Supplier name:
Not Applicable
Site country:
Bulgaria
Site name:
DEDRAX AD
Parent Company name (of the site):
Not Applicable
SMETA Audit Type:
Date of Audit
2–Pillar
4–Pillar
19-20/02/2015
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
1
Audit Company Name:
Report Owner (payee):
(If paid for by the customer of the site
please remove for Sedex upload)
Bureau Veritas
Sedex Company Reference:
(only available on Sedex System)
Sedex Site Reference:
(only available on Sedex System)
S:
P:
Audit Conducted By
Commercial
Purchaser
NGO
Retailer
Trade Union
Brand Owner
Multi–stakeholder
Combined Audit (select all that apply)
Auditor Reference Number:
(If applicable)
NOT APPLICABLE
SMETA Declaration
I declare that the audit underpinning the following report was conducted in accordance with SMETA best practice
guidance version 5.0. Any exceptions to this are recorded here:
(1) A SMETA audit was conducted which included some or all of Labour Standards, Health & Safety,
Environment and Business Ethics. The SMETA Best Practice Methodology v.5.0 Dec 2014 was applied. The
scope of workers included all types at the site e.g. direct employees, agency workers, workers employed by
service providers and workers provided by other contractors.
(2) The audit scope was against the following reference documents
2-Pillar SMETA Audit
- ETI Base Code
- SMETA Additions
o Management systems and code implementation,
o Entitlement to Work & Immigration,
o Sub-Contracting and Home working,
4-Pillar SMETA
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
2
o 2-Pillar requirements plus
o Additional Pillar assessment of Environment
o Additional Pillar assessment of Business Ethics
The Customer’s Supplier Code (Appendix 1)
(3) Where appropriate non-compliances were raised against the ETI code / SMETA Additions & local law and
recorded as non-compliances on both the audit report, CAPR and on Sedex.
(4) Any Non-Compliance against customer code shall not be uploaded to Sedex. However, in the CAPR these
‘Variances in compliance between ETI code / SMETA Additions/ local law and customer code’ shall be noted
in the observations section of the CAPR.
Any exceptions to this must be recorded here (e.g. different sample size): No Exceptiions
Auditor Name(s) (please list all including all interviewers): Maritsa Panova
Lead auditor: Maritsa Panova
Team auditor: Irena Gineva
Interviewers: Maritsa Panova
Date: 19-20 February 2015
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
3
Non–Compliance Table
Area of Non–Conformity
Issue
(Only check box when there is a non–conformity,
and only in the box/es where the non–conformity
can be found)
(please click on the issue title to go direct to
the appropriate audit results by clause)
ETI Base
Code
Local Law
Additional
Elements
(i.e. not part
of ETI code )
Record the number
of issues by line*:
NC
Obs
GE
0
Management systems and code
implementation
0
0
0
1
Employment Freely Chosen
0
0
0
2
Freedom of Association
0
0
0
3
Safety and Hygienic Conditions
0
0
1
4
Child Labour
0
0
0
5
Wages and Benefits
0
0
0
6
Working Hours
0
0
0
7
Discrimination
0
0
0
8
Regular Employment
0
0
0
8A
Sub–Contracting and
Homeworking
0
0
0
9
Harsh or Inhumane Treatment
0
0
0
10A
Entitlement to Work
0
0
0
10B2
Environment 2–Pillar
NA
NA
NA
10B4
Environment 4–Pillar
0
0
0
10C
Business Ethics
0
0
*Please note the table above records the total number of Non compliances (NC), Observations (Obs) and Good
Examples (GE). This gives the reviewer an indication of problem areas but does not detail severities of each issue –
Reviewers need to check audit results by clause.
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
4
Summary of Findings
Summary of main findings: (positive and negative)
(Please give a short summary of the main findings per clause)
Workers are working in a calm and professional environment. Managers are doing their best to ensure the
production process and satisfaction of workers’ needs. Requirements of laws in the field of Health and Safety,
environmental issues, Labour conditions, etc are well known and applied.
The machinery is in excellent condition. There is an excellently maintained fire safety system. There are places for
rest and changing-rooms for women and men.
There are clear rules and policies for obeying the human rights, environmental issues, clear business practices,
open and honest attitude between people, child labour, discrimination etc.
Positive finding: None
Negative findings: None found
Positive finding:
1. High level of investment in fire safety
Negative findings: None found
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
5
Audit Details
Audit Details
A: Report #:
SOF/15/7146
B: Time in and time out
19.02.2015
Sofia
20.02.2015
Sofia
20.02.2015
Varna
Time in: 09:00
Time out: 17:00
Time in :09:00
Time out: 15:30
Time in: 09:00
Time out: 17:00
(SMETA Best Practice Guidance and
Measurement Criteria recommends 9.00–17.00
hrs. if any different please state why in the
SMETA declaration )
C: Number of Auditor Days Used:
(number of auditor x number of days)
2 auditors:
1 Auditor x 1.5. days + 0.5 days for planning and reporting
1Auditor x1 day
Total: 2.5 days + 0.5 days for planning and reporting
D: Audit type:
Full Initial
Periodic
Full Follow–up
Partial Follow–Up
Partial Other – Define
E: Was the audit announced? (AAG
recommends a window of three weeks for semi–
announced, this gives optimum results)
Announced
Semi – announced: Window detail:
Unannounced
F: Was the Sedex SAQ available for
review?
Yes
No
If No, why not?
(Examples would be, site has not completed
weeks
NOT APPLICABLE
SAQ, site has not been asked to complete the
SAQ.)
G: Any conflicting information SAQ/PreAudit Info to Audit findings?
Yes
No
If Yes, please capture detail in appropriate audit by clause
H: Auditor name(s) and role(s):
Maritsa Panova – Lead auditor (Sofia)
Irena Gineva – Auditor (Varna)
I: Report written by:
Irena Gineva – Auditor (Varna)
J: Report reviewed by:
K: Report issue date:
27/02/2015
L: Supplier name:
DEDRAX AD
M: Site name:
DEDRAX AD
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
6
N: Site country:
Bulgaria
O: Site contact and job title:
Katya Stanoeva – Management Representative
P: Site address:
(Please include full address)
1, Square, NDK, enter AI4., 1463 Sofia, Bulgaria
173 Prilep Str., 9000 varna, Bulgaria
Site phone:
+359 2 9166 129
Site fax:
+359 2 865 74 97
Site e–mail:
[email protected]
Q: Applicable business and other legally
required licence numbers:
for example, business license no, and
liability insurance
Company registration 201412044
R: Products/Activities at site, for example,
garment manufacture, electricals, toys,
grower
Production of scratch cards. Manufacture of paper and paper
composite materials. Production of printed products and polygraph
services.
S: Audit results reviewed with site
management?
Yes
T: Who signed and agreed CAPR
Katya Stanoeva – Management Representative
(Name and job title)
U: Did the person who signed the CAPR
have authority to implement changes?
Yes
V: Present at closing meeting (Please state
name and position, including any
workers/union reps/worker reps):
Katya Stanoeva – Management Representative
W: What form of worker representation /
union is there on site?
Union (name)
Worker Committee
Other (specify)
None
X: Are any workers covered by Collective
Bargaining Agreement (CBA)
Yes
Y: Previous audit date:
No
14-15.10.2013
Z: Previous audit type:
SMETA 2–
pillar
SMETA 4–
pillar
Other
Full Initial
Periodic
Full Follow–Up
Audit
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
7
Partial Follow–
Up
Partial Other*
*If other, please define:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
8
Audit Scope/Actual Results
Criteria
Local Law
(Please state legal requirement)
Actual at the
Site
(Record site results
against the law)
A: Standard/Contracted work hours:
(Maximum legal and actual required working
hours excluding overtime, please state if
possible per day, week and month)
B: Legal Overtime hours:
(Maximum legal and actual overtime hours,
please state if possible per day, week and
month)
C: Legal age of employment:
(Minimum legal and actual minimum age at
site)
D: Legal minimum wage for
standard/contracted hours:
(Minimum legal and actual minimum wage at
site, please state if possible per hr, day, week
and month)
E: Legal minimum overtime wage:
(Minimum legal and actual minimum overtime
wage at site, please state if possible per hr
,day, week and month)
Is this part of a
Collective
Bargaining
Agreement?
Legal maximum:
40 hours (8 hours per day, 5
days per week)
In compliance
with the law - 40
hours (8 hours
per day, 5 days
per week)
Yes
No
Legal maximum:
Prolongation up to 3 hours
daywork (or 2 hours nightwork)
per day
Prolongation up to 6 hours
daywork (or 4 hours nightwork)
per week
Prolongation up to 30 hours
dayshift (or 20 hours nightwork)
per month
There is no
overtime in the
company.
Yes
No
Legal minimum:
16 - 18 years for not heavy,
dangerous or hazardous jobs
15 - 16 years for easy jobs, with
no risk for the proper physical,
mental and moral development
In both cases (15-18) after
medical examination and
issuance of a statement that they
fit for the job and with permision
from local authorities
The youngest
worker in the
company is19
years old.
Legal minimum:
360 BGN per month – gross.
Around 280 BGN – net
Yes
No
1 EUR=1.95583 BGN
Legal minimum:
during the week - 150%
during rest days – 175%
during holidays – 200%
in case of summarized
calculated working hours – 150%
There is no
overtime in the
company.
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Yes
No
9
Audit Scope
(Please select the code and additional requirements that were audited against during this audit)
2–Pillar Audit
10B4: Environment 4–Pillar
10C: Business Ethics
All groups of workers are included in the scope of this audit such as; Direct employees, Casual
and agency workers, Workers employed by service providers such as security and catering staff
as well as workers supplied by other contractors.
Note: The main focus of this ethical audit is on the ETI Base Code and local law. The additional elements will not be audited in such
depth or scope, but the audit process will still highlight any specific issues.
This report provides a summary of the findings and other applicable information found/gathered during the social audit conducted
on the above date only and does not officially confirm or certify compliance with any legal regulations or industry standards. The
social audit process requires that information be gathered and considered from records review, worker interviews, management
interviews and visual observation. More information is gathered during the social audit process than is provided here. The audit
process is a sampling exercise only and does not guarantee that the audited site prior, during or post–audit, are in full compliance
with the Code being audited against. The provisions of this Code constitute minimum and not maximum standards and this Code
should not be used to prevent companies from exceeding these standards. Companies applying this Code are expected to comply
with national and other applicable laws and where the provisions of law and this Code address the same subject, to apply that
provision which affords the greater protection. The ownership of this report remains with the party who has paid for the audit.
Release permission must be provided by the owner prior to release to any third parties.
Audit Overview
Audit Overview
Audit attendance
Management
Worker Representatives
Senior management
Worker Committee
representatives
Union representatives
A: Present at the opening meeting?
Yes
No
Yes
No
Yes
No
B: Present at the audit?
Yes
No
Yes
No
Yes
No
C: Present at the closing meeting?
Yes
No
Yes
No
Yes
No
D: If Worker Representatives were not
present please explain reasons why
There is a worker committee and a worker representative presented at
audit and closing meeting.
(only complete if no worker reps present)
E: If Union Representatives were not
present please explain reasons why:
There are no unions in the company and therefor no union
representatives.
(only complete if no union reps present)
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
10
F: Site description:
(Include size, location and age of site. Also
include structure and number of buildings)
The core business of the company is Production of scratch cards.
Manufacture of paper and paper composite materials. Production of
printed products and polygraph services.
Dedrax is a private company established in 1993 having as core activity
prepress services, printing and bookbinding.
Since 1995 it is among the first to work as a print film exposure studio.
In 2002 Dedrax expanded by hiring the printing facility of the National
Palace of Culture in Sofia and invested 5 million euros in the purchase
of its own new conventional and digital printing and bookbinding
equipment
Main operations and main equipment used:
rinting machines: MAN Roland R705 DirectDrive, 2 x MAN Roland
R705 HiPrint, MAN Roland R705, MAN Roland R504, RYOBI 525 GX
5D, MAN Roland R202 TOB, Heidelberg SORK
Finshing works machines: BOBST Expertfold 110A, BOBST Novacut
106, Sakurai SC72, TM-1100B, Komfi Sagitta 76, JBI WOB 3500, Smyth
Freccia 180 4D, Muller Martini Prima Plus, Wohlenberg Golf 370,
Wohlenberg City 6000 e, Hohner HSB 7000, Hohner HSB 5000, RENZ INLINE 500, Laconda Speed, Wohlenberg ANG 115 (2 бр.),
Wohlenberg ANG 115, MBO K76S-KTL, MBO K760 Efficiency KTL4 (2
бр.), MBO K760 Efficiency 4-SKTL (2 бр.), NAGEL Auto-Rillnak 50,
Solarco Calendar 80A, Solarco Calendar 55A, JAGENBERG Diana 85,
KUGLER - 340-2, GBC Delta Komfi, EUROCUTTER 1160 AD Monitor,
EUROCUTTER 1320 AD Monitor
Digital and card machines: Xerox iGen3, Xerox Nuvera 100 EA, Man
Roland DICOpress, Kern 3000, KBA-Metronic UNIVERSYS, KöraPackmat VMC100/VRM30
Production lines: Offset Print, Computer to Press Digital Print, Scratch
cards printing, Wide-format Print, Color Laser Printer, Bookbinding
services,Package gluing services, UV Polishing, Scanning and Text
Editing, Filmsetting, Pre-Print
There is only one building of 2 floors. It is 950 m² and is 30 years
old.
Dedrax site in Varna is located in business building Bee Garden on 173
Prilep Str. There is administrative office and production area hold by the
company. Main production equipment is:
2 polygraph guillotines Wohlenberg 115
1 saddle sewing machine Hohner HSB 7000
2 folding machines MBO
1 printing machine Roland 705 directive drive
2 puncheons Heidelberg Cylinder 500/700
1 image setter ETP-Luncher SLP 230
1 quire machine Wohlenberg 6000
1 punching machine Bobst 106
2 gluers Bobst 110
For below, please add any extra rows if appropriate.
Production
Description
Remark, if any
Building no
Floor 1
Printing works
None
Floor 2
Printing works
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
None
11
Is this a shared
building?
G: Site function:
H: Month(s) of peak season:
No
None
Agent
Factory Processing/Manufacturer
Finished Product Supplier
Grower
Homeworker
Labour Provider
Pack House
Primary Producer
Service Provider
Sub–Contractor
October - December
(if applicable)
I: Process overview:
(Include products being produced, main operations, number of production lines, main equipment used)
The core business of the company is Production of scratch cards. Manufacture of paper and paper composite
materials. Production of printed products and polygraph services.
Dedrax is a private company established in 1993 having as core activity prepress services, printing and bookbinding.
Since 1995 it is among the first to work as a print film exposure studio. In 2002 Dedrax expanded by hiring the printing
facility of the National Palace of Culture in Sofia and invested 5 million euros in the purchase of its own new
conventional and digital printing and bookbinding equipment
Main operations and main equipment used:
rinting machines: MAN Roland R705 DirectDrive, 2 x MAN Roland R705 HiPrint, MAN Roland R705, MAN Roland
R504, RYOBI 525 GX 5D, MAN Roland R202 TOB, Heidelberg SORK
Finshing works machines: BOBST Expertfold 110A, BOBST Novacut 106, Sakurai SC72, TM-1100B, Komfi Sagitta
76, JBI WOB 3500, Smyth Freccia 180 4D, Muller Martini Prima Plus, Wohlenberg Golf 370, Wohlenberg City 6000 e,
Hohner HSB 7000, Hohner HSB 5000, RENZ - INLINE 500, Laconda Speed, Wohlenberg ANG 115 (2 бр.),
Wohlenberg ANG 115, MBO K76S-KTL, MBO K760 Efficiency KTL4 (2 бр.), MBO K760 Efficiency 4-SKTL (2 бр.),
NAGEL Auto-Rillnak 50, Solarco Calendar 80A, Solarco Calendar 55A, JAGENBERG Diana 85, KUGLER - 340-2,
GBC Delta Komfi, EUROCUTTER 1160 AD Monitor, EUROCUTTER 1320 AD Monitor
Digital and card machines: Xerox iGen3, Xerox Nuvera 100 EA, Man Roland DICOpress, Kern 3000, KBA-Metronic
UNIVERSYS, Köra-Packmat VMC100/VRM30
Production lines: Offset Print, Computer to Press Digital Print, Scratch cards printing, Wide-format Print, Color Laser
Printer, Bookbinding services,Package gluing services, UV Polishing, Scanning and Text Editing, Filmsetting, PrePrint
There is only one building of 2 floors. It is 950 m² and is 30 years old.
Dedrax site in Varna is located in business building Bee Garden on 173 Prilep Str. There is administrative office and
production area hold by the company. Main production equipment is:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
12
2 polygraph guillotines Wohlenberg 115
1 saddle sewing machine Hohner HSB 7000
2 folding machines MBO
1 printing machine Roland 705 directive drive
2 puncheons Heidelberg Cylinder 500/700
1 image setter ETP-Luncher SLP 230
1 quire machine Wohlenberg 6000
1 punching machine Bobst 106
2 gluers Bobst 110
J: Attitude of workers:
(Include their attitude to management, workplace and the interview process. Both positive and negative information should be
included) Note: Do not document any information that could put workers at risk
It was noted that workers had very open attitude towards the interviews. They were willing to express everything
related to their workplace and their management. They shared a lot of information about the conditions of work and
about attitude of management. No discrepancies are observed during the interviews. The interviews show that there
are no violations of human rights or deviations from the requirements of the code. The employees are very content
with the work conditions.
Workers are working in a calm and professional environment. Managers are doing their best to ensure the production
process and satisfaction of workers’ needs. Requirements of laws in the field of Health and Safety, environmental
issues, Labour conditions, etc are well known and applied.
The machinery is in excellent condition. There is an excellently maintained fire safety system. There are places for
rest and changing-rooms for women and men.
K: Attitude of workers committee/union reps:
(Include their attitude to management, workplace and the interview process. Both positive and negative information should be
included) Note: Do not document any information that could put workers at risk
There is no requirement to have a union or workers committee in the company. Nevertheless the management gave
the workers an opportunity to elect their representatives. There is no pressure or discrimination towards the workers
representatives. They are calm and share that there are no problems in the company.
L: Attitude of managers:
(Include attitude to audit, and audit process. Both positive and negative information should be included)
The attitude towards audit is open and honest, as it is found as a way for improvements and finding new clients. The
General Manager is open minded. It was observed that all of the employees approach him without any shyness and
with a smile, obviously calm when communicating.
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
13
Key Information
Key Information
(click on the key information title to go to appropriate section of the report)
A: Do all workers (including migrant workers)
have contracts of employment/employment
agreements?
Yes
No
(Go to clause 8 – Regular Employment)
B: Are maximum standard/contracted
working hours clearly defined in
contract/employment agreements?
Yes
No
(Go to clause 8 – Regular Employment)
C: Were appropriate records available to
verify hours of work and wages?
Yes
No
(Go to clause 5 – Living Wage)
D: Were any inconsistencies found?
(if yes describe nature)
Yes
No
(Go to Wages Table)
E: For the lowest paid production workers,
are wages paid for standard/contracted
hours (excluding overtime) below or above
the legal minimum?
(Go to clause 5 – Living Wage)
F: % of piece rate workers:
(if applicable)
G: Do the standard/contracted hours stated
in a contract/employment agreement exceed
the law or 48 hours per week?
Poor record keeping
Isolated incident
Repeated occurrence
Wages found:
Please indicate the breakdown of workforce
according to earnings:
Below legal
min
Meet
Above
____% of workforce earning under min wage
____% of workforce earning min wage
____% of workforce earning above min wage
Not Applicable
Yes
No
(Go to clause 6 – Working hours)
H: If yes, what are the standard/contracted
hours per week as stated in the
contract/employment agreement?
_____ hrs/week
Approx. ____% of ALL workers on these contacted
hours
Not Applicable
(Go to clause 6 – Working hours)
I: Combined hours (standard/contracted plus
overtime = total hours) over 60 per week
found?
Yes
No
(Go to Working Hours Analysis)
J: Are workers provided with 1 day off in
every 7-day-period, or 2 in 14-day-period
(where the law allows)?
Yes
No
If ‘No’, please explain:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
14
K: Are the correct legal overtime premiums
paid?
(Go to Wages Table)
L: Please state what actual OT is paid.
(As a percentage of the workers standard rate)
(Go to Working Hours Analysis)
Yes. Note: There is no overtime in the company. But the company
has a legal obligation to pay at a premium rate if overtime occurs.
No
N/A – there is no legal requirement to OT premium
Please give details of overtime premium as a % of standard wages:
0%
1% – 115%
116% – 124%
125% – 199%
200%+
Please give details: According to legislation, following premium
rates for overtime work applies:
• during the week - 150%
• during rest days – 175%
• during holidays – 200%
in case of summarized calculated working hours – 150%
M: Is there any night production work at the
site?
Yes
No
There was some night production during the peak season. Records
were checked. Premium rates were paid. Workers interviewed
confirmed it.
N: % of workers living in site provided
accommodation (if applicable):
None
O: Age of youngest worker found:
19 years old
(Go to clause 4 – Child labour)
P: Workers under 18 subject to hazardous
work assignments?
Yes
No
(Go to clause 3 – Health and Safety)
% of under 18’s at this site (of total workers)
Q: What form of worker representation/union
is there on site?
(Go to clause 2 – Freedom of Association)
R: Is it a legal requirement to have a union?
(Go to clause 2 – Freedom of Association)
S: Is It a legal requirement to have a workers
committee?
(Go to clause 2 – Freedom of Association)
T: Is there any other form of effective
worker/management communication
channel? (Other than union/worker committee)
(Go to clause 2 – Freedom of Association)
0%
Union (name)
Worker Committee
Other (specify)
None
Yes
No
Yes – For organizations with more than 0 employees, as per the
labour Code
No
Yes
No
Describe: there is a Workers committee in the company.
Also there is a direct communication with the management.
There are suggestion boxes for anonymous communication
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
15
U: Are there any External Processes?
(Go to clause 8A – Sub–contracting and Home
working)
Sub–Contracting
Homeworking
Other External Process
No external processes
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
16
Management Systems
Management Systems:
A: Nationality of Management
Bulgarian
B: Gender breakdown of Management +
Supervisors (Include as one combined group)
Male: 16 %
Female: 84 %
C: Majority nationality of workers
Bulgarian
D: Number of workers leaving in last 12
months as a % of average total number of
workers on site over the year (annual worker
turnover)
13 %
Please note that most of the people left due to personal reasons not
related to the job. New people were hired.
E: Were accurate records shown at the first
request?
Yes
No
F: If No, why not?
NOT APPLICABLE
G: In the last 12 months, has the site been
subject to any fines/prosecutions for non–
compliance to any regulations?
Yes
No
Please describe:
H: Do policies and/or procedures exist that
reduce the risk of forced labour, child labour,
discrimination, harassment & abuse?
Yes
No
Please describe: Internal Labour Rules. ETI Base code
I: If Yes, is there evidence (an indication) of
effective implementation? Please give
details.
There is effective implementation of all of the procedures.
There is no discrimination in the company. Part of the workers are are
Gypsy, part are Jewish. No children are employed (records and walk
around the premises). There are policies on forced labour, child labour,
discrimination, harassment & abuse
J: Have managers and workers received
training in the standards for forced labour,
child labour, discrimination, harassment &
abuse?
Yes
No
Please describe: Everybody has been introduced to to the following
documents: Manual for internal labour rules and practices, ETI Base
code, Dedrax Core Social Policies
K: If Yes, is there evidence (an indication)
that training has been effective e.g. training
records etc.? Please give details
Interviews confirm that trainings have been conducted.
Training Records.
L: Are there published, anonymous and/or
open channels available for reporting any
violations of Labour standards and H&S or
rd
any other grievances to a 3 party?
Yes
No
Please describe:
There are anonymous claim boxes installed in the premises. Also the
workers are trained on the channels to report violations to authorities
and certification organizations.
M: If Yes, are workers aware of these
There are anonymous claim boxes installed in the premises. Also the
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
17
channels? Please give details.
workers are trained on the channels to report violations to authorities
and certification organizations.
N: Have health and safety risks been
identified e.g. through internal audits, formal
risk analysis process, worker involvement
etc.?
Yes
No
Please describe: There is a risk assessment performed .
O: If Yes, has effective action been taken to
reduce or eliminate these risks?
All necessary steps have been undertaken. Risks are minimized. Good
health and safety conditions are provided to the workers.
P: Are accidents recorded?
Yes
No
Please describe: No major incidents are recorded. Only superficial
cuts.
Q: Has the auditor made a simple calculation
to compare capacity with workers’ work load
in order to identify possible unrecorded work
hours?
Yes
No
Please describe: There is no overtime in the company.
R: Does the site have all required land rights
licenses and permissions (see SMETA
Measurement Criteria)?
Yes
S; Does the site have any internationally
recognised system certifications e.g. ISO
9000, 14000, OHSAS 18000, SA8000 (or
other social audits).
Second Party Social Audit performed by Bureau Veritas in 2013
The company has a certified ISO 9001:2008 Management System
Please detail (Number and date).
T: Is there a Human Resources
manager/department?
If Yes, please detail.
Yes
No
Please describe: There is an accounting department that acclaims
responsibility on human resources activities.
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
18
Worker Analysis
Worker Analysis
Local
Migrant
Total
Permanent
Temporary
Agency
Permanent
Temporary
Home
workers
Agency
Worker numbers –
male
15
-
-
-
-
-
-
15
Worker numbers –
female
3
-
-
-
-
-
-
Total
18
-
-
-
-
-
-
18
Number of Workers
interviewed
18
-
-
-
-
-
-
18
3
Contractors:
(Individuals supplying workers to site with the workers paid by contractors, not by site)
Yes
No
A: Any contractors on site?
B: If Yes, how many workers supplied by
contractors
NOT APPLICABLE
C: Are all contractor workers paid according
to law?
Yes
No
NOT APPLICABLE
If Yes, Please give evidence for contractor
workers being paid according to law:
NOT APPLICABLE
Migrant Workers:
(Please see SMETA Best Practice Guidance and Measurement Criteria for definitions of migrant workers)
D: Originating
Locations/Countries:
NOT APPLICABLE
E: Type of work undertaken by
migrant workers :
NOT APPLICABLE
F: Were migrant workers
recruited through an agency?
If yes, please give details.
Yes
No
Please describe: NOT APPLICABLE
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
19
If Yes, is there a contract with
the agency? Provide details of
agencies and contractual
arrangements including any fees
lodged during the recruitment
process.
NOT APPLICABLE
G: Does the site have a system
for checking labour standards of
agencies?
If yes, please give details.
Yes
No
Please describe: NOT APPLICABLE
H: Percentage of migrant
workers in company provided
accommodation:
NOT APPLICABLE
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
20
Audit Results by Clause
0: Management systems and Code Implementation
0: Managements system and Code Implementation
(click
here to return to NC Table)
0.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code.
0.2 Suppliers shall appoint a senior member of management who shall be responsible for compliance with the Code.
0.3 Suppliers are expected to communicate this Code to all employees.
0.4 Suppliers should communicate this code to their own suppliers and, where reasonably practicable, extend the
principles of this Ethical Code through their supply chain.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to
understand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant
procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any
documentary or verbal evidence shown to support the systems.
Current systems: There is a responsible for the code. ETI Base Code and Dedrax Core Social Policies have
been communicated to on-site workers including, local labour laws/labour rights and how this has been done
e.g. posters, worker trainings etc.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Manual for internal labour rules and practices.
Dedrax Policies on Workers’ Rights
ETI Base code – in the premises and through e-mails.
Interviews
Non–compliance:
1. Description of non–compliance:
NC against ETI/Additional Elements
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI/Additional Elements
NC against Local Law
Local law and/or ETI requirement:
Recommended corrective action:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
21
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Comments:
Good Examples observed:
Objective evidence
observed:
Description of Good Example (GE):
1: Employment is Freely Chosen
1: Employment is Freely Chosen
(Click here to return to NC–table)
ETI
1.1 There is no forced, bonded or involuntary prison labour.
1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free to
leave their employer after reasonable notice.
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
22
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems: No forced, bounded or involuntary prison labour observed.
Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their
employer after reasonable notice (period is stated in the labour contract).
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Manual for internal labour rules and practices.
Dedrax Policies on Workers’ Rights
ETI Base code – in the premises and through e-mails.
Interviews
Non–compliance:
1. Description of non–compliance:
NC against ETI
NC against Local Law:
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI requirement
Recommended corrective action:
2. Description of non–compliance:
NC against ETI
NC against Local Law
Local law and/or ETI requirement:
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Comments:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
23
Good Examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective evidence
observed:
24
2: Freedom of Association and Right to Collective Bargaining are Respected
2: Freedom of Association and Right to Collective Bargaining are Respected
(Click
here to return to NC–table)
(Click here to return to Key Information)
ETI
2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargain
collectively.
2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.
2.3 Workers’ representatives are not discriminated against and have access to carry out their representative
functions in the workplace.
2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employer
facilitates, and does not hinder, the development of parallel means for independent and free association and
bargaining.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems: Workers have the right to join or form trade unions. It was confirmed during the interviews that
there has never been a restriction by the company management to do so. Currently there are no trade unions in the
company. It was confirmed by the workers that in case of any issue or problem it can be discussed with the direct
manager or with the workers’ representative. Also there is a workers committee in the company.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Manual for internal labour rules and practices
Quality Policy
Ethical Policy
Election of Workers’ Representative Protocol
Workers’ Committee Election Protocol
Interviews
Non–compliance:
1. Description of non–compliance:
NC against ETI
NC against Local Law
Objective evidence
observed:
(where relevant please add photo
numbers)
Local law and/or ETI requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI
NC against Local Law
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
25
Local law and/or ETI requirement:
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Comments:
A: Name of union and union
representative, if applicable:
NOT APPLICABLE
Is there evidence of free elections?
Yes
No
N/A
B: If no union what is parallel means of
consultation with workers e.g. worker
committees?
There is a workers’
representative and a workers’
committee in close
communication with the
Management
Is there evidence of free elections?
Yes
No
N/A
C: Were worker representatives/union
representatives interviewed
Yes
No
If Yes, please state how many: 1
D: State any evidence that
union/workers committee is effective?
There is a very well established communication. The workers committee
meets regularly. Interviews confirm the effectiveness
Specify date of last meeting; topics covered;
how minutes were communicated etc.
E: Are any workers covered by
Collective Bargaining Agreement (CBA)
Yes
No
F: If Yes what percentage by trade
Union/worker representation
0 % workers covered by Union
CBA
G: If Yes, does the Collective
Bargaining Agreement (CBA) include
rates of pay
Yes
No
NOT APPLICABLE
0 % workers covered by worker rep
CBA
Good Examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective evidence
observed:
26
3: Working Conditions are Safe and Hygienic
3: Working Conditions are Safe and Hygienic
(Click here to return to NC–table)
(Click here to return to Key Information)
ETI
3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the
industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health
arising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonably
practicable, the causes of hazards inherent in the working environment.
3.2 Workers shall receive regular and recorded Health & Safety training, and such training shall be repeated for
new or reassigned workers.
3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shall
be provided.
3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.
3.5 The company observing the code shall assign responsibility for Health & Safety to a senior management
representative.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems:
A safe and hygienic working environment is provided. There is risk assessment of Health and Safety at work is
approved and covers all of the possible risks. The premises are equipped with appropriate and correctly maintained
firefighting equipment. Workers receive regular and recorded Health & Safety training. Each new or reassigned
worker receives introduction training and records are kept.
There are clean toilet facilities and potable water without any limitation of access.
There is no need for the accommodation to be provided by the company.
Legislation is strictly followed.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Certificates for control of working conditions.
Health and safety at work risk assessment, done in September 2009
Establishment of Health and Safety committee, records for training of the members and records from quarterly held
meetings;
PPE needed - available.
Fire-fighting schemes, rules, plans, actions;
Regular trainings, evacuation drills once per year.
Firefighting training.
Periodical training for health and safety at work.
Logbook for incident – none observed.
Periodical medical examination and analysis of the health condition of the employees are performed.
Quality Policy
Ethical Policy
Examination of work premises
Interviews
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
27
Non–compliance:
1. Description of non–compliance:
NC against ETI
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI requirement
Recommended corrective action:
2. Description of non–compliance:
NC against ETI
NC against Local Law
Local law and/or ETI requirement:
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Recommended corrective action:
Good Examples observed:
Description of Good Example (GE):
Exquisitely well-developed fire safety system!
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective Evidence
Observed:
Pictures attached to the
report
28
4: Child Labour Shall Not Be Used
4: Child Labour Shall Not Be Used
(Click here to return to NC–table)
(Click here to return to Key Information)
ETI
4.1 There shall be no new recruitment of child labour.
4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for the
transition of any child found to be performing child labour to enable her or him to attend and remain in quality
education until no longer a child.
4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.
4.4 These policies and procedures shall conform to the provisions of the relevant ILO Standards.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems: There is a policy for not employing children – prior to labour contract ID papers are checked.
The policy also requires not exposing people under 18 years old to hazardous conditions or using them for night
work - that is also requirement of Bulgarian law. Each singed contact is registered in the system of the Government
Tax Authority, where the age of employee is also observed. The youngest worker in the company is 19 years old.
Policies toward child labour are in line with law and accordingly – in line with relevant ILO Standards.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Manual for internal labour rules and practices
Interviews
Personal files and personnel contracts
Witnessing the work process
Interviews
Non–compliance:
1. Description of non–compliance:
NC against ETI
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI
NC against Local Law
Local law and/or ETI requirement:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
29
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Comments:
Good Examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective Evidence
Observed:
30
5: Living Wages are paid
5: Living Wages are Paid
(Click here to return to NC–table)
(Click here to return to Key information)
ETI
5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industry
benchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs and
to provide some discretionary income.
5.2 All workers shall be provided with written and understandable information about their employment conditions in
respect to wages before they enter employment and about the particulars of their wages for the pay period
concerned each time that they are paid.
5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wages
not provided for by national law be permitted without the expressed permission of the worker concerned. All
disciplinary measures should be recorded.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems:
Wages are paid at the beginning of each month. The lowest level of workers’ wage meets the legal minimum.
Workers with more responsibilities/skills and experience have contracts with salaries higher. All workers are
receiving the same benefits – free of charge transportation and additional insurance, also free of charge.
All workers are provided with written and understandable information about their employment conditions in respect
to wages before they enter employment and about the particulars of their wages for the pay period concerning
each time that they are paid. Deductions from wages are done just due to legal required taxes, health and pension
insurances. There were not found any clues for deductions done as a disciplinary measure.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Manual for internal labour rules and practices
ETI base code.
Personal files
Personnel contracts
Payrolls
Witnessing the work process
Interviews
Non–compliance:
1. Description of non–compliance:
NC against ETI
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI requirement:
Recommended corrective action:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
31
2. Description of non–compliance:
NC against ETI
NC against Local Law
Local law and/or ETI requirement:
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Comments:
Good Examples observed:
Objective Evidence
Observed:
Description of Good Example (GE):
Wages analysis:
Wages analysis:
(Click here to return to Key Information)
A: Sample Size Checked
(State number of worker records checked and from
which weeks/months – should be current, peak and
random/low. Please see SMETA Best Practice
Guidance and Measurement Criteria)
10 Records for January 2015
10 records for October 2014
10 records for June 2014
B: Are there different legal minimum wage
grades? If Yes, please specify all.
Yes
No
If Yes, please give details:
C: If there are different legal minimum grades,
are all workers graded correctly?
Yes
No
N/A
If No, please give details:
D: What deductions are required by law e.g.
social insurance? Please state all types:
E: Have all of these deductions been made?
Please list all deductions that have/have not
been made.
For social security payment, health insurance and pension
assurance fees, income tax.
Yes
No
If Yes, Please list all deductions that have been
made: For social security payment, health
insurance and pension assurance fees, income
tax.
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
32
If No, please give details on any deductions
which have not been made:
F: Industry norm for this region:
NOT APPLICABLE
(please include time period e.g. hour/week/month)
Wages table
Wages table
(Click here to return to Key information)
Worker Type
Process Operator
(Lowest paid)
Process Operator
(Average paid)
Process Operator
(Highest paid)
Select from individual worker records one worker from, lowest, average and highest wages and populate the
boxes. Ensure comparison is made for same pay period and only uses full–time workers. See SMETA Best
Practice Guidance and Measurement Criteria for completing this:
10 Records for each of the
following months:
January 2015
October 2014
June 2014
10 Records for each of the
following months:
January 2015
October 2014
June 2014
10 Records for each of
the following months:
January 2015
October 2014
June 2014
B: Anonymous Employee
Reference/Dept.
OR
KN
CTF1
C: Employee Gender
male
female
female
D: Contracted/Standard
working hours:
40 hours/ 5 –days week
40 hours/ 5 –days week
40 hours/ 5 –days week
298 BGN – net salary after
taxes
305.7 BGN – net salary
after taxes
313.56 BGN – net
salary after taxes
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
A: Pay period:
(State month selected)
(excluding OT – please
include time period e.g.
hour/week/month)
E: Contracted /Standard
work pay rate:
(excluding OT – please
include time period e.g.
hour/week/month)
F: Standard day overtime
– hours:
(please include time period
e.g. hour/week/month)
G: Standard day overtime
– wage:
(please include time period
e.g. hour/week/month)
H: Rest day overtime –
hours: (please include time
period e.g. hour/week/month)
I: Rest day overtime –
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
33
wage:
(please include time period
e.g. hour/week/month)
J: Statutory Holiday
overtime – hours:
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
NOT APPLICABLE
382.54 BGN
306.84 BGN
356 BGN
380 BGN
390 BGN
400 BG
O: Social insurance and
other deductions; please
list which and amount.
82 BGN
84.28 BGN
86.44 BGN
P: Actual wage paid after
deduction:
298 BGN – net salary after
taxes +382.54 BGN Bonus
305.7 BGN – net salary
after taxes +306.84 BGN
Bonus
313.56 BGN – net
salary after taxes +356
BGN Bonus
(please include time period
e.g. hour/week/month)
K: Statutory holiday OT –
wages:
(please include time period
e.g. hour/week/month)
L: Total overtime hours:
(please include time period
e.g. hour/week/month)
M: Incentives/Bonus/
Allowances etc.:
(please include time period
e.g. hour/week/month)
N: Gross wages:
(please include time period
e.g. hour/week/month)
(please include time period
e.g. hour/week/month)
Comments:
(Please state here any specific reasons/circumstances that explain the lowest and highest gross wages)
None
Q: Is there a defined living wage:
This is not normally minimum legal
wage. If answered Yes please state
amount and source of info:
Please see SMETA Best Practice
Yes
No
Please specify amount/time period:
360 BGN gross per month/ Around 282.20 BGN net per month
Guidance and Measurement Criteria.
R: Are workers paid in a timely
manner in line with local law?
S: Is there evidence that equal rates
are being paid for equal work:
T: How are workers paid:
Yes
No
Yes
No
Details: Records checked
Cash
Cheque
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
34
Bank Transfer
Other
If other explain:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
35
6: Working Hours are not Excessive
6: Working Hours are not Excessive
(Click here to return to NC–table)
(Click here to return to Key Information)
ETI
6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below,
whichever affords the greater protection for workers. Sub–clauses 6.2 to 6.6 are based on international labour
standards.
6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.
6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: the
extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to
replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to
be not less than 125% of the regular rate of pay.
6.4 The total hours worked in any 7 day period shall not exceed 60 hours, except where covered by clause 6.5
below.
6.5 Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all of the
following are met:
– this is allowed by national law;
– this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a
significant portion of the workforce;
– appropriate safeguards are taken to protect the workers’ health and safety; and
– The employer can demonstrate that exceptional circumstances apply such as unexpected production
peaks, accidents or emergencies.
6.6 Workers shall be provided with at least one day off in every 7 day period or, where allowed by national law, 2
days off in every 14 day period.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems:
Working hours comply with national laws. Workers are not required to work in excess. There is no overtime in the
company. Legally required breaks during the day and rests between weeks are correctly implemented. There is
one work shifts with one hour lunch break.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Personal files
Personnel contracts
Interviews
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
36
Non–compliance:
1. Description of non–compliance:
NC against ETI
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI
NC against Local Law
Local law and/or ETI requirement:
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Comments:
Good Examples observed:
Objective Evidence
Observed:
Description of Good Example (GE):
Working hours analysis
Working hours analysis
Please include time period e.g. hour/week/month
(Go back to Key information)
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
37
Systems & Processes
A. What timekeeping systems are
used: time card etc.
Describe: There is a clear announced working time and breaks appointed
for the two work shifts:
07:00-16:00
13:00 – 22:00
B: Sample Size Checked
(State number of worker records
checked and from which
weeks/months and type – should be
current, peak and random/low: See
10 Records for each of the following months:
January 2015
October 2014
June 2014
SMETA Best Practice Guidance and
Measurement Criteria)
C: Do ALL workers have
contracts/employment agreements?
Yes
No
If NO, state which type of workers do NOT have
contracts/employment agreements:
D: Are standard/contracted working
hours defined in all
contracts/employment agreements?
Yes
No
If NO, please state which type of workers do NOT have
standard hours defined in contracts/employment
agreements.
E: Are there any other types of
contracts/employment agreements
used?
Yes
No
If YES, Please complete as appropriate:
0 hrs
Part time
Variable hrs
Other
If “Other”, Please define:
Not Applicable
Standard/Contracted Hours worked
F: Do standard/contracted standard
hours ever exceed the law or 48
hours per week?
Yes
No
If YES give details and comparison (local law/48 hrs
week)
Not Applicable
G: What are the actual
standard/contracted hours worked in
sample (State per week/month)
H: Any local waivers/local law or
permissions which allow
averaging/annualised hours for this
site?
Highest hours:
40 hours per week
Lowest hours:
40 hours per week
Yes
No
If YES, Please give details
Overtime Hours
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
38
I: Actual overtime hours worked in
sample (State per day/week/month)
J: Range of overtime hours over all
workers/or as large a sample as
possible. (State per week/month and
details)
Highest OT
hours:
Not Applicable
Lowest OT
hours:
Not Applicable
__ to __ in _______(month)
__ to __ in _______(month)
__ to __ in _______(month)
Not Applicable – No overtime in the company
K: Approximate percentage of
workers on highest overtime hours
0%
L: Is overtime voluntary?
Yes
No
Conflicting
Information
Not
Applicable –
No overtime
in the
company
Please detail evidence e.g. Wording of
contract/employment agreement/handbook/worker
interviews/refusal arrangements:
Yes
No
Not
Applicable –
No overtime
in the
company
Please give details of normal day overtime premium as a
% of standard wages:
Not Applicable – No overtime in the company
Overtime Premiums
M: Is overtime paid at a premium?
0%
1–
115%
116 –
124%
125 –
149%
150 –
199%
200%+
Any other comments:
N: ETI Code requires a prevailing
standard to give greatest worker
protection.
If a site pays less than 125% OT
premium and this is allowed under
local law, are there other
considerations? Please complete the
boxes where relevant. Multi select is
possible.
No
Consolidated pay (May be standard wages above minimum legal wage, with
no/low overtime premium)
Collective Bargaining agreements
Other
Not Applicable – No overtime in the company
Please explain any checked boxes in N above e.g. detail of consolidated
pay CBA or Other.
Rest Days
O: Are workers provided with 1 day
off in every 7–day–period, or 2 in 14–
Yes
No
Maximum number of days worked without a day off (in
sample):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
39
day–period (where the law allows)?
Workers have
2 days of rest
after each 5
days of work.
Total Hours
P: Range of total hours:
(Quote highest and lowest please include
time period e.g. hour/week/month)
R: If more than 60 total hours per
week and this is legally allowed, are
there other considerations? Please
complete the boxes where relevant.
Multi select is possible.
Highest total
hours
40 per week
Lowest total
hours
40 per week
Overtime is voluntary
Onsite Collective bargaining allows 60+ hours/week
Safeguards are in place to protect worker’s health and safety
Site can demonstrate exceptional circumstances
Other reasons
Not Applicable – No overtime in the company
Please explain any checked boxes in R above
Comments:
(please state here any specific reasons/circumstances that explain the highest working hours)
Please add details of examples where the site has demonstrated “exceptional circumstances”.
Please give details of any appropriate safeguards in place at the time of the 60+ hours working.
Any other comments:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
40
7: No Discrimination is practiced
7: No Discrimination is Practiced
(Click here to return to NC–table)
ETI
7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirement
based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, union
membership or political affiliation.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems: There is no discrimination in hiring, compensation, access to training, promotion, termination or
retirement based on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation,
union membership or political affiliation. Same was confirmed during the interviews. Some of the employees are
Muslim and Gypsy and are not treated differently in any way. The employees shared that the Management is
against any conflict on religious or race basis.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Manual for internal labour rules and practices
ETI base code.
Discrimination Policy
Witnessing the work process
Interviews
Non–compliance:
1. Description of non–compliance:
NC against ETI
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI
NC against Local Law
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
41
Local law and/or ETI requirement:
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Comments:
Good Examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective Evidence
Observed:
42
8: Regular Employment Is Provided
8: Regular Employment Is Provided
(Click here to return to NC–table)
(Click here to return to Key Information)
ETI
8.1 To every extent possible work performed must be on the basis of recognised employment relationship
established through national law and practice.
8.2 Obligations to employees under labour or social security laws and regulations arising from the regular
employment relationship shall not be avoided through the use of labour–only contracting, sub–contracting, or
home–working arrangements, or through apprenticeship schemes where there is no real intent to impart skills or
provide regular employment, nor shall any such obligations be avoided through the excessive use of fixed–term
contracts of employment.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems: Vacancy workplaces are announced and hired employees undergo probationary period of not
more than 6 months. If positive result of job performance evaluation, employee is provided with regular
employment status. Nevertheless probationary or regular - worker has same benefits and rights. All workers sign
labour contract prior starting work. A newly employed person (six months of work) was interviewed.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Manual for internal labour rules and practices
ETI base code.
Witnessing the work process
Interviews
Non–compliance:
1. Description of non–compliance:
NC against ETI
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI
NC against Local Law
Local law and/or ETI requirement:
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43
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Comments:
Good Examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective Evidence
Observed:
44
8A: Sub–Contracting and Homeworking:
8A: Sub–Contracting and Homeworking
(Click here to return to NC–table)
(Click here to return to Key Information)
8A.1. There should be no sub–contracting unless previously agreed with the main client.
8A.2. Systems and processes should be in place to manage sub–contracting, homeworking and external
processing.
Note to auditor on homeworking:
Report on whether it is direct or via agents. How many workers, relationship with site and what control systems are
in place.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems:
The company is not using subcontractors or home workers.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate): The company is not using subcontractors or home workers.
If any processes are sub–contracted – please populate below boxes
Process Subcontracted
Process 1
Process 2
Name of factory
Address
Process Subcontracted
Name of factory
Address
Process 3
Process 4
Process Subcontracted
Name of factory
Address
Process 5
Process 6
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
45
Non–compliance:
1. Description of non–compliance:
NC against ETI/Additional Elements
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI /Additional Elements requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI/Additional Elements
NC against Local Law
Local law and/or ETI requirement:
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI/Additional elements requirement:
Comments:
Good Examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective Evidence
Observed:
46
Summary of sub–contracting – if applicable
Summary of sub–contracting – if applicable
A: If sub–contractors are used, is
there evidence this has been agreed
with the main client?
Yes
No
If Yes, summarise details: NOT APPLICABLE
B: Number of sub–
contractors/agents used
NOT APPLICABLE
C: Is there a site policy on sub–
contracting?
Yes
No
If Yes, summarise details: NOT APPLICABLE
D: What checks are in place to
ensure no child labour is being used
and work is safe?
NOT APPLICABLE
E: What processes are sub–
contracted?
NOT APPLICABLE
Summary of homeworking – if applicable
F: If homeworking is being used, is
there evidence this has been agreed
with the main client?
Yes
No
If Yes, summarise details: NOT APPLICABLE
G: Number of homeworkers
Male: NOT
APPLICABLE
H: Are homeworkers employed direct
or through agents?
Directly
Through Agents
NOT APPLICABLE
I: If through agents, number of
agents
NOT APPLICABLE
J: Is there a site policy on
homeworking?
Yes
No
NOT APPLICABLE
K: How does site ensure worker
hours and pay meet local laws for
homeworkers?
NOT APPLICABLE
L: What processes are carried out by
homeworkers?
NOT APPLICABLE
M: Are written agreements in place
for homeworkers that include regular
employment?
Yes
No
NOT APPLICABLE
N: Are full records available at the
site?
Female: NOT
APPLICABLE
Total: NOT
APPLICABLE
Yes
No
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
47
NOT APPLICABLE
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
48
9: No Harsh or Inhumane Treatment is allowed
9: No Harsh or Inhumane Treatment is Allowed
(Click here to return to NC–table)
ETI
9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or
other forms of intimidation shall be prohibited.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is
/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems:
Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse or other
forms of intimidation are prohibited. Documents show that management does not tolerate any harsh or inhumane
treatment in the company. During interviews there were found no clues of Harsh or Inhumane treatment.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Manual for internal labour rules and practices
ETI base code.
Witnessing the work process
Interviews
Non–compliance:
1. Description of non–compliance:
NC against ETI
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI
NC against Local Law
Local law and/or ETI requirement:
Recommended corrective action:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
49
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI requirement:
Comments:
Good Examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective Evidence
Observed:
50
10 A: Entitlement to Work and Immigration
10. Other Issue areas: 10 A: Entitlement to Work and Immigration
(Click here to return to NC–table)
Additional Elements
10A1 Only workers with a legal right to work shall be employed or used by the supplier.
10A2 All workers, including employment agency staff, must be validated by the supplier for their legal right to work
by reviewing original documentation.
10A3 Employment agencies must only supply workers registered with them.
10A4 The supplier shall implement processes to enable adequate control over agencies with regards the above
points and related legislation.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems:
Only workers with legal rights to work are employed. The company checks the personal identification cards, issued
by Bulgarian Ministry of Interior, before signing a labour contract with a person
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Manual for internal labour rules and practices
ETI base code.
Witnessing the work process
Interviews
Non–compliance:
1. Description of non–compliance:
NC against ETI/Additional Elements
NC against Local Law
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI /Additional Elements requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI/Additional Elements
NC against Local
Local law and/or ETI/Additional Elements requirement:
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
51
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI/Additional Elements requirement:
Comments:
Good examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective Evidence
Observed:
52
10B4: Environment 4–Pillar
10. Other issue areas 10B4: Environment 4–Pillar
(Click here to return to NC–table)
To be completed for a 4–Pillar SMETA Audit and remove the previous page which is 10B2 environment 2 pillar
B.4. Compliance Requirements
10B4.1 Suppliers as a minimum must meet the requirements of local and national laws related to environmental
standards.
10B4.2.Where it is a legal requirement, suppliers must be able to demonstrate that they have the relevant valid
permits including for use and disposal of resources e.g. water, waste etc.
10B4.3. The supplier shall be aware of their end client’s environmental standards/code requirements and have a
system in place to monitor their performance against these.
B4. Guidance for Observations
10B4.4. Suppliers should have completed the appropriate section of the SAQ and made it available to the auditor.
10B4.5. Suppliers should have an environmental policy, covering their environmental impact, which is
communicated to all appropriate parties, including its own suppliers.
10B4.6. Suppliers shall be aware of the significant environmental impact of their site and its processes.
10B4.7. The site should measure its impacts, including continuous recording and regular reviews of use and
discharge of natural resources e.g. energy use, water use (see 4–pillar audit report and audit checks for details).
10B4.8. Suppliers shall seek to make continuous improvements in their environmental performance.
10B4.9. Suppliers shall have available for review any environmental certifications or any environmental
management systems documentation
10B4.10. Suppliers should have a nominated individual responsible for coordinating the site’s efforts to improve
environmental performance.
10B.4.11. Has the site recently been subject to (or pending) any fines/prosecutions for noncompliance to
environmental regulations.
Note for auditors and readers. This environment section is intended to take not more than 0.25 auditor days. It is an
assessment only and the main requirement is to establish whether a site is meeting applicable environmental laws
and/or has any certifications or environmental management systems in place. Following this assessment the
client/supplier may decide a full environmental audit is required (see also best practice guidance/environment and
guidance for auditor)
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who
is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems:
Water, energy and gas consumption is being monitored on monthly basis. In general site has not been subject to
fines for non-compliances to environmental laws and regulations. During interviews it was found that responsible
persons are quite qualified and competent and willing to protect the environment. The company has contracts for
waste management with registered organizations.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
Records for quantities and invoices were presented.
Transportation cards from legally registered companies for waste management are available.
Interviews
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
53
Non–compliance:
1. Description of non–compliance:
NC against ETI/Additional Elements
NC against Local
Objective evidence
observed:
(where relevant please add
photo numbers)
Local law and/or ETI/Additional Elements requirement:
Recommended corrective action:
2. Description of non–compliance:
NC against ETI/Additional Elements
NC against Local
Local law and/or ETI/Additional elements requirement:
Recommended corrective action:
Observation:
Description of observation:
Objective evidence
observed:
Local law or ETI/Additional elements requirements:
Comments:
Good examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective Evidence
Observed:
54
Environmental Analysis
Environmental Analysis
(Site declaration only – this has not been verified by auditor. Please state units in all cases below.)
A; Responsible for Environmental issues (Name and
Position):
Katya Stanoeva – Management Representative
B: Does the site have a recognised environmental
system certification such as ISO 14000 or equivalent?
Please detail.
Yes
Details:
C: Does the site have an Environmental policy?
Yes
No
The company follows the requirements of the Local Law
(For guidance, please see Measurement criteria )
Does the site have a Biodiversity policy?
No
Yes
No
Yes
Details:
No
(For guidance, please see Measurement criteria )
E: Is there any other sustainability systems present such
as Chain of Custody, Forest Stewardship Council
(FSC), Marine Stewardship Council (MSC) etc.?
Please detail.
(For guidance, please see Measurement criteria )
F: Have all legally required permits been shown?
Please detail.
Yes
No
Details: License to operate. No license by the Ministry of
Ecology is required considering the type of production.
G: Is there a documentation process to record
hazardous chemicals used in the manufacturing
process?
Yes
Details:
H: Is there a system for managing client’s requirements
and legislation in the destination countries regarding
environmental and chemical issues?
Yes
No
Details: No such requirements have ever been
presented by the clients.
No
N/A
Usage/Discharge analysis
Criteria
Previous Year: Please state period:
January – December 2014
Current year: Please state period:
January 2015
Electricity Usage:
Around 3870 000 Kw/hrs
320 000 Kw/hrs
None
None
None
None
Kw/hrs
Renewable Energy Usage:
Kw/hrs
Gas Usage:
Kw/hrs
Has site completed any carbon
Footprint Analysis?
Yes
No
Yes
No
If Yes, please state result
Water Sources:
•
Sofia Municipal Water Supply
• Sofia Municipal Water Supply
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
55
Please list all sources e.g. lake, river,
and local water authority.
Water Volume Used:
Around 8750 m3
720 m3
(m³)
Water Discharged:
•
None
•
None
Please list all receiving waters/recipients.
Water Volume Discharged:
None
None
None
None
720 t
35 t
16 t
None
700 t
30 t
None
None
Around 2543 tones/year
Not yet calculated
(m³)
Water Volume Recycled:
(m³)
Total waste Produced
(please state units)
Total hazardous waste Produced:
(please state units)
Waste to Recycling:
(please state units)
Waste to Landfill:
(please state units)
Total Product Produced
(please state units)
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
56
10C: Business Ethics – 4–Pillar Audit
10C: Business Ethics – 4-Pillar Audit
(Click here to return to NC–table)
To be completed for a 4–Pillar SMETA Audit
10C. Guidance for “Observations”
10C.1. Suppliers should have completed the appropriate section of the SAQ and have made it available to the
auditor.
10C.2. The supplier should have received and acknowledged– preferably in writing – the Business Ethics policy of
the auditor/audit company.
10C.3. Suppliers shall seek to conduct their business ethically without bribery, corruption, or any type of fraudulent
Business Practice.
10C.4. Suppliers shall be aware of any applicable laws, their end client’s Business Ethics standards/code
requirements and have a system in place to monitor their performance against these.
10C.5. Supplier should have a Business Ethics policy concerning bribery, corruption, or unethical Business
Practice. This should be clearly communicated to all relevant parties.
10C.6. Suppliers should have a designated person responsible for implementing standards concerning Business
Ethics
10C.7. Suppliers should have a transparent system in place for confidentially reporting, and dealing with unethical
Business Ethics without fear of reprisals towards the reporter
10C.8. Suppliers should ensure that the staff whose job roles carry a higher level of risk in the area of ethical
Business Practice e.g. sales, purchasing, logistics are trained on what action to take in the event of an issue arising
in their area.
Note for auditors and readers. This Business Ethics section is intended to take not more than 0.25 auditor days. It
is an assessment not an audit and the main requirement is to gather information on the relevant Business Ethics
issues in a supply chain. All findings will be recorded as observations not Non– Compliances and the data collected
will allow the membership to define appropriate standards over time as part of a continuous review process.
Current Systems and Evidence Examined
To complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and
record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is
/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to
support the systems.
Current systems:
There are clear statements about ethical, transparent and respectful relationship with suppliers. Business
relationship shall be carried out as per preliminary agreed conditions of integrity, transparency and cooperation and
without briberies.
There are rules for assessment and approval of suppliers, based on quality of the goods, years of experience,
prices and years of experience and relationship. There was not found any info about bribery, corruption, or any
type of fraudulent Business Practice.
Evidence examined – to support system description (Documents examined & relevant comments. Include
renewal/expiry date where appropriate):
ETI base code.
Witnessing the work process
Interviews
Observation
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
57
Description of observation:
Objective evidence
observed:
Local law or ETI/Additional elements requirement:
Comments:
Good examples observed:
Description of Good Example (GE):
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
Objective Evidence
Observed:
58
Worker Interview Summary
Worker Interview Summary
A: Were workers aware of the audit?
Yes
No
B: Were workers aware of the code?
Yes
No
C: Number of group interviews:
1 group of 4
(Please specify number and size of
groups. Please see SMETA Best
Practice Guidance and Measurement
Criteria)
D: Number of individual interviews
Male: 2
Female: 7
Male: 2
Female: 12
(Please see SMETA Best Practice
Guidance and Measurement Criteria)
E: Total number of interviewed
workers
(Please see SMETA Best Practice
Guidance and Measurement Criteria)
F: Interviews were done in private
and the confidentiality of the
interview process was
communicated to the workers?
Yes
No
G: In general, what was the attitude
of the workers towards their
workplace?
Favourable
Non–favourable
Indifferent
H: What was the most common
worker complaint?
No complaints have been shared
I: What did the workers like the most
about working at this site?
Management attitude
Timely payment
Permanent employment
Working conditions
Transport
J: Any additional comment(s)
regarding interviews:
None
K: Attitude of workers to hours
worked:
Favourable
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
59
Agency Workers
Agency Workers (if applicable)
(workers sourced from a local agent who are not directly paid by the site)
A: Number of agencies used
(average):
None
And names if available:
B: Were agency workers’
age/pay/hours included within scope
of this audit
Yes
No
NOT APPLICABLE
C: Were sufficient documents for
agency workers available for review?
Yes
No
NOT APPLICABLE
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
60
Other findings
Other Findings Outside the Scope of the Code
NOT APPLICABLE
Community Benefits
(Please list below any specific community benefits that the site management stated that they were involved in, for example, HIV
programme, education, sports facilities)
NOT APPLICABLE
Audit company: Bureau Veritas Report reference: SOF/15/7146 Date: 19-20/02/15
61
Appendix 1
Comparison between ETI code and Customer's Supplier's Code. Any areas where a site complies with the
Customer's Supplier Code, but not with the ETI code are discussed at the audit close out meeting and recorded on
the CAPR. Note to supplier "for this customer it may not be necessary to complete corrective actions where NC's
DO NOT meet the ETI code, but DO meet your customer's code. If the audit is shared with other customers who
work to the ETI code or an equivalent international standard, corrective actions will be necessary."
NOTE: The provisions of the ETI base Code constitute
minimum and not maximum standards, and this code
should not be used to prevent companies from
exceeding these standards. Companies applying the
ETI Base Code are expected to comply with national
and other applicable law and, where the provisions of
law and the ETI Base Code address the same subject,
to apply that provision which affords the greater
protection.
Instruction to Audit Company: fill in the relevant
clauses from the Customer Supplier Code - where
applicable.
ETI Code
Customer's Supplier Code equivalent
ETI 1. Employment is freely chosen
ETI 1. Employment is freely chosen
1.1. There is no forced, bonded or involuntary prison
labour.
1.2. Workers are not required to lodge "deposits" or their
identity papers with their employer and are free to leave
their employer after reasonable notice.
ETI 2. Freedom of association and the right to
collective bargaining are respected
ETI 2. Freedom of association and the right to
collective bargaining are respected
2.1. Workers, without distinction, have the right to join or
form trade unions of their own choosing and to bargain
collectively.
2.2. The employer adopts an open attitude towards the
activities of trade unions and their organisational
activities.
2.3. Workers representatives are not discriminated
against and have access to carry out their
representative functions in the workplace.
2.4. Where the right to freedom of association and
collective bargaining is restricted under law, the
employer facilitates, and does not hinder, the
development of parallel means for independent and free
association and bargaining.
ETI 3. Working conditions are safe and hygienic
ETI 3. Working conditions are safe and hygienic
3.1. A safe and hygienic working environment shall be
provided, bearing in mind the prevailing knowledge of
the industry and of any specific hazards. Adequate
steps shall be taken to prevent accidents and injury to
health arising out of, associated with, or occurring in the
course of work, by minimising, so far as is reasonably
practicable, the causes of hazards inherent in the
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working environment.
3.2. Workers shall receive regular and recorded health
and safety training, and such training shall be repeated
for new or reassigned workers.
3.3. Access to clean toilet facilities and to potable water,
and, if appropriate, sanitary facilities for food storage
shall be provided.
3.4. Accommodation, where provided, shall be clean,
safe, and meet the basic needs of the workers.
3.5. The company observing the code shall assign
responsibility for health and safety to a senior
management representative.
ETI 4. Child labour shall not be used
ETI 4. Child labour shall not be used
4.1. There shall be no new recruitment of child labour.
4.2. Companies shall develop or participate in and
contribute to policies and programmes which provide for
the transition of any child found to be performing child
labour to enable her or him to attend and remain in
quality education until no longer a child; “child” and
“child labour” being defined in the appendices.
4.3. Children and young persons under 18 shall not be
employed at night or in hazardous conditions.
4.4. These policies and procedures shall conform to the
provisions of the relevant ILO standards.
ETI 5. Living wages are paid
ETI 5. Living wages are paid
5.1. Wages and benefits paid for a standard working
week meet, at a minimum, national legal standards or
industry benchmark standards, whichever is higher. In
any event wages should always be enough to meet
basic needs and to provide some discretionary income.
5.2. All workers shall be provided with written and
understandable Information about their employment
conditions in respect to wages before they enter
employment and about the particulars of their wages for
the pay period concerned each time that they are paid.
5.3. Deductions from wages as a disciplinary measure
shall not be permitted nor shall any deductions from
wages not provided for by national law be permitted
without the expressed permission of the worker
concerned. All disciplinary measures should be
recorded.
ETI 6. Working Hours are not excessive
ETI 6. Working Hours are not excessive
6.1 Working hours must comply with national laws,
collective agreements, and the provisions of 6.2 to 6.6
below, whichever affords the greater protection for
workers. Sub–clauses 6.2 to 6.6 are based on
international labour standards.
6.2 Working hours, excluding overtime, shall be defined
by contract, and shall not exceed 48 hours per week.
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6.3 All overtime shall be voluntary. Overtime shall be
used responsibly, taking into account all the following:
the extent, frequency and hours worked by individual
workers and the workforce as a whole. It shall not be
used to replace regular employment. Overtime shall
always be compensated at a premium rate, which is
recommended to be not less than 125% of the regular
rate of pay.
6.4 The total hours worked in any 7 day period shall not
exceed 60 hours, except where covered by clause 6.5
below.
6.5 Working hours may exceed 60 hours in any 7 day
period only in exceptional circumstances where all of
the following are met:
– this is allowed by national law;
– this is allowed by a collective agreement freely
negotiated with a workers’ organisation representing a
significant portion of the workforce;
– appropriate safeguards are taken to protect the
workers’ health and safety; and
– The employer can demonstrate that exceptional
circumstances apply such as unexpected production
peaks, accidents or emergencies.
6.6 Workers shall be provided with at least one day off
in every 7 day period or, where allowed by national law,
2 days off in every 14 day period.
ETI 7. No discrimination is practised
ETI 7. No discrimination is practised
There is no discrimination in hiring, compensation,
access to training, promotion, termination or retirement
based on race, caste, national origin, religion, age,
disability, gender, marital status, sexual orientation,
union membership or political affiliation.
ETI 8. Regular employment is provided
ETI 8. Regular employment is provided
8.1. To every extent possible work performed must be
on the basis of recognised employment relationship
established through national law and practice.
8.2. Obligations to employees under labour or social
security laws and regulations arising from the regular
employment relationship shall not be avoided through
the use of labour-only contracting, sub-contracting, or
home-working arrangements, or through apprenticeship
schemes where there is no real intent to impart skills or
provide regular employment, nor shall any such
obligations be avoided through the excessive use of
fixed-term contracts of employment.
ETI 9. No harsh or inhumane treatment is allowed
ETI 9. No harsh or inhumane treatment is allowed
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Physical abuse or discipline, the threat of physical
abuse, sexual or other harassment and verbal abuse or
other forms of intimidation shall be prohibited.
SMETA Extra Sections for 4 Pillar Audit:
SMETA Extra Sections for 4 Pillar Audit:
Environment Section
Environment Section
D1. Suppliers as a minimum shall meet the
requirements of local and national laws related to
environmental standards.
D2. Suppliers shall seek to make continuous
improvements in their environmental performance.
D3. The supplier shall be aware of their end client’s
environmental standards/code requirements and have a
system in place to monitor their performance against
these.
D4. Suppliers shall have available for review any
environmental certifications or any environmental
management systems documentation.
D5. Suppliers should be aware of the significant
environmental impacts of their site and its processes.
D6. Suppliers should have an environmental policy,
covering its environmental impacts, which are
communicated to all appropriate parties, including their
own suppliers.
D7. Suppliers should have a nominated individual
responsible for coordinating the site’s efforts to improve
environmental performance.
D8. Where appropriate suppliers must be able to
demonstrate that they have the relevant valid permits for
use and disposal of resources e.g. water, waste, etc.
Business Practices Section
Business Practices Section
E1. As a minimum, suppliers must comply with the
requirements of local and national laws and regulations
in the area of business integrity.
E2. Suppliers shall seek to conduct their business
ethically without bribery, corruption or any other type of
fraudulent or unfair business practice.
E3. Suppliers shall be aware of their end client’s
business integrity standards/code requirements and
have a system in place to monitor their performance
against these.
E4. Suppliers should have a business integrity policy
concerning bribery, corruption or unethical business
practice. This should be clearly communicated to all
relevant parties.
E5. Suppliers should have a transparent system in place
for confidentially reporting, and dealing with, unethical
business practices, without fear of reprisals towards the
reporter.
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Photo Form
Adding Images To help keep the size of the Report as small as possible for ease of sending and
saving the document we recommend that you use Microsoft Paint to resize your photos. To do so please
follow these instructions:
1) To start Microsoft Paint, click 'Start', 'Programs', 'Accessories', then 'Paint'.
2) Open the image file you wish to edit.
3) Click the 'Image' Menu at the top and select "Stretch/Skew Image”.
4) Choose a percentage figure to resize the image: to avoid distortion, choose the same percentage for
horizontal and vertical stretch. Click OK.
5) Once you have the desired size, click File > Save As… (To prevent overwriting the original image).
Save As jpeg (this provides compression to make the file smaller).
6) Please delete this text once complete.
Evacuation scheme
Exit Signs
Hydrant
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Work Premises First-aid kit
Extinguisher
Extinguisher
Changing room
Outside view of the warehouse
Extinguisher
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Resting Area
Resting Area
Extinguisher
Production Area
Coffee machine
Departments Information Board
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Pictures – Site Varna
Dedrax Varna office entrance
Kitchen facilities site Varna
Potable water – site Varna (office)
Production area site Varna
Finished products site Varna
Hot drinks machine in the production area
site Varna
Fire extinguisher production area site Varna
Potable water production area site Varna
Evacuation scheme production area site
Varna
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Evacuation signs site Varna
Emergency door production area site Varna
Toilets production area site Varna
Toilets production area site Varna
First aid kit production area site Varna
Firefighting system production area site
Varna
Hazardous wastes storage place production
area site Varna
Hazardous chemicals production area site
Varna
Fire signaling system production area site
Varna
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Your feedback on your experience of the SMETA audit you have observed is extremely valuable.
It will help to make improvements to future versions.
You can leave feedback by following the appropriate link to our questionnaire:
Click here for A & AB members:
http://www.surveymonkey.com/s.aspx?sm=riPsbE0PQ52ehCo3lnq5Iw_3d_3d
Click here for B members:
http://www.surveymonkey.com/s.aspx?sm=d3vYsCe48fre69DRgIY_2brg_3d_3d
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