure                      Factory adopted a checklist to track       document review    Employment files that were checked had age           interview;     Randomly picked 50 names from payroll and the        interview;          completed Corrected: Audit team             Documents Review (personnel
                                                                          documentation for all workers, such as a        including copies of workers’ ID cards                                                                              interview confirmed it.                                     for verifying the ages of workers and maintaining                     down documents required for                                   documentation. The factory also has a "no ID, no     checking of    the factory was able to provide employment file      checking of                   randomly selected 30              files, labor contracts, juvenile
                                                                          birth certificate, which verifies date of       were not kept in the factory.                                                                                                                                                  documentation in employee personnel files. Factory                    submission upon employment.                                   application" policy. In case of doubt on the ID,     employeme      for each worker with the necessary age               employement                   personal files from various       workers registration form
                                                                          birth.                                                                                                                                                                                                                         should develop a plan to improve its record-                          Workers' employment files are now                             the factory will also check it in the website.       nt files       documentation                                        files                         departments and 5 ones of         stamped by the local labor
                                                                                                                                                                                                                                                                                                         keeping practices and systems to ensure that all                      complete                                                                                                                                                                                                             fresh workers to check,           bureau and factory internal
                                                                                                                                                                                                                                                                                                         personnel files are complete and available for                                                                                      (Note: According to other sources in China, there                                                                                                      copied ID cards were found        regulation); Management and
                                                                                                                                                                                                                                                                                                         auditors to review.                                                                                                                 is a website for checking one's ID)                                                                                                                    to be attached in all of them     workers Interview.

Age Verification                Nil.                                      In those cases where proof of age                                                         The factory did not establish and                                        Document review and management                              see above.                                                            see above                                                                                                                                                                                                             Corrected: Facility has          Documents Review (personnel
                                                                          documentation is not readily available,                                                   implement an effective worker age                                        interview confirmed it.                                                                                                                                                                                                                                                                                                                                 established the procedure to     files, labor contracts, juvenile
                                                                          employers will take precautions to ensure                                                 verification procedure and personnel                                                                                                                                                                                                                                                                                                                                                                                             check and verify the age of      workers registration form
                                                                          that all workers are at least the minimum                                                 file retain management system in                                                                                                                                                                                                                                                                                                                                                                                                 each applicant. HR staff         stamped by the local labor
                                                                          working age, including medical or                                                         place, about 10% workers personnel                                                                                                                                                                                                                                                                                                                                                                                               asks for the original ID card    bureau and factory internal
                                                                          religious records, or other means                                                         files including copies of workers’ ID                                                                                                                                                                                                                                                                                                                                                                                            of the potential worker and      regulation); Management and
                                                                          considered reliable in the local context.                                                 cards were not kept in the factory.                                                                                                                                                                                                                                                                                                                                                                                              checks the picture with the      workers Interview.
                                                                                                                                                                    No precaution process to ensure all                                                                                                                                                                                                                                                                                                                                                                                              specific worker to see
                                                                                                                                                                    workers are at least the minimum                                                                                                                                                                                                                                                                                                                                                                                                 whether the ID card is
                                                                                                                                                                    working age in the factory.                                                                                                                                                                                                                                                                                                                                                                                                      authentic. These
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     requirements have been
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     listed in the internal written
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     policy.


Legal Compliance for            Clause 9, Regulations on Young            Employers will comply with applicable           12 young workers (17 years old)                                                                                    Based on workers interview and                              Per Article 65 of the Labor Law of the PRC and                        There is no progress on this issue;                           The policy on young workers formulated by the        interview      Policy for young workers, which stated annual        interview and       on-going   Corrected: Facility currently    Documents Review (personnel        No juvenile workers       documents review,
Juvenile Workers                Worker Special Protection:                laws that apply to young workers, i.e.,         were identified during the audit. The                                                                              document review, 12 young wrokers                           Articles 6 and 9 of the Circular of the Ministry of                   needs further follow up.                                      factory was incomplete as it indicated only the      and            health check, no overtime, not to be assigned in     document review                has 11 juvenile workers. All     files, labor contracts, juvenile   were found during this    factory tour and
                                Employment of Young worker must           those between the minimum working age           factory did not obtain young worker                                                                                were identified as young workers, no                        Labor on Issuing the Provisions on Special                                                                                          definition of what a young worker is and did not     document       hazardous work, is done.                                                            of them have been                workers registration form          audit.                    interviews
                                subject to registration approval from     and the age of 18, including regulations        registration permit from the local                                                                                 young worker registration permit from                       Protection for Juvenile Workers, employers shall                                                                                    include policies on their protection. Factory was    review                                                                                             registered in the Labor and      stamped by the local labor
                                local Labour Bureau of government.        relating to hiring, working conditions,         Labour Bureau. It violated Clause 9,                                                                               local Labour Bureau was available                           provide regular medical examinations for juvenile                                                                                   advised to develop policies and procedures to                       Registration of newly hired young workers is                                        Social Security Bureau of        bureau and factory internal
                                                                          types of work, hours of work, proof of          Regulations on Young Worker                                                                                        during the audit. The management                            workers and recruiting juvenile workers must, in                                                                                    comply with local law governing juvenile workers.                   done monthly. Regular health check up is also                                       Changzhou City. The              regulation); Management and
                                                                          age documentation, and overtime                 Special Protection.                                                                                                confirmed that they did not obtain the                      addition to meeting general employment                                                                                                                                                                  provided. No overtime and non-assignment to                                         mandated physical exams          Workers Interview.
                                                                                                                                                                                                                                             young worker registration permit yet.                       requirements, register with local labor                                                                                                                                                                 hazardous jobs are also observed for young                                          free of charge were
                                                                                                                                                                                                                                                                                                         administrative departments at or above the county                                                                                                                                                       workers.                                                                            conducted for all of them
                                                                                                                                                                                                                                                                                                         level. The factory should develop a policy and                                                                                                                                                                                                                                              after they had been hired in
                                                                                                                                                                                                                                                                                                         procedure to comply with local regulations                                                                                                                                                                                                                                                  one month's time. The exam
                                                                                                                                                                                                                                                                                                         governing the employment of juvenile                                                                                                                                                                                                                                                        records were attached in
                                                                                                                                                                                                                                                                                                         workers.Personnel involved in the recruitment                                                                                                                                                                                                                                               their personal files.
                                                                                                                                                                                                                                                                                                         process must be adequately briefed on the policy
                                                                                                                                                                                                                                                                                                         and procedure.
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. 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.

Pregnancy Risk                                                            Employers will ensure that pregnant                                                       No sufficient evidence showed that                                       Document review, management and                             Reasonable accommodations should be made for                          There is no progress on this issue;                           Policies formulated for the protection of pregnant   interview      Orientation training of workers about company        interview and       completed Corrected: Detailed               Documents Review (factory
                                                                          women are not engaged in work that                                                        pregnancy status of female workers                                       worker interview confirmed it.                              workers in the event of pregnancy. Factory should                     needs further follow up                                       workers are complete.                                and            policies, including those pertaining to pregnant     document review               information regarding             internal regulation);
                                                                          creates substantial risk to the health of                                                 were effectively managed so as to                                                                                                    adopt a policy that includes protections for                                                                                                                                             document       workers, is being done every month.                                                treatment of pregnant             Management and workers
                                                                          the pregnant woman.                                                                       eliminate the risk to pregnant workers.                                                                                              pregnant workers, to ensure that pregnant workers                                                                                                                                        review                                                                                            employees was presented           Interview.
                                                                                                                                                                                                                                                                                                         are not engaged in work that creates substantial                                                                                                                                                        Interviewed workers are aware of the policies                                      and reviewed by audit team.
                                                                                                                                                                                                                                                                                                         risk to their health (e.g. such as job reassigments                                                                                                                                                     for pregnant workers                                                               Audit team verified that they
                                                                                                                                                                                                                                                                                                         to lighter or non-hazardous work, etc.)                                                                                                                                                                                                                                                    were in compliance with the
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    legal requirements and FLA
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    Benchmarks. Workers
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    interviews confirmed that
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    female employees clearly
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                    understood the policy.

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          China Fire Prevention Law, Article        Employer will comply with applicable            The factory did not obtain effective                                                                               Document review and management                              The factory should secure and maintain all legally                    Fire safety certificate dated 1992         document review    Fire safety certificates (dated 1992 and 1994)       documents      New fire safety certificate for 2006 already filed   documents           on-going   Corrected: The fire safety       Documents Review (fire safety      Fire safey system is      Documents checking,
Safety Legal Compliance         10: The completed construction            health and safety laws and regulations.         fire safety inspection certificates of                                                                             interview confirmed it.                                     required permits, such as fire safety inspection                      and annual inspection report dated                            issued by the government for buildings 1 and 3       review         with local office but not yet released. 2005         review; interview              inspection certificates          inspection certificates);          monitored by local fire   management
                                project must comply with fire             In any case where laws and code of              factory buildings in section #1 and                                                                                                                                            certificates.                                                         April 28, 2005 are available                                  were available.                                                     certificate is available.                            of management                  offered by local fire            Factory Tour; Management           safey bureau, which       interviews
                                protection design following to the        conduct are contradictory, the higher           section #3.                                                                                                                                                                                                                                                                                                                                                                                                                                 staff (ISO                     department for the factory       and workers Interview.             including fire safey
                                state construction fire protection        standards will apply. The factory will          It violated article 10 of China Fire                                                                                                                                                                                                                                                                                                                                                                                                        representative                 buildings in section #1 and                                         certificate inspection,
                                technical standards and must be           possess all legally required permits            Prevention Law.                                                                                                                                                                                                                                                                                                                                                                                                                             officer)                       section #3 were presented                                           fire safety facilities
                                delivered for acceptance inspection                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  to audit team for review.                                           inspection, and fire
                                by Fire Protection Bureau, those                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     The latest inspection date                                          drill practice twice a
                                which are not inspected or fail to                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   was May 28, 2007.                                                   year. Records of
                                pass the inspection may not be                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           2007 are available.
                                delivered for use.
                                            China Construction Law,




Document Maintenance/           Article 27 of Safe Use of                 All documents required to be available to       No MSDS was available in chemical                                                                                  On site observation confirmed it.                           MSDS in local language should be made available                       Copies of MSDS have been posted                               Factory was issued the ISO 14001 certificate on      inspection     Practice is being continued.                         documents           completed Corrected: MSDS in local          Factory Tour
Accessibility                   Chemicals at Workplace Provisions:        workers and management by applicable            storing area.                                                                                                                                                                  in all areas where chemicals are used and stored.                     but training of workers on the MSDS                           Dec. 6, 2005. There is now a separate storage        of storage                                                          review; site                  language is posted in the
                                The employees have the right to           laws (such as policies, MSDS, etc.) shall       It violated Article 27 of Safe Use of                                                                                                                                          MSDS should be kept up-to-date and maintained in                      was not yet done.                                             room for chemicals which is provided with eye        areas; ISO                                                          inspection                    chemical storage area.
                                obtain all the relevant information on    be made available in the prescribed             Chemicals at Workplace Provisions.                                                                                                                                             good, legible condition. Workers involved in                          Needs further follow up                                       wash and a first aid box. Workers were briefed       14001
                                the chemicals used in workplace           manner and in the local language or                                                                                                                                                                                            handling chemicals should be briefed on MSDS.                                                                                       on the MSDS                                          certificate;
                                (MSDS).                                   language spoken by majority of the                                                                                                                                                                                                                                                                                                                                                                                      briefing
                                                                          workers if different from the local                                                                                                                                                                                                                                                                                                                                Empty containers of chemicals are stored             records;
                                                                          language                                                                                                                                                                                                                                                                                                                                                           separately and disposal is handled by a chemical     contract
                                                                                                                                                                                                                                                                                                                                                                                                                                             waste handling company                               with
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  chemical
PPE                             Clause 54 of China Labour Law:            Workers shall wear appropriate                  No suitable mask was provided for         No sign or diagram was available to                                      On site observation and verification                        Factory should provide workers with appropriate                       Workers were provided with the             on-site inspection Training already provided; workers seen using        interview,     Workers in stuffing section were observed            site inspection     completed Corrected: Workers in the         Factory Tour
                                Employer must provide employees           protective equipment (such as gloves,           stuffing floss workers and about 3        indicate the need of PPE.                                                with workers and interview with                             Personal Protective Equipment (PPE) required to                       necessary protective equipments but                           the PPEs properly; PPE signs were posted and         documents      wearing masks and PPE signs are present.                                           floss stuffing room were
                                with occupational health and safety       eye protection, hearing protection,             cutting workers did not use metal                                                                                  management confirmed it.                                    prevent injuries in the performance of their job.                     were not using them. Factory still                            so were the copies of MSDS                           review,                                                                                           wearing masks when
                                conditions conforming to the              respiratory protection, etc.) to prevent        gloves while working. It violated the                                                                                                                                          Training should be provided to workers in the use                     needs to provide training to workers                                                                               physical                                                                                          operating and cutting
                                provisions of the state and               unsafe exposure (such as inhalation or          Clause 54 of China Labour Law.                                                                                                                                                 and maintenance of PPE. Mandatory PPE-usage                           on the importance and proper use of                                                                                inspection                                                                                        workers were using mesh
                                necessary personal protective             contact with solvent vapors, noise, dust,                                                                                                                                                                                      signs should be posted in appropriate areas.                          the protective equipments.                                                                                                                                                                                           gloves when working.
                                equipment and provide regular health      etc.) to hazardous elements including                                                                                                                                                                                                                                                                Needs further follow up.
                                examination for employees who             medical waste.
                                engaged in work with occupational
                                hazards.

Chemical Management             Article 4.2 of Storage Regulations of     All chemicals and hazardous substances          Cleaning chemicals were stored in                                                                                  On site observation and verification                        Factory should fully comply with all local regulations                Chemicals are already kept in a                               Factory was issued the ISO 14001 certificate on      inspection     Practice is being continued.                         documents           completed Corrected: Chemicals were         Factory tour; documents
                                General Dangerous Chemical                should be properly labeled and stored in        the components warehouse, no                                                                                       with workers and interview with                             governing the safe and proper storage of                              separate storage area.                                        Dec. 6, 2005. There is now a separate storage        of storage                                                          review; site                  stored in a segregated area       review (contracts with the
                                Goods: Dangerous chemical shall be        accordance with applicable laws.                segregated area for storing the                                                                                    management confirmed it.                                    chemicals, provision of first aid supplies, and                                                                                     room for chemicals which is provided with eye        areas; ISO                                                          inspection                    on the first floor of one         waste dealer)
                                stored at the warehouse that              Workers should receive training,                chemicals. It violated the Article 4.2                                                                                                                                         disposal of waste chemicals. Designated personnel                                                                                   wash and a first aid box.                            14001                                                                                             production floor.
                                approved by local Fire Prevention         appropriate to their job responsibilities, in   of Storage Regulations of General                                                                                                                                              should be assigned responsibility for health and                      No progress yet on the other items                                                                                 certificate;                                                                                      Corrected: Eye wash
                                Authority.                                the safe use of chemicals and other             Dangerous Chemical Goods.                                                                                                                                                      safety compliance of the factory.                                     Needs further follow up                                       Empty containers of chemicals are stored             contract                                                                                          system is placed in the
                                                                          hazardous substances                                                                                                                                                                                                                                                                                                                                               separately and disposal is handled by a chemical     with                                                                                              chemical storage area.
                                Article 17 of Safe Use of Chemicals                                                       No source of water and appropriate                                                                                                                                                                                                                                                                                 waste handling company                               chemical                                                                                          Corrected: Facility has
                                at Workplace Provisions: Suitable                                                         medical supplies in or near the                                                                                                                                                                                                                                                                                                                                         waste                                                                                             signed a contract with a
                                first aid facilities should be provided                                                   chemical storing area.                                                                                                                                                                                                                                                                                                                                                  handling                                                                                          professional waste disposal
                                in chemical using facility.                                                               It violated Article 17 of Safe Use of                                                                                                                                                                                                                                                                                                                                   company;                                                                                          company to deal with those
                                                                                                                          Chemicals at Workplace Provisions.                                                                                                                                                                                                                                                                                                                                      some                                                                                              waste chemicals. The
                                Article 18 of Safe Use of Chemicals                                                                                                                                                                                                                                                                                                                                                                                                                               records of                                                                                        dealer has the license to
                                at Workplace Provisions: Disposal of                                                      Disposal of waste chemicals were                                                                                                                                                                                                                                                                                                                                        chemical                                                                                          deal with the dangerous
                                waste chemicals should meet the                                                           not effectively controlled, i.e. no                                                                                                                                                                                                                                                                                                                                     waste                                                                                             waste.
                                state requirements.                                                                       qualified dealer was used to deal                                                                                                                                                                                                                                                                                                                                       disposal
                                                                                                                          with the waste chemicals. It violated
                                                                                                                          Article 18 of Safe Use of Chemicals
                                                                                                                          at Workplace Provisions.
                                                                                                                                                                                                                                                                                                                                                       1
                                                                                                                                                                                                             IEM Findings                                                                                                                                                                                                       Remediation                                                                                                                               Status                       Third-Party Verification                         Company Verification Follow up
FLA Code/ Compliance           Country Law/Legal Reference              FLA Benchmark                                Non-Compliance                             Risk of Non-compliance                     Evidence of     If not        Sources/Documentation used for          Notable Features   PC Remediation Plan                                     Target         Company Follow Up                    Documentation    Company Follow up                                  Documentati Company Follow up                                     Documentation    Complete    External Verification (Date)   Documentation                   Company Follow up Documentation
Issue                                                                                                                                                                                                     Non-compliance corroborated,   corroborating                           implemented by                                                             Completion          November 10, 2005                                               (May 10, 2006)                      on                       (November 17, 2006)                                       d;          Independent External                                           (Mar.3rd, 2008)
                                                                                                                                                                                                          (uncorroborated) explain why                                           Factory                                                                    Date                                                                                                                                                                                                       Pending;    Verification (IEV)
                                                                                                                                                                                                                                                                                 Management or                                                                                                                                                                                                                                                                         On-going    conducted by ALGI on
                                                                                                                                                                                                                                                                                 Company                                                                                                                                                                                                                                                                                           October 16, 2008
Machinery Maintenance         Article 32 of Regulations             All production machinery and equipment           About 15 sewing machines were not                                                                                   On-site observation confirmed it.                          Safety guards should be installed on sewing                          Some safety guards have been                            Necessary safety guards already installed except   inspection   Transparent eye guards were installed.              inspection        completed Corrected: All sewing             Factory Tour
                              on Health and Safety in Factory:      shall be maintained, properly guarded,           installed with safety guards on                                                                                                                                                machines to prevent injury to workers. Workers                       installed. Others still missing.                        for eye guards on two machines which were not                                                                                                   machines are equipped with
                              Protection device shall be installed  and operated in a safe manner                    rotation wheels. It violated the Article                                                                                                                                       should be briefed on the importance of the safety                    Needs further follow up                                 transparent and had to be moved aside by the                                                                                                    pulley guards
                              for the dangerous parts such as                                                        32 of Regulations on Health and                                                                                                                                                guards and a regular inspection and maintenance                                                                              workers. These must be replaced with the
                              transmission belt, exposed gear,                                                       Safety in Factory.                                                                                                                                                             of the machines should be implemented.                                                                                       appropriate ones.
                              rotating axis, belt wheels and flying
                              sheels.
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                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  Mar.24th 2009             Documents checking,
                                                                        constitution guarantees Freedom of                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        PUMA has clear and        management and
                                                                        Association; however, the Trade Union                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     universal requirement     worker interviews
                                                                        Act prevents the establishment of trade                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   to all suppliers
                                                                        unions independent of the sole official                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   establish effective
                                                                        trade union – the All China Federation of                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 internal
                                                                        Trade Unions (ACFTU). According to                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        communication
                                                                        the ILO, many provisions of the Trade                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     system to facilitate
                                                                        Union Act are contrary to the                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                             the establishment of
                                                                        fundamental principles of freedom of                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      harmonious labor
                                                                        association, including the non-                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                           relationship, There is
                                                                        recognition of the right to strike. As a                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  HSE committee in this
                                                                        consequence, all factories in China fall                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  factory, members are
                                                                        short of the ILO standards on the right to                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                elected by workers
                                                                        organize and bargain collectively.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        and regular meeting
                                                                        Recently, however, the government has                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     records are available
                                                                        introduced new regulations that could                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     for checking.
                                                                        improve the functioning of the labor                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      According to
                                                                        relations mechanisms.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     interviews, workers
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  are saying they will
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  also talk to committee
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                  representatives if they
                                                                        The Amended Trade Union Act of
                                                                        October 2001 does stipulate 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. It also grants the
                                                                        trade union an enhanced role in dispute
                                                                        resolution. In December 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. 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
Minimum Wage                   Clause 48 of China Labour Law:           Employers will pay workers the legal         There was a lack of evidence to                                                                                     Some inconsistencies among                                 The factory must maintain accurate and complete                      Use of time cards is under                              The electronic time keeping system was started     interview,   Electronic print out of attendance records for      documents         pending     Corrected: Audit team           Documents Review (sampling     According to              Documents review,
                               Wages paid to employees by               minimum wage or the prevailing industry      confirm that the factory minimum                                                                                    production records , attendance                            time and payroll records, and have those records                     consideration. Further follow up is                     on the day of the audit, May 10, 2006 (the swipe   inspection   selected workers from May to September were         review; interview             randomly selected 30            payroll statements and time    attendance records        interview
                               employer shall not belower than the      wage, whichever is higher                    wages met the local law                                                                                             sheets, payrolls and interview with                        available for auditors to review during an audit.                    needed for the implementation of the                    cards were issued on that day)                                  provided.                                                                         workers including 3 fresh       records); Management and       provided by factory,
                               local standards on minimum wages.                                                     requirements due to no effective                                                                                    workers were identified during the                         Employees are to be compensated for all hours                        time card system to check propriety                                                                                                                                                                       workers (who entered the        Workers Interview.             no overtime work at
                                                                                                                     working hour recording system was                                                                                   audit.                                                     worked at the legally prescribed rates. The factory                  of the payment of wages                                 Needs further follow up on the accuracy of the                  Attendance record showed that there is only one                                   facility after September,                                      rest day and night.
                                                                                                                     established and implemented in the                                                                                  Worker and management interview                            should develop a detailed plan to improve its                                                                                new time keeping system and the related payroll                 hour overtime everyday and no work on any rest                                    2008) to check their payroll                                   But according to
                                                                                                                     factory.                                                                                                            also confirmed it.                                         record-keeping practices and systems.                                                                                        computations                                                    day.                                                                              records from October to                                        interviews, workers
                                                                                                                     It violated the Clause 48 of China                                                                                  The management admitted that the                                                                                                                                                                                                                                                                                                          December, 2007, February,                                      need overtime two to
                                                                                                                     Labour Law.                                                                                                         working hour registration system was                                                                                                                                                                                                                    Some workers were interviewed outside of the                                      April to June, and August,                                     three hours at night in
                                                                                                                                                                                                                                         not accurate.                                                                                                                                                                                                                                           factory during lunch break and they admitted                                      2008. All of the workers                                       peak season.
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 that overtime usually reached until 9 PM or 3                                     received no less than local
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 hours a day. Some production records also                                         minimum wages as their
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 indicate work on rest day.                                                        base wages. Workers
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   interview confirmed that.
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 The salary calculations in the payroll were all
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 based on one hour OT a day with no work on
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 rest day. Therefore, it cannot be confirmed if
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 the record of working hours is accurate that the
Legal Benefits                 China Labor Law, Article 72: The     Employers will provide all legally               1, About 20% workers were not                                                                                       The social insurance payment record                        Factory should provide all legally mandated                          1) All workers, except the newly        workers'        Workers are not clear on the amount of annual      interview,   All workers were included in the social insurance   documents         on-going    Corrected: 35 fresh             Documents Review (sampling     Factory does not have documents review,
                               sources of social insurance funds    mandated benefits to all eligible workers        provided with social insurance. It                                                                                  showed that not all kinds of social                        benefits to eligible workers. Factory policies should                hired, have been provided with social interview;        leave, maternity leave and public holiday pay.                  which covers maternity, retirement,                 review; interview             workers who entered the         payroll statements and time    records of paid       interview
                               shall be determined according to the                                                  violated Article 72 of China Labour                                                                                 insurance was provided for all                             be developed to inform workers of the benefits to                    insurance since August 2005          2) documents                                                                       unemployment, accident, and medical.                                              facility less than one month    records); Management and       marriage and
                               categories of insurance, and an                                                       Law.                                                                                                                employees.                                                 which they are legally entitled (such as paid annual                 Policy on annual leave and maternity review             Needs further follow up                                         Payments with receipt for July to October were                                    ago, were not covered by        Workers Interview.             maternity leaves.
                               overall pooling of insurance funds                                                    2, No evidence showed that paid                                                                                     The management confirmed that no                           and maternity leave).                                                leave had been developed; briefing                                                                                      presented.                                                                        social insurance. The
                               from the society shall be introduced                                                  annual leave and maternity leave                                                                                    paid maternity leave and annual leave                                                                                           on the new policy will be provided to                                                                                                                                                                     remaining employees are
                               step by step. The employing unit and                                                  were provided for workers. It violated                                                                              was provided for workers.                                                                                                       workers in December 2005                                                                                                Annual leave, maternity leave and public holiday                                  covered by five kinds of
                               laborers must participate in social                                                   Clause 45 & 62 of China Labour Law.                                                                                                                                                                                                                                   Needs further follow                                                                                  are now part of the orientation program                                           social insurances. Facility
                               insurance and pay social insurance                                                                                                                                                                                                                                                                                                        up                                                                                                                                                                                                        presented a waiver offered
                               premiums in accordance with the                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                     by Labor and Social
                               law.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                Security Bureau of
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   Changzhou City to prove the
                               Clause 45 of China Labour Law:                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      situation. The social
                               Employees who kept working for                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                      insurance payments of the
                               one year and more shall be entitled                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 past three months were
                               to annual vacation with pay.                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                        reviewed by audit team to
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   confirm the situation.
                               Clause 62 of China Labour Law:
                               After childbirth, female workers shall
                               be entitled to no less than 90 days
                               of maternity leaves with pay.


                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   2. Facility offers annual
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   leave usually during Chinese
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   New Year, but employees
9. Hours of Work                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   still have the rights to
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
Overtime Limitations          Clause 38 of China Labour Law: The Except in extraordinary business                     It was lack of evidence to confirm                                                                                 Some inconsistencies among                                 The factory must maintain accurate and complete                      Use of time cards is under                              The electronic time keeping system was started     interview,   Electronic print out of attendance records for      documents         pending     Corrected: Facility has          Documents Review (sampling    According to              documents review,
                              employer shall guarantee its            circumstances, employees will (i) not be       that the factory OT working hours                                                                                   production records , attendance                            time and payroll records, and have those records                     consideration. Further follow up is                     on the day of the audit, May 10, 2006 (the swipe   inspection   selected workers from May to September were         review; interview             established electronic          time records, on-site          interviews and            interview
                              employees have at least one day off required to work more than the lesser of           met the local law requirements or                                                                                   sheets, payrolls and interview with                        available for auditors to review during an audit.                    needed for the implementation of the                    cards were issued on that day)                                  provided.                                                                         working hours tracing           production records including   records checking, all
                              in a week;                              (a) 48 hours per week and 12 hours             workers had one day off in a week                                                                                   workers were identified during the                         Employees are to be compensated for all hours                        time card system to check propriety                                                                                                                                                                       system since May, 2006. All     broken needle records, daily   working hours are
                              Clause 41 of China Labor Law: The       overtime or (b) the limits on regular and      due to no effective working hour                                                                                    audit.                                                     worked at the legally prescribed rates. The factory                  of the payment of wages                                 Needs further follow up on the accuracy of the                  Attendance record showed that there is only one                                   working hours including         QC report and material         recorded accurately.
                              overtime working hour can not           overtime hours allowed by the law of the       recording system was established                                                                                    Worker and management interview                            should develop a detailed plan to improve its                                                                                new time keeping system and the related payroll                 hour overtime everyday and no work on any rest                                    overtime hours were well        delivery records);
                              exceed 3 hours a day and 36 hours       country of manufacture or, where the           and implemented in the factory. It                                                                                  also confirmed it.                                         record-keeping practices and systems.                                                                                        computations                                                    day.                                                                              recorded and maintained.        Management and workers
                              a month.                                laws of such country will not limit the        violated Clause 38 & 41 of China                                                                                    The management admitted that the                                                                                                                                                                                                                                                                                                                                          Interview.
                                                                      hours of work, the regular work week in        Labour Law.                                                                                                         working hour recording system was                                                                                                                                                                                                                       Some workers were interviewed outside of the
                                                                      such country plus 12 hours overtime; and                                                                                                                           not accurate.                                                                                                                                                                                                                                           factory during lunch break and they admitted
                                                                      (ii) be entitled to at least one day off in                                                                                                                                                                                                                                                                                                                                                                                that overtime usually reached until 9 PM or 3
                                                                      every seven day period. An                                                                                                                                                                                                                                                                                                                                                                                                 hours a day. Some production records also
                                                                      extraordinary business circumstance is a                                                                                                                                                                                                                                                                                                                                                                                   indicated work on rest day.
                                                                      temporary period of extra work that could
                                                                      not have been anticipated or alleviated by                                                                                                                                                                                                                                                                                                                                                                                 The salary calculations in the payroll were all
                                                                      other reasonable efforts                                                                                                                                                                                                                                                                                                                                                                                                   based on one hour OT a day with no work on
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 rest day. Therefore, it cannot be confirmed if
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 the record of working hours is accurate that the
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 wage payments to workers were in accordance
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 with legal requirements.

Other                          Nil                                      Time cards or records should be                                                         The factory used attendance sheet                                        attendance sheets and management                           Time worked by employees should be documented                        Factory will implement the use of                                                                                                                                                                         Corrected: Audit team           Documents Review (sampling
                                                                        completed at the beginning and end of                                                   recording workers working hours. But                                     interview confirmed it.                                    by time cards or other accurate and reliable                         time cards in December 2005.                                                                                                                                                                              randomly selected 30            time records, on-site
                                                                        the work shift.                                                                         there was no exact beginning and                                                                                                    electronic systems, such as an electronic swipe                      Needs further follow up on this.                                                                                                                                                                          workers including 3 fresh       production records including
                                                                                                                                                                ending time recorded on the                                                                                                         card system.                                                                                                                                                                                                                                                                   workers (enter facility after   broken needle records, daily
                                                                                                                                                                attendance sheets, only the total                                                                                                                                                                                                                                                                                                                                                                                  September, 2008) to check       QC report and material
                                                                                                                                                                normal and overtime hours of how                                                                                                                                                                                                                                                                                                                                                                                   their working hours records     delivery records);
                                                                                                                                                                many hours that workers worked were                                                                                                                                                                                                                                                                                                                                                                                of October to December,         Management and workers
                                                                                                                                                                recorded on it respectively.(i.e.if a                                                                                                                                                                                                                                                                                                                                                                              2007, February, April to        Interview.
                                                                                                                                                                worker worked from 8:00am-12:00am,                                                                                                                                                                                                                                                                                                                                                                                 June, and August, 2008.
                                                                                                                                                                13:30pm-17:30pm & 18:30pm-                                                                                                                                                                                                                                                                                                                                                                                         Audit team corss-checked
                                                                                                                                                                20:30pm on a day, then the                                                                                                                                                                                                                                                                                                                                                                                         via workers' interview and
                                                                                                                                                                attendance sheet only showed the                                                                                                                                                                                                                                                                                                                                                                                   production records review,
                                                                                                                                                                worker's working hours was 8 hours                                                                                                                                                                                                                                                                                                                                                                                 all records were verified to
                                                                                                                                                                for normal working hour and 2 hours                                                                                                                                                                                                                                                                                                                                                                                be accurate and complete.
                                                                                                                                                                for overtime working hour on that day.)
                                                                                                                                                                So, the factory attendance sheet
                                                                                                                                                                records were not complete.

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.
OT Compensation for Piece According to the Article 44 of China            Where workers are paid on a piece rate,     Workers were paid by piece rate. It                                                                                Some inconsistencies among                                 The factory must maintain accurate and complete                      Use of time cards is under                              The electronic time keeping system was started     interview,   Electronic print out of attendance records for      documents         pending     Corrected: Audit team        Documents Review;                 After cross-checking      documents checking,
                                  Labor Law, the overtime premium         the payment for overtime work performed    was lack of evidence to confirm that                                                                                production records , attendance                            time and payroll records, and have those records                     consideration. Further follow up is                     on the day of the audit, May 10, 2006 (the swipe   inspection   selected workers from May to September were         review; interview             randomly selected 30         Management and Workers            of the working hour       interview
                                  should be calculated at the rate of     shall result in no less payment than the   OT premium met the local law                                                                                        sheets, payrolls and interview with                        available for auditors to review during an audit.                    needed for the implementation of the                    cards were issued on that day)                                  provided.                                                                         workers including 3 fresh    Interview.                        and payroll records,
                                  150%, 200% and 300% on normal           premium pay required by law                requirements due to no effective                                                                                    workers were identified during the                         Employees are to be compensated for all hours                        time card system to check propriety                                                                                                                                                                       workers (who entered the                                       all overtime hours are
                                  day extension, rest day and national                                               working hour recording system was                                                                                   audit.                                                     worked at the legally prescribed rates. The factory                  of the payment of wages                                 Needs further follow up on the accuracy of the                  Attendance record showed that there is only one                                   facility after September,                                      compensated
                                  holiday working.                                                                   established and implemented in the                                                                                  Worker and management interview                            should develop a detailed plan to improve its                                                                                new time keeping system and the related payroll                 hour overtime everyday and no work on any rest                                    2008) to check their payroll                                   according to legal
                                                                                                                     factory. It violated Article 44 of China                                                                            also confirmed it.                                         record-keeping practices and systems.                                                                                        computations                                                    day.                                                                              records of October to                                          standards
                                                                                                                     Labour Law.                                                                                                         The management admitted that the                                                                                                                                                                                                                                                                                                          December, 2007, February,
                                                                                                                                                                                                                                         working hour registration system was                                                                                                                                                                                                                    Some workers were interviewed outside of the                                      April to June, and August,
                                                                                                                                                                                                                                         not accurate.                                                                                                                                                                                                                                           factory during lunch break and they admitted                                      2008. All of the workers
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 that overtime usually reached until 9 PM or 3                                     were paid overtime
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 hours a day. Some production records also                                         compensations which were
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 indicated work on rest day.                                                       properly calculated and
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                   accurate. Puma came to the
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 The salary calculations in the payroll were all                                   facility every half year to
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 based on one hour OT a day with no work on                                        check whether the
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 rest day. Therefore, it cannot be confirmed if                                    calculation method used by
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 the record of working hours is accurate and that                                  facility was correct.
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 the wage payments to workers were in
                                                                                                                                                                                                                                                                                                                                                                                                                                                                                                 accordance with legal requirements.
Miscellaneous




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