- Step 1: Engage Stakeholders and Partners
- Step 2: Assess risks and impacts
- Step 3: Develop code of conduct
- Step 4: Communicate and Train across your supply chain
- Step 5: Monitor compliance
- Step 6: Remediate violations
- Step 7: Independent review
- Step 8: Report performance
Steps in an Audit
An audit typically consists of several steps, listed below. As appropriate, other steps can be included in an audit, such as interviews with trade union representatives. Click on each step below to learn more.
- Arrival at the worksite
- Opening meeting with management
- Walk-through of the worksite
Company practice varies in terms of whether worksites are notified in advance of an audit (an “announced audit”). However, best practice in this area normally is unannounced audits. No one at the worksite should be notified in advance that the audit team will visit on a particular day.
The purpose of the opening meeting is to explain the audit process to the worksite managers, including the portions in which management is or is not requested to participate. This is also the time for the team to request the documentation needed for the audit; management may need some time to assemble those documents after the meeting.
The purpose of the walk-through is to observe conditions in the factory and any associated locations such as cafeterias and dormitories. This allows the audit team to get a sense of any discernible social compliance concerns; for instance, the auditors may observe workers that appear young, possibly below the minimum age. The team should observe, but not disrupt, the flow of work in the factory. Auditors may choose to speak with workers briefly, but not in a manner that would interrupt their work or put the workers in any jeopardy. The walk-through is also a good time to examine safety equipment, emergency exits and timekeeping systems.
The Challenges of Age Verification
“Establishing the age of job applicants remains a major challenge in many parts of the world. Many companies working in countries where birth records are non-existent have had to devise their own means for determining age. In its 2001 Corporate Responsibility Report, Nike relates its experiences in verifying the age of workers in its partner manufacturers in Cambodia. There, a factory manager seeking to comply with national law and Nike Code of Conduct standards “must deal with a bewildering set of documents presented by a worker, including a record of family births and deaths (the ‘family book’), a district registration, voter's registration, and a medical certificate. All carry some form of official stamp. And each can be purchased on the black market for the equivalent of $5.”
So long as public records remain unreliable, this challenge will remain for employers seeking to avoid hiring children. Some strategies for addressing the issue include requiring multiple forms of written documentation, requiring prospective employees to undergo medical examinations prior to hiring, carrying out interviews with candidates whose age appears questionable, issuing photo identification cards to all employees, and maintaining a database to flag underage job applicants.”
Source: Excerpted from International Finance Corporation, Good Practice Note: Addressing Child Labor in the Workplace and Supply Chain, 2002.
- Worker interviews
- Management interviews
- Interviews with labor brokers and recruiters
- Documentation review
- Age verification procedures and documents
- Master list of juvenile workers
- Selection and recruitment procedures
- Contracts with labor brokers
- Worker contracts/employment agreements
- Worker personal documents that may be in the employer’s keeping
- Introduction program and materials
- Personnel files
- Employee communication and training plan - certifications including but not limited to skills training, worker preparedness, government certification programs, systems/policy orientations
- Collective bargaining agreements, including union certification, role of the union and minutes of meetings
- Contracts with and scope of responsibilities of security agencies
- Payroll and time records
- Production capacity reports
- Written human resources policies and procedures
- Occupational health and safety plans and records including legal permits, maintenance and monitoring records, injury/accident reports, investigation procedures, chemical inventories, personal protective equipment inventories, training certificates and evacuation plans
- Disciplinary notices
- Grievance reports
- Performance evaluations
- Promotion and/or merit increases
- Dismissal and suspension records
- Records of employees who have resigned
- Worker paystubs
- Closing meeting with management
- Report preparation
The team should select a cross-section of workers to interview. The selected workers should represent the full diversity of the workplace, and include (as applicable) men and women, migrant workers and local workers, workers on different shifts, workers performing different tasks, members of various production teams, etc. If there are young persons in the facility, a representative group should be interviewed using age-sensitive interview techniques.
Interviews may be conducted individually or in groups, and typically should be conducted both inside and outside the facility. Particularly in cases where there are indications of egregious violations about which employees may hesitate to discuss at work, auditors may need to make time to speak with workers outside work hours and away from the worksite. Auditors should use their audit tools to ensure that they ask workers a comprehensive set of questions. They also should collect copies of paystubs from workers in order to compare them to management-provided payment records.
Interviews also provide workers a chance to voice any other concerns they may have. Workers should be ensured that all responses are confidential and are never shared with management. Your contract with suppliers should include a clause on non-retaliation against workers for participating in an audit; participation in an audit should carry the same worker protections as any grievance mechanism.
Management interviews provide an opportunity to corroborate or find discrepancies in information gathered through worker interviews. The team should interview a cross-section of management including human resources personnel, production supervisors and others. Audit tools should be used to ensure that they ask managers a comprehensive set of questions.
For companies with significant numbers of migrant and contract workers in their supply chains, there is an increasing movement toward interviewing labor recruiters and brokers as part of the audit process. Gaining access to recruiters or brokers for interviews can be a challenge, and is likely to require the supplier’s coordination and cooperation. Verité’s Fair Hiring Toolkit includes sample interview questions for labor brokers as well as labor recruitment-related questions for managers and migrant workers themselves.
The purpose of a documentation review is to provide tangible proof of compliance and to either corroborate or find discrepancies in the information gathered through workers and management interviews. The types of documents to be reviewed include:
The closing meeting is a time to report to management any code violations found in the facility. Some companies use the closing meeting as a time to request management proposals to remediate problems or to work with management on a corrective action plan (CAP). Other companies use the closing meeting as a time to discuss issues with management, but develop formal CAPs after the audit is complete and the full team has reviewed the audit report.
The audit team prepares a full report of the audit.
The length of an audit depends on the size of the worksite. Most audits take one to two days, but they can take longer if the worksite and workforce are large and/or if significant violations are found that require time to investigate. Audits triggered by a grievance or whistleblower complaint may take longer to investigate, particularly if they require intervention by law enforcement authorities.