1: Employment freely chosenmethod
1. Work is not voluntary, for
example, unpaid overtime,
bonded, forced or trafficked
Critical 30 days Follow up
2. Workers who refuse overtime
are penalised, for example,
threats of dismissal, pay cuts,
demotion etc.
Critical 30 days Follow up
处罚拒绝加班的工人，例如，解雇的威胁，支付削减，降级等。
3. Any involuntary prison labour. Critical 30 days Follow up
任何非自愿的监狱劳动
4. retention by employer or
employment agent of original
identification papers and/or
passports unless required by law
Critical 30 days Follow up
5. Workers are not allowed to
leave the facility when shifts end
Critical 30 days Follow up
6. Workers are not able to resign
from the factory
Critical 30 days Follow up
7. Workers paying deposits when
commence employment
Major 30 days Follow up
8. unreasonable delays in
payments due to workers when
they leave
Major 60 days Follow up
9. unreasonable notice
requirements or financial penalties
for leaving
Major 60 days Follow up
10. Monetary deposits, for
example, for work tools, PPE,
training
Major 30 days Follow up
11. Excessive monetary deposits
for accommodation
Minor 30 days Follow up
12. Complete absence of toilet
and rest breaks
Critical 30 days Follow up
13. Workers monitored when they
go to toilets
Major 30 days Follow up
14. No policy on prison labour Minor 30 days desktop
15. No free employment policy Minor 30 days desktop
16. Extended probation period Minor 90 days Follow up
2: Freedom of association
1. Workers who wish to form or
join a trade union or worker
committee but are prevented by
management from doing so - and
there is a breach of national law
Critical 30 days Follow up
2. Workers who wish to join union
or worker committee but are
unable to do so - and there is no
breach of national law i.e. minority
of workers want to join
Major 60 days Follow up
3. There is no formal structure for
worker representation
Major 30 days Follow up
4. Failure to have works
councils/worker participation in
committees or equivalent where
a legal requirement.
Critical 30 days Follow up
5. Penalising or discriminating
workers or workers reps in any
way for seeking to join, joining,
being members of, taking part in
activities of or seeking to establish
or be represented by a trade
union or worker committee
Critical 60 days Follow up
6. Consistent refusal of facilities
for trade union activities
Critical 60 days Follow up
7. Employer interferes with union
decision making or the election or
appointment of workers
representatives
Critical 30 days Follow up
8. Employer obstructing recruitment
activities or denying unions
reasonable access for recruitment
Critical 60 days Follow up
9. Evidence of a critical
communication breakdown
between workers and employers
which may lead to serious conflict
or abuse
Critical 30 days Follow up
10. Workers reps are not
democratically elected
Major 60 days Follow up
11. Lack of regular elections for
workers reps where there is a
legal requirement
Critical 90 days Follow up
12. unequal representation of
management to workers
Major 60 days Follow up
13. Workers representatives not
given time off to meet and
address issues
Major 60 days Follow up
14. Collective agreements fail to
comply with local law
Critical 30 days Follow up
15. Collective agreements not in
writing or not available to
workforce
Major 60 days Follow up
16. Company does not comply
with collective agreement
Major 60 days Follow up
17. Workers forced to talk to
managers about sensitive issues
Major 30 days Follow up
18. No policy on Freedom of
Association and right to
Collective Bargaining
Minor 60 days desktop
19. Inadequate facilities for union
activities
Minor 60 days desktop
20. Workers do not know who
their reps are
Minor 60 days Follow up
21. No training for worker
representatives
Minor 60 days desktop
22. No action taken on issues
raised during meetings
Minor 60 days desktop
23. No records kept from
management/worker meeting
Minor 60 days desktop
24. Lack of documentary
evidence of bargaining
Minor 60 days desktop
25. Lack of effective worker/
management engagement
Major 60 days Follow up
3: Health and safety
3.1: FIrE SAFETY
1. Locked or no fire exits Critical Immediate Follow up
2. Insufficient fire exits Major 60 days Follow up
3. No fire exit signage Major 30 days desktop
4. Fire escape doors poorly
marked and/or maintained
Major 60 days desktop
5. Missing fire assembly points Minor 60 days desktop
6. Blocked aisles/exits preventing
use
Major 30 days desktop
7. No fire fighting equipment on
site
Critical 30 days Follow up
8. Fire fighting equipment
inaccessible, insufficient,
unusable of wrong type or no
training on its use
Major 60 days desktop
9. Fire extinguishers out of date Major 60 days desktop
10. Fire extinguishers installed at
the incorrect height
Minor 30 days desktop
11. No fire alarm Major 30 days desktop
12. Lack of distinctive fire alarm Major 30 days desktop
13. No evacuation procedures,
drills or training
Major 60 days desktop
14. No records of fire evacuation
drills
Minor 60 days desktop
15. Incomplete records of fire
evacuation drills
Minor 60 days desktop
16. No, or no adequate,
functioning emergency lighting
Major 30 days desktop
17. Poor maintenance emergency
light
Minor 60 days desktop
18. Failure to comply with
requirements for electrical safety
inspections
Major 30 days desktop
19. Electrical wiring not
adequately encased or secured
Major 30 days desktop
20. No or inadequately
maintained equipment or
procedures to prevent explosions
Major 30 days desktop
3.2: BuILdINGS
1. Premises are not structurally
safe
Critical Immediate Follow up
2. Premises require repairs that
affect personal safety
Major 30 days Follow up
3. Inadequate lighting in
hazardous areas
Major 60 days desktop
4. Generally inadequate lighting in
some areas
Minor 60 days desktop
5. Heating and ventilation and Air
Conditioning – Systematic failures
in maintenance programme
Major 60 days Follow up
6. Heating and ventilation and Air
Conditioning - Isolated failures in
maintenance programme
Minor 90 days desktop
7. The facility lacks the permits
and certificates required
Major 90 days desktop
3.3: MANAGEMENT SYSTEMS
1. No Health and Safety
Management Systems in place
Critical 90 days Follow up
2. Systematic failures in health
and safety systems
Major 60 days Follow up
3. No health and safety certificates Major 90 days desktop
4. Health and safety certificates
expired
Minor 90 days desktop
3.4: CHEMICALS
1. No or dangerous storage/disposal
facilities for hazardous chemicals
Critical 30 days Follow up
2. Storage of hazardous materials
in accommodation premises
Critical 30 days Follow up
3. Inadequate storage facilities,
disposal, labelling, training,
containment or spill kits for
hazardous chemicals or lapses in
their use
Major 60 days desktop
4. Inadequate provisions for safe
handling of hazardous chemicals
or lapses in their application
Major 30 days desktop
5. MSdS not available Major 60 days desktop
3.5: ACCOMMOdATION
1. Accommodation not
structurally safe
Critical Immediate Follow up
2. Production area and dormitory
area together
Major
30 days if
unsafe 120
days if new
build
Follow up
3. Personal living space does not
meet legal and industrial minimum
standards
Critical 60 days Follow up
4. Each individual does not have
own sleeping mat/bed
Major 60 days desktop
5. Personal living space and/or
sleeping areas are not separated
by gender
Major 30 days desktop
6. Living conditions are unsanitary Major 30 days desktop
7. unsafe appliances Major 30 days Follow up
8. No secure personal storage for
personal effects
Major 60 days desktop
9. Inadequate laundry facilities Minor 60 days desktop
10. Poor housekeeping Minor 30 days desktop
11. Inadequate secure storage for
personal effects
Minor 30 days desktop
3.6: WOrkEr HEALTH
1. Clean drinking water not
available
Critical Immediate Follow up
2. Clean drinking water not easily
accessible
Major 30 days desktop
3. No testing of water for
potability.
Minor 30 days desktop
4. Some lapses in records of
water testing
Minor 30 days desktop
5. Factory equipment
inappropriately used, maintained
or designed that could lead to
loss of limb or life
Critical Immediate Follow up
6. Factory equipment
inappropriately used, maintained
or designed that could cause
serious injury
Major 30 days Follow up
7. Lack of regular maintenance by
appropriately trained personnel of
machines which are a potential
danger to life or health
Critical 60 days desktop
8. Workstations and work areas
are untidy creating a risk of
serious injury
Major 30 days desktop
9. Workstations and work areas
are untidy creating a risk of
moderate injury
Minor 30 days desktop
10. Slippery surfaces creating injury
risk
Major 30 days Follow up
11. Suitable PPE not issued to
workers or not worn in hazardous
environments
Critical 30 days desktop
12. Suitable PPE not always
issued, for example, insufficient
hearing protectors in areas where
noise exceeds recommended limits
Major 30 days desktop
13. Suitable PPE issued but not
consistently worn or maintained
Minor 30 days desktop
14. No health and safety training
for workers in hazardous areas
Critical 30 days desktop
15. Inadequate health and safety
training for workers in hazardous
areas.
Major 30 days desktop
16. Systematic failures to provide
health and safety training for
workers
Major 30 days desktop
17. Isolated failures to provide health
and safety training for workers
Minor 90 days desktop
18. Lack of appropriate equipment
or training for safe handling of loads
which constitute a serious risk
Major 30 days desktop
19. Lack of eye or needle guards
on sewing machines or belt guards
on machines
Major 30 days desktop
20. No wash facilities in hazardous
environments including eye wash
facility where appropriate.
Critical 30 days desktop
21. Inadequate toilet and washing
facilities and/or facilities not
separated by gender
Major 90 days desktop
22. Injuries/accidents are not recorded Major 30 days desktop
23. No appropriate medical
examinations of workers in hazardous
environments (for example, for
hearing loss because of noise)
Major 90 days desktop
24. Isolated failures to carry out
medical examinations
Minor 90 days desktop
25. No medical room was provided
for the workers
Major 30 days desktop
26. No trained first aid personnel Major 30 days desktop
27. Insufficiently trained first aid
personnel/workers do not know
who they are
Minor 60 days desktop
28. Inadequate health and safety
provision and procedures for
pregnant workers
Major 30 days desktop
29. No Health and Safety
representatives and/or Committee
Major 30 days desktop
30. No first aid kits available Critical Immediate Follow up
31. Inadequate numbers or
maintenance of first aid kits
Minor 30 days desktop
32. Inadequate provision for
hygienic food storage and
preparation
Major 30 days desktop
33. No noise assessment has
taken place
Minor 60 days desktop
34. Worker transport where
provided is unsafe or inadequate
Major 30 days Follow up
4: Child labour
1. under 15 years Critical Immediate Follow up
2. under country’s legal minimum
age but >15
Major 30 days Follow up
3. Systematic cases of evidence
of individual’s age and identity
being unavailable, incomplete,
false, or not kept on personnel file
Critical 30 days Follow up
4. Isolated cases of evidence of
individual’s age and identity being
unavailable, incomplete, false, or
not kept on personnel file
Major 30 days Follow up
5. Company accepts photocopy
Ids from workers without
checking originals
Major 30 days Follow up
6. Child on site but not working Major 30 days Follow up
7. Young persons hours of work
contrary to local law
Major 30 days Follow up
8. Young persons engaged in
night work
Major 30 days Follow up
9. Young persons engaged in
hazardous work
*could be critical in some cases
Major
*Critical
Immediate Follow up
10. Young workers not registered
or recorded per legal
requirements with local labour
bureau or equivalent
Major 30 days Follow up
11. No risk assessments for
young workers
Major 30 days desktop
12. No health examination for
young workers
Major 30 days Follow up
13. No recruitment policy for
young workers
Minor 30 days desktop
14. No remediation policy in place
for child workers
Minor 30 days desktop
15. Contracts for young workers
not signed by parent or legal
guardian (see Employment is Freely
Chosen re general issues on
contracts)
Minor 30 days desktop
16. No policy on child labour Minor 30 days desktop
5: Wages and benefits
1. Employees work without
payment
Critical Immediate Follow up
2. Employees pay or piece rate
earnings below any applicable
legal minimum wage or agreed
national industry benchmark
Critical 60 days Follow up
3. O/T premiums not paid at ,
according to law or not paid for
holidays worked
Critical 60 days Follow up
4. Wages and hours could not be
verified due to inconsistent or
incomplete records
Critical* 60 days Follow up
5. Evidence of deliberate
falsification of wage and hours
records (double books)
Critical* 60 days Follow up
6. No payroll or time records Critical 60 days Follow up
7. Wages not paid on time Major 60 days Follow up
8. Legally required allowances,
bonuses or benefits are not paid
or not paid correctly
Major 60 days Follow up
9. Legally required social security
payments are not paid correctly
Major 60 days Follow up
10. No paid annual leave Major 60 days Follow up
11. Factory is using home
working, other factories, or other
locations as a way of avoiding
paying overtime premiums
Major 60 days Follow up
12. unreasonable deductions
from wages
Major 60 days Follow up
13. Isolated inconsistencies
between payroll records, payslips
and other records (poor record
keeping)
Major 60 days Follow up
14. Pay slips not provided with
each payment in local language
Major 60 days Follow up
15. Workers have not been given
information, or understand how
wages are calculated
Minor 60 days Follow up
16. Failure to pay meals allowance
where a legal requirement
Major Immediate Follow up
These issues may be downgraded to major significance if a site is able
to produce correct records. refusal or inability to show correct time and
payroll records will result in critical significance.
6: Working hours
1. unreasonable hours i.e. total
working hours are in excess of 72
hours per week
Critical 60 days Follow up
2. Total working hours are in
between 60-72 hours or above
the legal limit whichever is lower
Major 60 days Follow up
3. Overtime hours regularly
exceed 12 hours per week or
local law, whichever is the lower
Major 60 days Follow up
4. Standard hours regularly
exceed 48 or local law, whichever
is the lower
Major 60 days Follow up
5. Isolated cases of overtime
exceeding 12 hours per week or
local law, whichever is the lower
Minor 60 days Follow up
6. Isolated cases of standard
hours exceeding 48 per week or
local law, whichever is the lower
Minor 60 days Follow up
7. regular/Systemic 7-day working Critical 60 days Follow up
8. Occasional/Isolated 7
days/week working
Major 60 days Follow up
9. Wages and hours could not be
verified due to inconsistent or
incomplete records
Critical* 60 days Follow up
10. Evidence of deliberate
falsification of wage and hours
records (double books)
Critical* 60 days Follow up
11. Isolated inconsistencies
between payroll records, payslips
and other records (poor record
keeping)
Major 60 days Follow up
12. Working without correct legal
breaks
Major 60 days Follow up
13. Pregnant, younger or female
workers working illegal hours or
without prior approval from local
labour bodies
Major 60 days Follow up
14. No clear policy on overtime
working and/or policy has not
been communicated to or
understood by workers
Minor 30 days desktop
These issues may be downgraded to major significance if a site is able
to produce correct records. refusal or inability to show correct time and
payroll records will result in critical significance.
7: discrimination
1. Sexual abuse or harassment Critical Immediate Follow up
2. dismissal of Pregnant workers Critical Immediate Follow up
3. Pregnancy testing of
employees/potential recruits
Critical Immediate Follow up
4. Evidence of 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
Major 30 days Follow up
5. Not meeting legal requirements
on working conditions for
pregnant, post partum or lactating
women
Major 30 days Follow up
6. Women returning from
maternity leave not given
equivalent position and pay
Major 60 days Follow up
7. Suspicion of discrimination –
no proof
Minor Immediate Follow up
8. Lack of transparency/lack of
policies on employment practices
Minor 30 days desktop
9. No policy on discrimination Minor 30 days desktop
Any findings of harassment or abuse must be dealt with immediately, but
any policy changes, or implementation of anti – discrimination training may
require longer. A period of 30 -60 days is allowed for proof of change and
implementation of new policies. However all critical discrimination issues
must cease immediately.
8: regular employment
1. Complete absence of contracts Critical 30 days Follow up
2. Agency does not meet national
requirements as a labour provider
Critical 30 days Follow up
3. Isolated absence of contracts Major 30 days desktop
4. Copies of terms and conditions
not provided to workers
Major 30 days Follow up
5. Workers are required to sign
blank papers, resignation letters
etc.
Major Immediate Follow up
6. Absence of clear,
understandable written terms and
conditions of employment which
comply with local law and are
signed by workers
Major 30 days desktop
7. Facility imposing additional
terms or requirements on worker
after employment contract signed
Major 30 days Follow up
8. Probation periods exceeds
legally allowed period
Major 60 days Follow up
9. Subcontractor failing to meet
labour standards
Major 30 days Follow up
10. Workers are fired and rehired
to avoid paying same terms and
benefits as for permanent workers
Major 30 days Follow up
11. Workers are consistently
employed on temporary
contracts
Major 90 days Follow up
12. Agency workers not receiving
full legal and social security
entitlements
Major 30 days Follow up
13. unreasonable payment of fee
to agent by the worker in own
home or host country
Major 60 days Follow up
14. Agencies are charging
workers fees which exceed
relevant legal limits
Major 30 days Follow up
15. Workers are not receiving
employment contract in home
country and/or having additional
contract when in country of work
Major 90 days Follow up
16. Contract not accurate or up
to date
Minor 30 days desktop
9: discipline
1. Any physical punishment or
sexual harassment of workers
Critical Immediate Follow up
2. Supervisors or managers
taking bribes including sexual
favours
Critical Immediate Follow up
3. Extreme verbal abuse Critical Immediate Follow up
4. Shouting or swearing at or
other forms of verbal abuse of
workers
Major Immediate Follow up
5. unreasonable personal body
searches
Critical Immediate Follow up
6. No formal disciplinary or
grievance procedure
Major Immediate Follow up
7. rules and disciplinary action
not transparent and/or
documented
Major 30 days Follow up
8. Inadequate
disciplinary/grievance procedure
Minor 30 days Follow up
9. Managers and supervisors do
not follow the disciplinary
procedure
Major 30 days Follow up
10. Failure to discipline
supervisors/ managers or fellow
workers who abuse workers
Major 30 days Follow up
11. disciplinary and grievance
procedures not communicated
to/not understood by workers
Minor 30 days Follow up
12. unreasonable policy and
practice of fining workers for
breaking rules
Major 30 days Follow up
13. Workers fined an
unreasonable amount for lateness
Major 30 days Follow up
All forms of abuse must cease immediately, but a period of 30 days is
allowed for implementing a policy against abuse
