Non- New Details of Non-Compliance Root cause Preventative and Time Verific Agreed by Verification Status

Compliance or Corrective Actions scale ation Managemen Evidence and

Number Carri Metho t and Name Comments
ed d of
Over Responsible
Person:

PC 2. Freedom of New In accordance with ETI Base code 2.4, Lack of It is recommended that the 90 Follow Y Follow up audit is Open
Association Bangladesh Labor Law 2006 (Correction), awareness facility should form Days -up Mr. Monir required to solve
And Local Law Section 205 (6) and 207(2) Workers Participation Hossain – the issue.
In the case of an establishment where there is Committee as per law. Sr.
no trade union, representatives of the workers Manager-
on a participation Committee shall be elected in Compliance
the prescribed manner from amongst the & IMS
workers engaged in the establishment for which
the Participation Committee is constituted.

The proceedings of every meeting of the

participation committee shall be submitted to
the Director of Labour and the conciliator within
seven days of the date of the meeting.

It was noted through Workers Participation

Committee (WPC) formation records review,
employees and management (Sr. Manager-
Compliance & IMS) interview, the facility has
formed WPC by voice poll instead of election.
Moreover facility did not send the meeting
minutes after completion every meeting.
Participation 2.1.Freedom New It was noted from participation committee Lack of It is recommended that the 30 Deskto Y- Uploading photo Open
committee meeting of Association meeting register review and management monitoring participation committee Days p Mr. Nurul evidence to
minutes ETI Base interview that, facility did not acknowledge their meeting minutes should Haque- SEDEX showing
Code, point: participation committee meeting minutes from receive by labour director Assistant that participation
2.2 and the Director of Labour. Last meeting held on 05 as per legal requirement. General committee
Bangladesh August, 2015. Manager meeting minutes
Labour Act (HR Admin received by labour
2006, Section & CSR) director.
207 (2)
PC 1. Freedom of New It was noted through Participation Committee (PC) Lack of It is recommended that the 60 Follow Y Follow up audit Open
Association 2 formation records review, employees and awareness facility should form Days -up Mr. Faysal required to verify
and BLL-06, management (Manager – HR & Compliance) Participation Committee Islam – and solve the
Section: 205 interview, the facility has formed participation through election process Manager issue.
(6) committee members by selection process instead of as per local law. (HR &
election process. Compliance)
Building approval 3.2.Working New It was noted through building approval plan Lack of It is recommended that the 180 Deskto Y Uploading photo Open
plan condition are review and management interview that, the monitoring facility should have Days p Mr. Nurul evidence to
safe and building construction plan was not approved by building plan approved by Haque- SEDEX showing
 hygienic ETI concern authority. Note that the facility concern engineering Assistant that facility have
Base Code, management collected building plan approval department of the General building plan
point: 3.1 and from Chairman of Kanchpur Union Council at government authority. Manager approved by
Bangladesh 2nd October, 2012 as Factory type building. (HR Admin concern authority.
Building & CSR)
Construction
Act 1952,
section (3):
Building approval Health & New In accordance with ETI base code 3.1 and Our facility is It is recommended that Y Uploading photo Open
plan Safety ETI 3.1 Building construction Act 1952, Section 3(1) newly facility should have 90 Deskto Md. Shariful evidence to Sedex
& Notwithstanding anything contained in any constructed building construction Days p Islam showing for
Local Law other law for the time being in force, or in any and we are approval plan from (Sr. approved building
agreement, no person shall, without the approaching concerned authority. Manager- construction plan.
previous sanction of an Authorized Officer, to the Admin, HR
construct or re-construct or make addition or government &
alteration to any building, or excavate or re- authority in Compliance)
excavate any tank within, the area to which this this regards.
Act applies; and such sanction shall be subject
to such terms and conditions as the Authorized
Officer may think fit to impose.

It was noted that from management interview

(Sr. Manager-Admin, HR & Compliance) facility
did not have building approval plan.
Building approval Health & New In accordance with ETI base code 3.1 and Waiting for It is recommended that the 180 Desk Y Upload Open
plan taken as Safety ETI 3.1 Building construction Act 1952, Section 3A(1) approval facility should have Days Top Mr. documentation to
commercial & No owner or occupier of a building shall, from building construction Khairuzzam Sedex Approved
Local Law without obtaining previous permission from the government approval plan approved as an – building
Authorized Officer or the Committee, as the office a factory/industrial building. Assistant construction
case may be, use the building for the purpose Manager ( approval plan as a
other than that mentioned in the sanction. Finance) factory building.

It was noted through facility management

interview (Asst Manager) and building
construction approval plan review that facility
building construction approval plan was
approved as a commercial building instead of
factory/industrial building.
Note that facility applied to concern authority
dated on for approval as factory/industrial
building.
Building Approval Health & New In accordance with ETI base code 3.1 and Lack of It is recommended that the 90 Deskto Y Uploading photo open
plan not included Safety ETI 3.1 Building Construction Act-1952, Section:3(1) monitoring facility should take days p Mr. Nazrul evidence to
& Notwithstanding anything contained in any permission from local Islam - SEDEX to the
Local Law other law for the time being in force, or in any authority for all floors. Manager facility taken
agreement, no person shall, without the (Compliance permission from
previous sanction of an Authorized Officer, & HRD) local authority for
construct or re-construct or make addition or all floor.
alteration to any building, or excavate or re-
excavate any tank within, the area to which this
Act applies; and such sanction shall be subject
to such terms and conditions as the Authorized
 Officer may think fit to impose.

It was noted through facility visit that,

management interview & building approval plan
review that, Basement not including in building
approval plan of main production building.
Moreover child care room, doctor room &
accessories store located at another building
no-4 but facility not provided that building
approval plan, fire license & lay out plan for this
building.

Note that 9 storey building approval found from

ground floor to 9th floor.
Building approval Health & New In accordance with ETI Base Code 3.1 and Applied to It is recommended that the 180 Deskto Y Upload Open
plan from chairman Safety ETI 3.1 Building Construction Act 1952, Section:3(1) Rajuk and facility management shall days p Mr. Monir documentation to
& Notwithstanding anything contained in any waiting for obtain building approval Hossain – Sedex showing
Local Law other law for the time being in force, or in any approval plan from concern Sr. obtain building
agreement, no person shall, without the authority. Manager- approval plan from
previous sanction of an Authorized Officer, Compliance concern authority.
construct or re-construct or make addition or & IMS
alteration to any building, or excavate or re-
excavate any tank within, the area to which this
Act applies; and such sanction shall be subject
to such terms and conditions as the Authorized
Officer may think fit to impose.

It was noted through building construction

approval plan review and management
interview that the facility took building approval
plan from Yarpur Union Council Chairman on
02 July, 2008 instead of concerned authority.
However facility applied to the RAJUK
(Rajdhani Unnoyan Katripokkho) on 26
December 2013 for building approval.
Have no Machine Health & New In accordance with the ETI Base Code 3.1 and Lack of It is recommended that the 90 Deskto Y Upload Open
Layout Plan Safety ETI 3.1 Factory Rules, 1979, Section 3(1) awareness & facility shall be obtaining days p Mr. Monir documentation to
& monitoring machine lay out approval Hossain – Sedex showing
Local Law There shall not be any construction or plan from concern authority Sr. obtain machine
extension of any factory unless previous for all buildings. Manager- layout approval
permission in writing is obtained from the Chief Compliance plan from concern
Inspector for such construction or extension. & IMS authority.

It was noted through facility tour and machine

layout approval plan review, facility did not have
machine lay out approval plan for Building-3
(Central warehouse building) and Building-4
(Medical & substation building) from chief
inspector.
Mismatch in 5. New It was noted through facility tour and approved Due to It is recommended that 60 Deskto Y- Upload photo
machine layout Working machine layout plan review that, mismatch was construction there should have updated Days p Mr. Eftekhar evidence on
plan Conditions are found in between present floor layout plan with work going floor layout plan for 2nd Mahbub SEDEX showing
 Safe and approval floor plan. For example facility using on and all floor of building 1. Sunny – that facility took
Hygienic 3.1 2nd floor as finished goods warehouse, yarn, floor are General approval layout
and Factory grey and accessories warehouse but approved using Manager plan for of 2nd
Rules 1979, lay out plan shown as sewing section. temporarily floor of building 1
Section: 3(1) basis as per existing
floor setup.
Mismatch in Health & New In accordance with ETI Base Code 3.1 and The Lack of It is recommended that the 90 Deskto Y Upload Open
machine layout Safety ETI 3.1 Factory Rules, 1979, Section: 3(1) awareness & facility shall be take days p Mr. Monir documentation to
plan & monitoring machine lay out approval Hossain – Sedex showing
Local Law There shall not be any construction or plan from concern authority Sr. machine layout
extension of any factory unless previous as per existing position. Or Manager- approval plan as
permission in writing is obtained from the Chief floor shall be organized as Compliance per existing
Inspector for such construction or extension. per approval plan. & IMS position.

It was noted through facility tour and machine

layout approval plan review, mismatch found in
present arrangement in between machine
layout approval plan. For example 4th floor
shows as sewing to finishing where as
presently finished goods section located. 5th
floor shows as sewing to finishing where as
presently dining hall and canteen located.
Not included in fire Health & New In accordance with ETI Base Code 3.1 and Fire Waiting for We already apply to the 30 Deskto Mr. Mahmud Upload Open
license Safety ETI 3.1 prevention and Extinguishment Act 2003, approval fire service and civil days p Reza – GM documentation to
& section: 4(1) defense authority to Compliance Sedex showing of
Local Law Any person if used any place or building as include that area into the include all area in
warehouse or workshop must be took license fire license. the fire license.
from Director of General.

It was noted through fire license review and

management interview, facility did not include
4th floor dining hall (4500 square feet) into the
fire license. However facility applied to the fire
service and civil defence authority to include
into the fire licence.
Not included in fire 3.4.Working New It was noted through fire license review, building Lack of It is recommended that the 60 Deskto Y Uploading photo Open
license condition are approval plan review and management interview monitoring facility should include all Days p Mr. Nurul evidence to
safe and that, the security single storied building (where the mentioned area in Haque- SEDEX showing
hygienic ETI security office, RMS room, visitor room and child facility fire license. Assistant that facility have
Base Code, care room located ) and Shed 1 used as wastage General included
point: 3.1 and storage and poly recycling were not included in the Manager mentioned area in
Fire facility fire license. (HR Admin facility fire license.
Prevention & CSR)
and
Extinguishing
Act 2003,
Section-4(1)
Have no fire license Health & New In accordance with ETI Base Code 3.1 and Fire Waiting for We already apply to the 30 Deskto Mr. Mahmud Uploaded Open
Safety ETI 3.1 prevention and Extinguishment Act 2003, approval fire service and civil days p Reza – GM documentation to
& section: 4(1) defense authority. Compliance Sedex showing
Local Law Any person if used any place or building as obtain fire license
warehouse or workshop must be took license for the facility.
 from Director of General.

It was noted through fire license review and

management interview, facility have no fire
license. However facility applied to the fire
service and civil defense authority to include
into the fire license.
Have no Health & New In accordance with ETI Base Code 3.1 and Lack of We already applied 30 Deskto Mr. Mahmud Uploaded Open
Environment Safety ETI 3.1 Bangladesh Environment Conversation Act, awareness days p Reza – GM documentation to
certificate & 1995, section:12 Compliance Sedex showing
Local Law obtains
No industrial unit or project shall be established Environment
or undertaken without obtaining, in the manner Certificate for the
prescribed by rules, an Environmental facility.
Clearance Certificate from the Director General.

It was noted from management representative

(Sr. Manager- Admin & HR) interview, facility
have no environment clearance certificate.
Environment Health & New In accordance with ETI Base Code 3.1 and Waiting for 30 Deskto Mr. Mahmud Uploaded Open
license expired Safety ETI 3.1 Bangladesh Environment Conversation Rules, approval days p Reza – GM documentation to
& 1997, section:8 (2) Compliance Sedex showing
Local Law obtains valid
Each Environmental Clearance Certificate shall Environment
have to be renewed at least thirty days before Certificate for the
expiry of its validity period. facility.

It was noted from management representative

Sr. Manager (Admin & HR) interview &
environment clearance certificate review it was
noted that facility environment clearance
certificate expired on 08 March, 2013. Note that
facility management applied on 13 February,
2013 & further 27 February 2014 but yet not
received.
Acid license Health & New In accordance with Acid Control Rules 2004, It is recommended that the
Safety ETI 3.1 Section: 03 facility should take a valid
& For any import, production, store, transport, acid license.
Local Law sale and use of acid one should obtain valid
license.

It was noted through acid license review,

license for the permission of acid use of the
facility had expired from 01 July, 2016.

Insufficient Fire Health & New In accordance with ETI base code 3.1 & Facility Lack of It is recommended that the 60 Desk Y The facility will open
equipment Safety ETI 3.1 fire license monitoring. facility management days top Md.Bahadur provide sufficient
& It was noted through documents( fire license) Rising Setup provide sufficient fire Alam fire equipments.
Local Law review and facility visit it was noted that is ongoing equipments at the (HR, admin
a) The facility has 157 instead of 206 ABC type process. mentioned area. and
fire extinguishers. Compliance
b) No hose pipe connection was found at dining Manager)
 hall, child care room and one out of two hose
pipe was found out of order at the ground floor
in building one.
c) No Smoke detector was installed at wastage
area.
d) No hose reel with riser in the both side of the
floor.
Insufficient Fire Health & New In accordance with ETI Base Code, point-3.1 Lack of It is recommended that 30 Follow Y Follow up audit open
equipment Safety ETI 3.1 and the Facility Fire License monitoring facility should install fire days up Mr. Nazrul required to verify
& resistance door, fire Islam - the issue.
Local Law It was noted during facility tour, fire license fighting platform & fire Manager
review and management interview that fighting stair. Fire training (Compliance
should be cover 25% for & HRD)
a) Facility has no fire resistant door, fire fighting dyeing, generator room,
platform & fire fighting stair for production and yarn store.
building (main building).

b) Facility has trained fire fighter from fire

service & civil defense 18 instead of 60 for
Shed-7, 11, 14, 12 (Dyeing section, Yarn store,
Generator & boiler room), which is mentioned
this fire license.
Fire hose reel 3. New It was noted that facility visit and management Lack of It is recommended that 30 Deskto Yes- Upload photo Open
coverage 3: Working interview it was noted that, all area of sewing awareness facility should install fire days p Mr. Abu evidence to
Conditions are floor does not covered by fire hose reel. Total and hose reel connection at Hayat Md. SEDEX showing
Safe and scenario of the facility given below: monitoring north side of the facility Jaman – that facility install
Hygienic 3.1 In sewing section has 01 fire hose reel building-1 which is covered Asst. fire hose reel
connection (south side of the building) out of 04 whole area. Manager connection at
side and 01 hose reel connection has at (HR & north side which is
finishing section (west side) which is also Compliance) covered whole
covered some area. But north side of the facility area.
building has no fire hose reel connection.
Fire resistance 2. New It was noted through fire license review, Construction It is recommended that the 60 Deskto Yes- Upload photo Open
door, smoke 3: Working management interview and facility visit that works. facility should install days p Mr. Abu evidence to
detector and fire Conditions are a) Facility did not install fire resistant door a) Fire resistant door Hayat Md. SEDEX showing
hydrant Safe and throughout the facility. throughout the facility. Jaman – facility installed
Hygienic 3.1 b) Facility did not install wet riser with hose reel b) Riser with hose reel Asst. a) Fire resistant
and LL throughout the facility. throughout the facility. Manager door throughout
c) Facility did not install auto type smoke (HR & the facility.
detection system with control panel. Compliance) b) Riser with hose
reel throughout
the facility.
Smoke detector 1. New It was noted through during facility visit, fire All fire It is recommended that 60 Deskto Y Uploading photo Open
and fire hydrant Working license review and management interview that, equipment facility should install hose days p Mr. Lee evidence to
Conditions are coming from riser with hose reel and Jong Soe – SEDEX that
Safe and a) Facility did not install wet riser connected abroad and auto type fire detector with Director facility install hose
Hygienic 3.1 with hose reel of both side of the floor. delay alarm system. (Business) riser with hose
and fire process of reel and auto type
license b) Facility did not install auto type from fire detector.
interconnected fire detector with alarm system. Alliance.
Note that facility had 352 manual smoke
detectors.
Fire alarm & PA Health & New In accordance with ETI base code 3.1 and Lack of It is recommended that the 60 Deskto Y Uploading photo Open
system Safety ETI 3.1 Bangladesh Labour Law-2006, Section: 62 (5) monitoring facility management days p Mr. Monir evidence in
& In every establishment every window, door, or provide fire alarm and PA Hossain – SEDEX showing
Local Law other exit affording means of escape in case of System at the mentioned Sr. install fire alarm
fire to every person employed therein. area. Manager- and PA system in
Compliance the mentioned
It was noted through facility visit, & IMS areas.
a) Fire alarm was found missing in finished
goods store located at 1st floor of Building-3
(Prefabricated Building).
b) PA (public Address System) was not found in
finished goods store located at 1st floor of
Building-3 and 1st floor of Medical and
substation building (Building-4).
PA system missing 2. New It was noted through facility visit and management Lack of It is recommended that the 30 Deskto Y- Uploading photo
Working interview (Sr. Executive – HR & Compliance) that, monitoring facility management shall Days p Mr. Eftekhar evidence in SEDEX
Conditions are a) PA (Public Address) system was not found in install PA System at the Mahbub showing that facility
Safe and finished good, yarn, grey and accessories mentioned area. Sunny – installed PA system
Hygienic 3.1 warehouse located at ground floor and 2nd floor of General in the mentioned
and building-1. Note that on that floor approximately 10 Manager areas.
Bangladesh employees working and during emergency situation
Labour Law
particular employees not hear any announcement.
2006, Section:
62 (5)
PA system 6. New It was noted through facility visit and management Lack of It is recommended that the 60 Deskto Y Uploading photo Open
Working interview that, PA (Public Address) system was not monitoring facility management shall days p Mr. Faysal evidence in SEDEX
Conditions are found install PA System at the Islam – showing that facility
Safe and 1) in ground to 9th floor of annex building part. mentioned area which is Manager install PA system in
Hygienic 3.1 2) in ground floor quarantine area of main building. covered whole area. (HR & the mentioned
and BLL 2006, Compliance) areas.
Section: 62 (5)
Exit Sign Health & New In accordance with ETI Base code 3.1 and Already It is recommended that the 30 Deskto Y Uploading photo Open
Safety ETI 3.1 Bangladesh Labour Law 2006, Section-62 (4): import facility should install exit Days p Mr. Monir evidence to Sedex
& industrial sign where missing and Hossain – showing installs
Local Law In every establishment every window, or other grade provide functional exit sign Sr. exit sign and
exit affording means of escape in case of fire, emergency at mentioned area. Manager- change non
other than the means of exit in ordinary use, light and Compliance functional exit
shall be distinctively marked in Bangla and in waiting in the & IMS sign.
red letters of adequate size or by some other port.
effective and clearly understood sign.

It was noted through from facility visit,

 01 out of 01 exit sign found missing in
thread cutting room located at ground floor
of building-2.
 02 out of 02 exit sign found missing in
finished goods store located at 1st floor of
building-3.
 01 out of 02 exit sign found missing in
sample section located at 1st floor of
building-1.
Moreover 02 out of 02 exit sign found non
 functional in central fabric store located at
ground floor of building-3.
Exit Sign & 1. New It was noted through facility visit, Due to It is recommended that 30 Deskto Y- Uploaded photo
emergency light Working a) 03 out of 04 exit sign found missing in construction facility shall install fire exit Days p Mr. Eftekhar evidence to SEDEX
missing Conditions are finished good, yarn, grey and accessories work and fire sign and emergency light Mahbub showing that facility
Safe and warehouse located at 2nd floor of building-1. door with battery backup on Sunny – has installed exit
Hygienic 3.1 b) 02 out of 04 exit sign found missing in cutting installation those particular exits and General sign and emergency
and section and fabric warehouse located at 1st floor work going stair for easy Manager light with battery
Bangladesh of building-1. on. identification/evacuation back up on that
Labour Law c) Emergency light with battery backup was during night or avoid
mentioned exit
2006, Section: found missing 04 out of 04 stairs in 2nd floor, 02 electricity problem.
point and stair.
62 (4) out of 04 stairs in 1st floor and ground floor of
building-1.
Based on employee interview and overtime
record review that, in review period facility
worked daily 10 to 24 hours. That means facility
shift end times sometime at night. So
emergency light and exit sign required for easy
evacuation during night and avoid electricity
problem.
Note that, facility construction work and fire
door installation work going on.
One exit / No Health & New In accordance with ETI Base code 3.1 and The Lack of It is recommended that 30 Deskto Y Uploading photo Open
secondary exit Safety ETI 3.1 Factory Rules 1979, Section-51 (1): monitoring facility should make Days p Mr. Monir evidence in
& Each room of a factory building shall be another exit for this room. Hossain – SEDEX showing
Local Law provided with not less than two exits for use in Sr. facility make
case of fire, so positioned that each person will Manager- another exit for
have a reasonably free and unobstructed Compliance this room
passage from his work place to an exit. & IMS

It was noted through from facility visit, one exit

door was found in thread cutting room instead
of two exit door located at ground floor of
Building-2. Note that during facility tour 17
employees found working in that room.
Partially block Health & New In accordance with ETI Base Code3.1 & We did not It is recommended that the Y Sedex uploading Open
Safety ETI Bangladesh plan factory should make evidence showing
3.1 & 30 Deskto Md. Shariful
Labor Law 2006, Section-72 previously obstacle free aisle for days p Islam for obstacle free
Local Law but we will employee’s safety. aisle on
do in short (Sr. mentioned floor.
It was noted that, from facility visit aisles was time. Manager-
found partially blocked by pillars in some areas Admin, HR
of the facility which are mentioned below &
04 aisles located at ground floor of building #1, Compliance)
02 aisles located at 3rd floor of building #1
02 aisles located at 4th floor of building #1.
Aisles mark 7. New It was noted through facility visit that aisles mark Lack of It is recommended that the 60 Deskto Y Uploading photo Open
missing Working was not found monitoring facility management shall days p Mr. Faysal evidence to
Conditions are 1) in storage area located at 6th floor of annex mark all passageways for Islam – SEDEX showing
Safe and building. easy evacuation. Manager that facility marked
Hygienic 3.1 (HR & all passageways
 and BLL 2006, 2) in printing section located at 7th floor of annex Compliance) at mentioned area.
Section: 72 (2) building.
3) in printing section located at 8th floor of main
building.
Inward door Health & New In accordance with The ETI Base Code, point Y
Safety ETI Lack of It is recommended that 60 Deskto Sedex open
3.1 and Bangladesh Labor Law 2006 Section the facility management days p Md. Shariful uploading
3.1 & 62 (3) planning
should make all doors Islam evidence
Local Law
outward opening (Sr. showing for all
It was noted that, from facility visit Inward Manager- the doors
opening door was found such in some area. Admin, HR outward is
& opening.
-04 out of 04 doors at Embroidery section Compliance)
located at 1st floor of Building #2,
-02 out of 03 doors at Chemical store located at
2nd floor of Building #1.
Fire drill 3. Working New In accordance with ETI Base Code 3.1 & Lack of It is recommended that the 60 Deskto Y Uploading photo Open
condition are Bangladesh Gazette SRO-109, section kha-C, knowledge facility should perform fire days p Mr. Rajeev evidence to Sedex
safe and published on 25 May 1999. drill every month Das Kalathil showing
hygienic General evidenced for
It was noted from fire drill record review, facility Manager every month fire
conducted fire drill every six month later. Last drill.
fire drill conducted on 14 November, 2013 &
before that have been fire drill performed on 13
June, 2013.
Fire Trained person 3. Working New In accordance with ETI Base Code 3.1 & Fire Lack of It is recommended that the 60 Deskto Y Uploading photo Open
condition are license. knowledge facility should given days p Mr. Rajeev evidence to Sedex
safe and training from fire service & Das Kalathil showing fire
hygienic It was noted from fire license review, facility did civil defense. General training from fire
not trained 6% of total employee from fire Manager service & civil
service & civil defense about fire. Facility has defense.
been applied to fire service on 03 July, 2013.
Moreover facility has been arranged training
program by station officer of DEPZ.
Evacuation plan Health and New In accordance with ETI base code 3.1 and Lack of It is recommended that the 60 Desk Y Upload Open
missing Safety Government Gazette Circular monitoring facility management should days top Md.Bahadur documentation to
No.3 No:40.05.31.0.0.01.2011 (Part-9)/393 post evacuation plan and Alam Sedex showing
Published on 01.01.12, Condition:6 mark passageway for safe (HR, admin updated boiler
Evacuation plan shall be keep in every floor of movement of the and license.
every factory employees working in that Compliance
section. Manager)
It was noted through facility visit that evacuation
plan found missing in finishing section located
at 2nd floor and jacquard Section at 1st floor in
building 01.
Moreover evacuation plan found mismatch of
1st floor from existing floor position. For
example in 1st floor facility uses sewing section
but evacuation plan have finishing section.
Aisles Mark Health and New In accordance with ETI base code 3.1 and Lack of It is recommended that the 30 Deskto Y Uploading photo Open
Missing Safety Bangladesh Labor Law 2006, Section 72(b) monitoring facility management shall days p Mr. Monir evidence to Sedex
No.3 and there shall, so far as is reasonably practicable, mark all passageways for Hossain – showing marking
 Local Law be provided and maintained safe means of evacuation. Sr. passageways at
access to every place at which any person is, at Manager- mentioned area.
any time, required to work; Compliance
& IMS
It was noted through facility visit that aisles
mark was not found in fabric warehouse located
at ground floor of Building-3 and thread cutter
room located at ground floor of Building-2.
One exit at roof top Health and New In accordance with ETI Base Code 3.1 Lack of It is recommended that the 60 Follow Y Follow up audit Open
Safety construction facility management should days up Mr. Md required to verify
No.3 and It was noted during facility visit, facility 5 storied problem provide another stair for Abdullah Al the issue.
Local Law building where have 2 factories under same emergency purpose. Saki - Asst.
management but facility used rooftop combine. Manager
During visit, only one exit found for going up at (HR &
rooftop west side stair. In case of emergency Compliance)
every employee stay in rooftop but if fire will be
happened in east stair facility employee do not
used another stair for stay in roof top. Note that
facility has been start for install a new stair.
Factory Category Health and New In accordance with ETI Base Code, point-3.1 Lack of It is recommended that 30 Deskto Y Uploading photo Open
Safety and The Factory Rules 1979, Section-5 (1) awareness facility should change the days p Mr. Nazrul evidence to
No.3 and category in the factory Islam - SEDEX to show
Local Law It was noted through factory license review, license from local authority Manager the facility had an
facility did not change the category of the as per total manpower. (Compliance update category
factory. The factory license showed the factory & HRD) for factory license.
is in “I” category instead of “J” though 2500
employees are working at the time of audit.
Have no boiler Health and New In accordance with ETI Base Code 3.1 and The Delay apply It is recommended that the 30 Deskto Y Upload Open
license Safety Boiler Act 1923, Section 7: facility management will days p Mr. Monir documentation to
No.3 and The owner of any boiler which is not registered obtain the boiler license Hossain – Sedex showing for
Local Law under the provisions of this act may apply to the from concern authority. Sr. obtain boiler
inspector to have the boiler registered. Manager- license.
Compliance
It was noted through documents review and & IMS
management interview that, facility did not have
01 out of 07 boiler licenses. Note that facility
applied to concern authority dated on 23 June,
2014.
Boiler license Health and New In accordance with ETI Base Code, point-3.1 Lack of It is recommended that the 90 Desk Y Upload Open
expired Safety and The Boiler Act 1923, Section 8: monitoring facility management will days top Md.Bahadur documentation to
No.3 and A certificate authorizing the use of a boiler shall renew the boiler license Alam Sedex showing
Local Law cease to be in force- and group insurance on (HR, admin updated boiler
(a) on the expiry of the period for which it was time. and license.
granted Compliance
Manager)
It was noted through documents review that the
boiler license of the facility had expired from
February 26, 2012. Note that the facility
management applied for the registration and
deposited the required amount of money to the
concerned authority but did not receive yet.
Boiler license 2. New It was noted through documents (boiler license) Lack of It is recommended that the 90 Deskto Y Uploaded boiler Open
expired Working review that, 01 out of 03 boilers license of the communicatio facility management will days p Mr. Faysal license renew copy
Conditions are facility had expired from February 23, 2015. That n and delay renew the boiler license Islam – to SEDEX showing
Safe and boiler license registration license no: BA:BO 5285. process from before expiry. Manager that facility have
Hygienic 3.1 Note that the facility management applied for the government (HR & updated boiler
and The Boiler registration and deposited the required amount of office. Compliance) license.
Act 1923, money to the concerned authority dated on 08
Section:8
February 2015 but did not receive yet. However
during audit the said boiler found inactive.
Boiler operator Health and New In accordance with ETI Base Code, point-3.1 Lack of It is recommended that the 60 Desk Y Upload Open
certificate missing Safety and The Boiler Act 1923, Section 6: monitoring boiler operator should have days top Md.Bahadur documentation to
No.3 and Save as otherwise expressly provided in this certificate of competency. Alam Sedex showing to
Local Law Act, no owner of a boiler shall use the boiler or (HR, admin get competency
permit it to be used —where the Govt. has and certificate for
made rules requiring that boilers shall be in Compliance boiler operator.
charge of persons holding certificates of Manager)
competency, unless the boiler is in charge of a
person holding the certificate required by such
rules.

It was noted through employee personal file

review, management and boiler operator
interview, facility have no certified boiler
operator certificate of competency.

Electrician Health and New In accordance with ETI Base Code 3.1 and The
certificate missing Safety Electricity Ordinance 1937, Section: 48(1)
No.3 and (1) No electrical installations work, including
Local Law additions, alterations, repairs, and adjustments
to existing installations, except such
replacement of lamps, fans, fuses, switches
and other component parts of the installation as
in no way alter its capacity or character, shall
be carried out upon the premises or on behalf
of any consumer or owner for the purposes of
the supply of energy to such consumer or
owner except by an electrical contractor
licensed by the Provincial Government in this
behalf and under the direct supervision of a
person holding a certificate of competency
issued by the Provincial Government:

It was noted through management interview

and document review, facility have no certified
electrician. Note that facility has total 13
designated electrician.
Electricity 3. Working New In accordance with ETI Base code 3.1 and In Lack of It is recommended that the 30 Deskto Y Uploading photo Open
Connection in condition are accordance with the circular published from the awareness facility management should Days p Mr. Nazrul evidence to Sedex
Warehouse safe and fire license and Civil Defence Authority remove the electricity Islam - showing remove
hygienic published on 22 January 2001: connection from the fabric Manager electricity
Electric connection shall be removed from wear house & finished (Compliance connection from
 warehouse. goods carton store area as & HRD) fabric wear house
per law. & finished goods
It was noted that facility management has not carton store area.
removed the electricity connection from fabric
wear house area located at ground floor &
finished goods carton store area located at 1st
floor.
Electricity 5. New It was noted through facility visit that, the facility Lack of It is recommended that the 30 Deskto Y Uploading photo Open
Connection in Working management did not remove live electric awareness facility management shall Days p Mr. Faysal evidence to
Warehouse Conditions are connection from empty carton storage area located remove the live electric Islam – SEDEX showing
Safe and at ground floor of annex building and finished connection from empty Manager remove electricity
Hygienic 3.1 goods store located at 2nd floor of main building. carton storage area and (HR & connection from
and LL finished goods store as per Compliance) empty carton
law. storage area and
finished goods
store.
Wooden Box 3. Working New In accordance with ETI Base code 3.1 and The Lack of It is recommended that 30 Deskto Y Uploading photo Open
condition are Factories Rules 1979, Chapter IV, Safety, monitoring facility should remove days p Mr. Nazrul evidence to
safe and Section 41: wooden box from electric Islam - SEDEX to the
hygienic In every factory all electric supply lines and wire. Manager facility remove
apparatus shall be of proper size and (Compliance wooden box from
sufficient strength and shall be constructed, & HRD) electric
situated, protected, worked and maintained in connection.
such a manner as to cause no risk of bodily
injury

It was noted that from facility visit that, all iron

machine, sewing machine at 1st & 2nd floor
electric distribution board covered by wooden
box. Moreover wooden electric box found in
accessories store room.
Open or naked wire Health New In accordance with ETI Base code 3.1 and The Lack of It is recommended that
30 Deskto Y Sedex uploading Open
and Factories Rules 1979, Chapter IV, Safety, monitoring facility should keep all the
Safety. Section 41: electrical equipments in day p evidence
s Md. Shariful showing for
ETI 3.1 & In every factory all electric supply lines and safe manner. Islam removed those
Local Law apparatus shall be of proper size and (Sr.
sufficient strength and shall be constructed, loose electric
Manager- wires from the
situated, protected, worked and maintained in Admin, HR mentioned area.
such a manner as to cause no risk of bodily &
injury Complianc
e)
It was noted that from facility tour, open
electrical apparatus was found at maintenance
room (Shed 4)
Ebonite board 3. Working New In accordance with ETI Base Code, point-3.1 Lack of It is recommended that 30 Deskto Y Uploading photo open
missing condition are and Factory rules 1979, Section-41 monitoring facility should remove days p Mr. Rajeev evidence to
safe and In every factory all electric supply lines and wooden box from electric Das Kalathil SEDEX to the
hygienic apparatus shall be of proper size and wire. General facility remove
sufficient strength and shall be constructed, Manager wooden box from
situated, protected, worked and maintained in electric
such a manner as to cause no risk of bodily connection.
injury
 It was noted during facility tour, electric
distribution board is found in cutting section
without inside protection (ebonite board).
Moreover 02 electric distribution board covered
by wooden box which is located at west side
ground floor.
Tiles broken 4. Safety and New It was noted through facility visit that, floor surfaces Lack of It is recommended that the 30 Deskto Y Upload evidence Open
Hygienic (tiles) were found broken in cutting section (located awareness facility management should Days p Mr. Bibhash showing facility
Conditions; at ground floor) and sewing section (located at 1st repair floor surfaces in the Kanti management has
ETI Base floor) which might cause injury to the employees in mentioned areas. Biswas – repaired the floor
Code 3.1 the mentioned sections who are working in bare Compliance surfaces in the
foot. Manager mentioned areas.
Slippery surface 7. New It was noted through facility visit that, 04 out of Due to It is recommended that 60 Follow Y- Follow up audit
Working 04 stairs were found slippery (water on tiles) construction facility should take Days up Mr. Eftekhar required for further
Conditions are due to continuous construction work going on. work going effective measure to avoid Mahbub verification.
Safe and For this reason may cause any bodily injury or on. any bodily injury or fall Sunny –
Hygienic 3.1 fall protection during evacuation. protection in all stairs. General
Manager

PPE training 3. New It was noted through facility visit, employee & Lack of record It is recommended that the 30 Desk Y Uploading photo Open
Working management interview, facility did not shown any keeping facility should keep training days top Mr. Lee evidence to
Conditions are training record regarding PPE & chemical handling system record regarding PPE & safe Jong Soe – SEDEX to the
Safe and procedure who’s are uses chemical (833 spot lifter) chemical handling whose are Director facility provides
Hygienic 3.2 in spot removing room. As per facility management using chemical in spot (Business) and keep training
interview, they provided training but did not removing room. document on PPE
maintain training records. & chemical
handling.
Chemical handling 5.3: Working New It was noted through facility visit, management Lack of It is recommended that 60 Deskto Yes Uploading photo Open
training Conditions are and employee interview, facility used acetone awareness facility should provide days p Mr. Golam evidence and
Safe and chemical for spot removing purpose and 01 training to concern Kader training record to
Hygienic 3.2 employee where found working in spot employee regarding Siddique – Sedex that facility
removing room at 1st floor finishing section. chemical safety and Manager provide chemical
That employee does not know the chemical handling procedure. (Admin, HR handling training
handling procedure and no training record was & to concern
found regarding chemical safety and handling Compliance) employee.
procedure.
Steam iron line 5. New It was noted through facility visit that the Lack of It is recommended that the 30 Desk Y Uploading photo Open
Working installed steam drums of steam line on monitoring facility management should days top Mr. Lee evidence to
Conditions are production floor were in unsafe condition. Note ensure safety for the Jong Soe – SEDEX that
Safe and that the said steam drums were installed on particulars. Director facility ensure
Hygienic 3.1 aisles and employees working areas, if any (Business) safety for the
leakage occurred which may causes of injury. particulars.
Drinking water 7. Safety and New It was noted through facility drinking water test Lack of It is recommended that the 30 Deskto Y Upload evidence Open
parameter Hygienic report review that, facility did not include the awareness facility management should Days p Mr. Bibhash showing facility
Conditions; parameter "Faecal Coliform" in their drinking water test "Faecal Coliform" in their Kanti management
ETI Base test report. Note that as per Bangladesh Standard drinking water. Biswas – included "Faecal
Code 3.1 and for Drinking Water (ECR 97) and WHO standard the Compliance Coliform"
Local Law acceptable number of Faecal Coliform is zero. Manager parameter in their
drinking water test
 report.
Drinking water 7. Safety and It was noted through drinking water test report It is recommended that the
parameter high Hygienic review (Date of test report- March 31, 2015) that facility management should
Conditions; the tested parameters of "Total Coliforms" and ensure all required
ETI Base "Feacal Coliforms" is exceeded the legal limits. As parameters of the drinking
Code 3.1 and per test report the parameter of "Total Coliforms" is water are compliant as per
Environment found 84 instead of 0 and the tested parameter of legal limits.
Conservation "Feacal Coliforms" is found 9 instead of 0. Note that
Rules 1997,
the test was done by icddr,b and the drinking water
Schedule 03
test report is common for all audited facilities.
(B)
MSDS , Labeling & 3. Working New In accordance with ETI Base code 3.1 and Lacking of It is recommended that 60 Y Uploading photo Open
Secondary condition are Bangladesh Labour Law 2006, Section: 79 (d monitoring facility should provide Da Deskt Mr. Nazrul evidence to Sedex
containment safe and & e) MSDS, Labeling and ys op Islam - showing arrange
missing hygienic (d) providing for the protection of all persons secondary containment to Manager secondary
employed in the operation or in the vicinity of required area. (Compliance containment,
the places where it is carried on and the use of & HRD) MSDS and
any specified materials or processes in labelling required
connection with the operation; and area.
(e) notice specifying use and precautions
regarding use of any corrosive chemicals.

It was noted that from facility visit that,

 Secondary containment, MSDS and
labeling was not found at maintenance
room located at 8th floor & Generator room
(Shed-12).
 MSDS and labeling was not found in spot
removing room at 2nd floor & knitting
section at ground floor where kept machine
oil, Mobil, Diesel & 833 chemical.

PPE not use 3. Working New In accordance with ETI base code 3.1 and Lack of It is recommended that the 30 Deskto Y Uploading photo Open
condition are Bangladesh labour law 2013 (Correction), monitoring facility should provide the days p Mr. Monir evidence to Sedex
safe and Section 75 and 78(Kha) PPE to the employees & Hossain – showing provide
hygienic and The Government may, in respect of any more training needed to Sr. PPE to all
Local Law manufacturing process carried on in any use this machine safe Manager- employee and use
establishment, by rules, require that effective guard properly. Compliance eye guard properly
screens of suitable goggles shall be provided & IMS while working.
for the protection of persons employed on, or in
the immediate vicinity of a process which
involves-
(a) risk of injury to the eyes from particles or
fragments thrown off in the course of the
process,

The workers concerned shall be held

responsible if they do not use the safety
equipments after those are being supplied to
the workers.

It was noted through facility visit that,

  30% eye guard of over lock machine, flat
lock machine, bar tack machine found
displace in sewing section.
 20% over lock machine operator and
cutter man not using face mask while
working.
 03 out of 03 spot removing operator not
using face mask and hand gloves located
at 4th floor of Building-2.
Eye wash station 9. New It was noted through facility visit that, eye wash Lack of It is recommended that the 30 Deskto Y Uploading photo Open
nonfunctional Working station was found non-functional in spot removing monitoring facility management shall days p Mr. Faysal evidence to
Conditions are room located at 2nd floor of main building. Note provide or installed Islam – SEDEX showing
Safe and that in spot removing room 4 employees were functional eye wash station in Manager that facility
Hygienic 3.1 working whose are using 833 spot lifter. spot removing room for (HR & installed or
and BLL 2006, employee safety. Compliance) provided
Section: 79 (d) functional eye
wash station in
spot removing
room.
Belt cover / without 3. Working New In accordance with ETI base code 3.1 and Lack of It is recommended that the 30 Follow Y Follow up audit Open
fencing machine condition are Bangladesh labor law 2006, section-63 monitoring facility should provide PPE days up Mr. Nazrul required to verify
safe and In every establishment the following shall be to the employees and more Islam - the issue.
hygienic securely fenced by training needed to use this Manager
the safeguards of substantial construction PPE and operating (Compliance
which shall be kept in position while the part of machine. & HRD)
machinery required to be fenced are in mention
or in use, namely-

It was noted through facility visit that,

 In ETP plant (Shed-14) filter section have 01
compressor machine found without fencing.
 In Generator room (Shed-12) generator
wheel belt found without fencing.
Note that, facility used generator, ETP
combined.
Have no generator 3. Working New In accordance with Bangladesh Energy Applied and It is recommended that the 30 Deskto Y Uploading photo Open
waiver certificate condition are Regularity commission Act 2003, Section 27 waiting for facility shall be obtaining days p Mr. Monir evidence to Sedex
safe and and ETI Base Code 3.1 certificate waiver certificate for use Hossain – showing for obtain
hygienic and generator. Sr. generator waiver.
Local Law Manager-
No person shall engage himself in the following Compliance
business unless he is empowered by a licence & IMS
or exempted from having it under this Act or
any other Act, such as:-
(a) power generation;
(b) energy transmission;
(c) energy distribution and marketing;
(d) energy supply; and
(e) energy storage.
 It was noted through documents review and
facility visit, that the facility did not have
generator installation permission waiver from
concern authority. Facility have 05 generators,
capacity was 1285 KVA. Note that facility
applied to Bangladesh Energy Regulatory
Commission dated on 17 April, 2014.
Generator waiver 1. Working New In accordance with ETI Base Code, point-3.1 and Unaware It is recommended that 90 Deskto Y Upload photo Open
certificate expired condition are Bangladesh Energy Regularity commission Act 2003, about the facility management should days p Mr. Md. evidence to Sedex
safe and Section 29 issue arrange generator license Noor Nabi showing facility
hygienic - from concern authority. Patwary- got generator
ETI 3.1 and No person shall engage himself in the following Deputy licence from
Local law business unless he is empowered by a licence or General concern authority.
exempted from having it under this Act or any other Manager
(Factory)
Act, such as:-
(a) power generation;
(b) energy transmission;
(c) energy distribution and marketing;
(d) energy supply; and
(e) energy storage.

It was noted through from facility visit and

document review the facility has two generators
(Brand name: maxenergy model no: John Deere
RE522852, capacity 407 KVA and another generator
Brand name: CATER PILLAR model no: C-18,
capacity 635 KVA) were in use located at shed but
facility not get generator license from concern
authority.
Note that facility already applied to concern
authority dated on 30 July, 2013.
Generator waiver 3. New It was noted through documents review, facility Lack of It is recommended that the 90 Deskto Y Upload update Open
certificate expired Working visit and management interview that, generator communicati facility shall be obtaining days p Mr. Faysal generator waiver
Conditions are waiver certificate of the facility expired from July on with update waiver certificate for Islam – certificate photo to
Safe and 02, 2011. Facility have 02 generators (Diesel concern use generator. Manager SEDEX showing for
Hygienic 3.1 and Gas), capacity was 1064 KW. authority (HR & verify that facility
and BERC Act Compliance) get or obtain
2003, generator waiver
Section:29
certificate.
Dining missing Health New In accordance with ETI Base Code 3.1 and Lack of It is recommended that the 60 Deskto Y
and Bangladesh Labour Law 2006, Section:93(1) awareness facility should have a dining days p
Safety. Md. Shariful Sedex uploading Open
In every establishment wherein more than fifty for the employees. Islam evidence showing
ETI 3.1 & workers are ordinarily employed, adequate and
Local Law (Sr. for dining is
suitable shelters or rest rooms, and a suitable available in the
lunch room, with provision for drinking water, Manager-
Admin, HR facility.
where workers can eat meals brought by them,
shall be provided and maintained for the use of &
the workers. Compliance)
It was noted that from facility visit, no dining was
 found in the facility premises.
Dining Capacity 3 New In accordance with ETI Base Code, point-3.1 Lack of It is recommended that the 30 Deskto Y Uploading photo Open
Working and the Factories Rules 1979, Section-58 (1) monitoring facility should increase the Days p Mr. Rajeev evidence in
condition are seating capacity of the Das Kalathil SEDEX showing
safe and The dining hall shall accommodate at least 30 dining hall. General facility increases
hygienic percent of the workers working at a time Manager seating capacity.
It was noted facility visit & management
interview, facility had a dining hall which is
located at first floor where 30% employees
could not take meal at a time, i.e. facility had
the seating capacity of 140 instead of 207.
Canteen Health New In accordance with Bangladesh labour Law As our facility It is recommended that the
and 60 De Y Sedex open
2006, Section 92 (1) building is facility should have a da skt uploading
Safety. In every establishment wherein more than one newly canteen for the employees. Md. Shariful
ETI 3.1 & ys op evidence
hundred workers are ordinarily employed, there constructed Islam showing for
Local Law shall be provided adequate number of canteens we are (Sr. canteen is
for the use of the workers. constructing Manager- available in
dining also. Admin, HR & the facility
Compliance)
It was noted that from Facility visit, management
and employees interview, there is no canteen in
the facility where light food will be served for the
employees.
Governor for child Health New In accordance with ETI Base Code 3.1, Lack of It is recommended that the 60 Deskto Y Uploading photo Open
care room and Bangladesh Labour Law 2006, Section-94 (2) & knowledge facility should recruit an days p Mr. Rajeev evidence to Sedex
Safety. Factory rules 1979, Section-65, experienced or trained Das Kalathil showing washing
ETI 3.1 & Such rooms shall provide adequate women for child care & General facility & recruit a
Local Law accommodation, adequately lighted and provide washing facilities. Manager trained women for
ventilated and maintained in a clean and child care.
sanitary condition and shall be under the
charge of woman trained or experienced in the
care of children and infants.

There shall be in or adjoining the creche a

suitable wash-room for the washing of the
children and their-clothing.

It was noted from factory tour; facility has a

child care room but has no washing facility &
was not found any governor or experience
women for monitoring child in the childcare
room.
Child care room 5. Safety and New It was noted through facility visit that, facility did Lack of It is recommended that the 30 Deskto Y Upload evidence Open
non functional Hygienic not have a functional child care room. Note that, awareness facility management should Days p Mr. Bibhash showing facility
Conditions; construction work of toilets and secondary exit was have a functional child care Kanti has a functional
Local Law going on observed during the audit for the child room. Biswas – child care room.
care room. Compliance
Manager
Child care room Health New In accordance with ETI Base Code 3.1 and Lack of It is recommended that the 60 Deskto Y Uploading photo Open
missing and Bangladesh Labour Law 2006, Section-94 knowledge facility should establish a days p Mr. Rajeev evidence to Sedex
Safety. In every establishment, wherein forty or more child care room. Das Kalathil showing establish
 ETI 3.1 & workers are ordinarily employed, thee shall be General a child care room.
Local Law provided and maintained a suitable room or Manager
rooms for the use of children under the age of
six years of such women.

It was noted from factory tour and management

interview, facility have no child care room
where above 40 women employee working at a
time.
Washing facility Health New In accordance with ETI Base Code 3.1 and The Space It is recommended that the 90 Deskto Uploading photo Open
missing in childcare and Factory Rules 1979, Section: 65 shortage facility should maintain Days p evidence to Sedex
room Safety. There shall be in or adjoining the creche a childcare room as per law. showing establish
ETI 3.1 & suitable wash-room for the washing of the a washing facility
Local Law children and their-clothing. in child care room.

It was noted through facility visit that the

childcare room of the facility is not well
furnished and no washing facility have in the
room.

Soap & unhygienic Working New

toilet condition are
safe and
hygienic
Fire Fighter training 1. New It was noted through randomly employee (fire Lack of It is recommended that 30 Deskto Yes- Upload training Open
3: Working fighter) interview, 05 out of 05 randomly effective facility should provide days p Mr. Abu documents &
Conditions are selected fire fighters of the facility did not have training effective training to facility Hayat Md. training picture
Safe and sufficient knowledge about firefighting fire fighter regarding Jaman – evidence to
Hygienic 3.2 equipment’s, fire evacuation plan, type of firefighting equipment’s, Asst. SEDEX showing
extinguisher and the usage of fire equipment’s. fire evacuation plan, type Manager facility has
of extinguisher and the (HR & conducted
usage of fire equipment’s. Compliance) mentioned type of
training with all fire
fighters.
Child Labour New Bangladesh Labour Law 2006, Section-5 Contractor is We will maintain personal 30 Follow Mr. Mahmud Follow-up audit Open
Shall Not Be Based on supplier contract register review, maintaining file to all employees. days -up Reza – GM required to verify
Used management and workers interview it was workers file Compliance the issues.
noted that factory did not maintain any personal with
file or any age verification documents for signature,
contract basis workers (65 workers in washing age proof,
section). Minimum
However no child or young looking employees wage
was found during the audit date. payment &
security
background
check.
Factory is
doing six
monthly
internal
audits of
contractors
 system.
Group Insurance Living wages New Bangladesh labor Law 2013 (Correction)
not paid Section 99.
Government may, in the manner provided by
rules, introduce group insurance, in the
establishments wherein minimum 100
permanent workers are employed.

It was noted through documents review that the

Group Insurance also expired on May 06, 2013.

Pay slip Living wages New In accordance with Bangladesh Government Lack of It is recommended that the 60 Follow Y Worker interview Open
not paid Gazette published through Gazette notification awareness factory management Days -Up Md.Bahadur and document
on November 19, 2006. SRO 100(2) should make the format of Alam review required to
Factory management shall make the format of the pay slip in local (HR, admin verify of follow up
the pay slip to the workers so that the workers language (Bengali) to the and audit that facility
will have a clear explanation and understanding workers so that the Compliance provide the pay
of claimed wages in a month. workers will have a clear Manager) slip.
explanation and
It was noted through from employee and understanding of claimed
management interview, facility did not provide wages in a month.
pay slip to all employee.

Increment 3. Living New It was noted through salary sheet, employee Lack of It is recommended that 60 Deskto Yes- Uploading photo Open
wages are personal file review, employee and awareness facility shall be providing days p Mr. Abu evidence to
paid 5.1 and management interview it was noted that, facility and yearly increment with new Hayat Md. SEDEX showing
LL management did not provide yearly increment monitoring rate of overtime for whose Jaman – that facility
with new rate of overtime 05 out of 42 randomly employee completed 1 Asst. provides arrear
selected employees whose are working from year service in the facility. Manager payment for
January 2014 for 1 years length of service. (HR & January 2015 and
Note that facility has been increase salary on Compliance) February 2015
December 2014 for whose employee joined whose employee
before January 2014. completed 1 year
service in this
facility.
Minimum wages as 5. Living New It was noted through facility tour that 4 Lack of It is recommended that 30 Follow Yes Follow up audit Open
per job & grade Wages are randomly interview employees (1 out of 4 was monitoring facility should ensured Days up Mr. Golam required to verify
Paid 5.1 and joined on September 2012 and others were minimum wages to all Rabbani – this issue those
LL joined on August 2014) of finishing section employees as per Manager folder employees
were working as Folder but during their government gazette and (HR, Admin got minimum
personal file and identity card review it was their job nature. & wages or not as
noted that they are designated as Finishing Compliance) per government
Assistant. As per Bangladesh Government gazette and their
Gazette published on December 5, 2013, grade job nature.
of Folder is 5 and the minimum wage is BDT
6042 and grade of Finishing Assistant is 7 and
minimum wage is BDT 5300. So, as per
minimum wage gazette and those interviewed
employees job nature observed, those 5
employees are entitled of minimum wage BDT
6042 with grade 5. As a result minimum wages
as per employee’s job nature of those
 employees are not ensured.
PF amount 7. New It was noted through documents review and Lack of It is recommended that the 60 Deskto Y Upload bank Open
Living wages management interview that all contributions awareness facility management should days p Mr. Lee account deposit
are paid including PF member and owner was not ensure all contributions Jong Soe – documents or slip
deposited to the concern PF bank account including PF member and Director to SEDEX
within 5 working days after realization of owner shall be deposited (Business) showing that
subscription of August and September 2014 to the concern PF bank facility PF member
(sample checked), it is delayed up to 25 account within 5 working and owner
working days. days after realization of deposited to the
subscription. concern PF bank
account within 5
working days after
realization of
subscription.
Inconsistency Wages and New In accordance with ETI base code 5.1 Lack of It is recommended that the 60 Follow Y Worker interview Open
benefit monitoring factory should maintain Days -Up Md.Bahadur and document
No.5 It was noted through the production report consistency among the Alam review required to
(Sample Delivery Khata) review that employees documents for better (HR, admin verify compliance
of the facility had worked on few weekly verification of compliance and
holidays. Those holidays were 4, 18 related issues. Compliance
January(Random Month) 2013, 8 February Manager)
2013, 1 march 2013, 21 June 2013 and 5 July
2013 which were not reflected in the
employee’s job card and salary sheet. For this
Reason the actual wages and working hours of
the employees could not be verified.
5.1 Living wages New It was noted through randomly checked 03 Lack of time It is recommended that 30 Follow Yes- Follow up audit is Open
are paid ETI month wages record and job card review, recording facility should maintain Days up Mr. Shofiqul required for verify
Base Code, Out time was not reflected system proper time recording Islam – this issue.
point: 5.1 a) 01 to 05 days at month of December, 2015 in system with keep all Manager
12 out of 52 sample employees. records. (Compliance
b) 01 to 09 days at month of August, 2015 in 18 )
out of 52 sample employees.
c) 01 to 03 days at month of March, 2015 in 03
out of 52 sample employees.
However, facility has no other out time register
or record to verify the actual scenario. Note
that, facility time recording system is
maintained by electronic attendance system
and all employees has done 2 hours overtime
in others working day.
In this circumstance actual overtime with
payment record could not be verified.
OT rate below Living wages New In accordance with ETI base code 5.1 and The Lack of It is recommended that the 90 Follow Y Follow up audit Open
are paid. Bangladesh Labour Law 2006 (Correction), awareness facility should provide days -Up Mr. Md required to verify
Section-108 overtime amount as per Abdullah Al the issue.
Where a worker works in an establishment on law. Saki - Asst.
any day or week for more than the hours fixed Manager
under this Act, he shall, in respect of overtime (HR &
work, be entitled to allowance at the rate of Compliance)
twice his ordinary rate of basic wage and
dearness allowance and ad-hoc or interim pay,
 if any.

It was noted that through wages sheet review,

management & worker interview, facility
overtime paid for piece rate worker based on
basic salary, didn’t calculate O.T rate on their
average earning.
Payment time Living wages New In accordance with ETI base code 5.1 & Due to It is recommended that 60 Follow Y Follow-up audit Open
are paid. Bangladesh Labour law 2006, Section-123 published facility management should Days -Up Mr. Md required to verify
The wages of every worker shall be paid before new gazette provide wages within Abdullah Al the issue.
the expiry of the seventh day after the last day for increase seven working days. Saki - Asst.
of the wage period in respect of which the the Manager
wages are payable. employee (HR &
wages. Compliance)
It was noted through management and
employees interview that facility management
calculated payment circle 21 date to next 20
date (monthly basis) for every month. But
December 2013 month salary didn’t provide
within seven working days.
Note that facility management interview, due to
political situation they are not able to provide
wages on time for this month.
Final Settlement 5.3 Living New It was noted through resigned employee’s files Lack of It is recommended that the 30 Follow Y Follow up audit is Open
wages are review and management interview that, monitoring facility should provide Days -Up Mr. Nurul required to verify
paid ETI Base service benefit to the Haque- the issue.
Code, point: a) The service benefits of 1 out of 5 randomly entitled resign employee Assistant
5.1 and checked resigned employee was found not yet (employee who has General
Bangladesh settled. Note that the employee was resigned worked 5 years or more in Manager
Labour Act on 30 November 2014 and his final settlement the facility) and actual un (HR Admin
2006, was found ready in his personal file. Also note availed earned leave & CSR)
Section: 27, that the facility has considered 2 days un- amount with resigned
11, 108 and availed leave during settlement calculation month’s wages.
123 (2) instead of 24 days that he supposed to get.
Note that the particular employee was
transferred from a sister concern of the audited
facility and he has joined to the audited facility
with 22 days un-availed leave. Therefore, this
employee supposed to get total 24 days (22
days from previous facility and 2 days from the
current facility) un availed annual leave benefit.

c) Also the wages and overtime payment of

resigned month was not settled for 1 out of 5
randomly checked resigned employees. Note
that the employee was resigned on 9 July 2015
and he was working 8 days with 6 hours
overtime in the particular month. Also note that
all documents related to payment was found
ready in employee’s personal file and
management informed that the employee did
not communicate to get the payment.
Earn Leave New Based on randomly checked 03
employees final settlement file,
earn leave encashment record
review and management interview
it was noted that, facility has a
system to encashed un-availed
earn leave amount for every
complete 1 year service in the
facility. As a result of which those
employees were resigning before
the next completed year were not
getting any payment against their
earn leave. For an example- ‘X’
employee joined in 1st September
2012 and according his date of
join in month of September 2013
she got her annual leave payment
and it will continue accordingly.
The said employees resigned on
8th July 2015 and did get annual
leave payment of approximately
13 days due to the facility’s
internal payment system.

In addition the calculation for

annual leave encashment was not
as per law.
Earn Leave 5.2 Living New It was noted through randomly checked 03 Lack of It is recommended that the 30 Follow Y Follow up audit is Open
encashment wages are resign employee’s personal file and monitoring facility management shall Days -Up Mr. Nurul required to verify
paid ETI Base management interview that, facility calculate annual leave Haque- the issue.
Code, point: management did not calculate un-availed earn payment as per law. Assistant
5.1 and leave amount as per local law. For example General
Bangladesh facility calculate earn leave amount = Gross Manager
Labour Act wages/ 30 days * un-availed earn leave (1 for (HR Admin
2006, 18 days) instead of = Gross wages/ last month & CSR)
Section: 119 actual attendance * un-availed earn leave (1 for
18 days). For these reason employees are
being deprived during final settlement.

In addition, the calculation method of yearly

 earn leave encashment was not as per law.
They did the calculation on basic wages instead
of gross wages which affect their ultimate
financial settlement during resign.
Bang interest not 4. Living New It was noted through randomly checked resign Lack of It is recommended that the 30 Follow Y Follow up audit Open
paid during Final wages are 05 employees personal file and management awareness facility management shall Days up Mr. Salim required for verify
Settlement paid and The interview that, during final settlement or provide full amount of Uddin - Sr. this issue.
EPZ separation the facility management did not employees and employer Executive (HR
Employees share bank interest or interest amount of subscription with bank &
(Contributory) his/her deposited subscription along with interest amount during final Compliance)
Provident employer subscription. separation of resign
Fund Policy employees as per BEPZA
2012, Clause: provident policy.
15
Inconsistency 10. Living New It was noted through employee time card, extra Lack of It is recommended that the 60 Follow Y- Follow up audit
wages are overtime register, wages sheet review, monitoring factory should maintain Days up Mr. Eftekhar required for further
paid 5.1 employee and management interview that, consistency among the Mahbub verification.
documents for better Sunny –
Overtime hour of all sampled employees were verification of compliance General
found not consistent in between extra overtime related issues. Manager
register, time card and wages payment record.
For Example “X” employee time card and extra
overtime record monthly shown (as per
provided documents) total overtime 76 hours
(50 hours + 26 hours) for the month of March
2015 but as per provided salary/wages sheet it
was shown monthly total overtime paid 89
hours.

For this reason the actual working hours,

overtime and actual wages of the employees
could not be verified.
6.1 Working New It was noted through randomly checked 03 Lack of time It is recommended that 30 Follow Yes- Follow up audit is Open
hours are not month wages record and job card review, recording facility should maintain Days up Mr. Shofiqul required for verify
excessive ETI Out time was not reflected system proper time recording Islam – this issue.
Base Code, a) 01 to 05 days at month of December, 2015 in system with keep all Manager
point: 6.1 12 out of 52 sample employees. records. (Compliance
b) 01 to 09 days at month of August, 2015 in 18 )
out of 52 sample employees.
c) 01 to 03 days at month of March, 2015 in 03
out of 52 sample employees.
However, facility has no other out time register
or record to verify the actual scenario. Note
that, facility time recording system is
maintained by electronic attendance system
and all employees has done 2 hours overtime
in others working day.
In this circumstance actual overtime with
payment record could not be verified.
Inconsistency 11. Working New It was noted through employee time card, extra Lack of It is recommended that the 60 Follow Y- Follow up audit
Hours are not overtime register, wages sheet review, monitoring factory should maintain Days up Mr. Eftekhar required for further
Excessive 6.1 employee and management interview that,
and Local Law consistency among the Mahbub verification.
Overtime hour of all sampled employees were documents for better Sunny –
found not consistent in between extra overtime verification of compliance General
register, time card and wages payment record. related issues and should Manager
For Example “X” employee time card and extra keep overtime hours within
overtime record monthly shown (as per working hour approval by
provided documents) total overtime 76 hours local law.
(50 hours + 26 hours) for the month of March
2015 but as per provided salary/wages sheet it
was shown monthly total overtime paid 89
hours.

For this reason the actual working hours,

overtime and actual wages of the employees
could not be verified.

Also below excessive working hour was found

based on provided records
a) In the month of May, 2015 (Current Month),
38 out of 42 randomly selected employees
worked lowest 73 hours (normal 48 hours +
overtime 25 hours) to highest 84 hours (normal
48 hours + overtime 36 hours) in a week.
Among the 42 sample employees, 10
employee’s maximum working hours in a week
reached to the mentioned highest 84 hours.
Daily highest working hour was found 18 hours
(normal 8 hours + overtime 10 hours). 10 out of
42 sample employees maximum working hour
in a day reached to that mentioned highest 18
hours.
b) In the month of March, 2015 (Peak Month),
35 out of 42 randomly selected employees
worked lowest 73 hours (normal 48 hours +
overtime 25 hours) to highest 84 hours (normal
48 hours + overtime 36 hours) in a week.
Among the 42 sample employees, 25
employee’s maximum working hours in a week
reached to the mentioned highest 84 hours.
Daily highest working hour was found 24 hours
(normal 8 hours + overtime 16 hours). 20 out of
42 sample employees maximum working hour
in a day reached to that mentioned highest 24
hours.
Working Hours New In accordance with ETI base code 6.1 Lack of It is recommended that the 60 Follow Y Worker interview Open
No.6 monitoring factory should maintain Days -Up Md.Bahadur and document
It was noted through the production report consistency among the Alam review required to
(Sample Delivery Khata) review that employees documents for better (HR, admin verify compliance
of the facility had worked on few weekly verification of compliance and
holidays. Those holidays were 4, 18 related issues. Compliance
January(Random Month) 2013, 8 February Manager)
2013, 1 march 2013, 21 June 2013 and 5 July
 2013 which were not reflected in the
employee’s job card and salary sheet. For this
Reason the actual wages and working hours of
the employees could not be verified.
Excess working 6: Working New In accordance with ETI base code-6.1 and the Due to It is recommended that the 90 Follow Y Follow-up audit Open
hour Hours are not Bangladesh labour Law 2006, Section 100 and production facility shall be maintain Days -Up Mr. Monir required to verify
Excessive and 102 pressure working hour as per ETI Hossain – the issue.
Local Law No adult worker shall generally be required or base code and local law. Sr.
allowed to work in an establishment for more Manager-
than eight hours in any day. Provided that, Compliance
subject to the provisions of section 108 an adult & IMS
worker may also work upto ten hours a day in
an establishment.
(1) No adult worker shall ordinarily be required
or allowed to work in an establishment for more
than forty-eight hours in any week.
(2) Subject to the provisions of section 108, an
adult worker may work for more than forty-eight
hours in any week:

It was noted through salary sheet, job card

review, employee interview and management
(Sr. Manager – Compliance & IMS) interview
that excessive working hour was noted as per
below:

a) 64 out of 90 employees tested record

showed 61 (normal 48 hours + overtime 13
hours) to 98 hours (normal 48 hours + overtime
50 hours) of work in a week in the month of
June 2014. Maximum work in a day was found
18 hours (normal 8 hours + overtime 10 hours).

b) 31 out of 90 employees tested record

showed 61 (normal 48 hours + overtime 13
hours) to 78 hours (normal 48 hours + overtime
30 hours) of work in a week in the month of
March 2014. Maximum work in a day was found
13 hours (normal 8 hours + overtime 5 hours).

c) 40 out of 56 employees tested record

showed 61 (normal 48 hours + overtime 13
hours) to 88 hours (normal 48 hours + overtime
40 hours) of work in a week in the month of
November 2013. Maximum work in a day was
found 15 hours (normal 8 hours + overtime 7
hours).
Consecutive days Working Hours New In accordance with ETI base code-6.1 and the Due to It is recommended that the 60 Follow Y Follow-up audit Open
are not Bangladesh labour Law 2006, Section 103 production facility should ensure one Days -Up Mr. Monir required to verify
Excessive and An adult worker employed in an establishment pressure day off after six Hossain – the issue.
Local Law (a) which is a shop or commercial consecutive days. Sr.
establishment, or industrial establishment, shall Manager-
 be allowed in each week one and half days Compliance
holiday and in factory and establishment one & IMS
day in a week;

It was noted through salary sheet, production

record, job card review and employee and
management interview that one day rest after
six days of work was not ensured for the
employees due to following reason:

a) Facility was open on facility weekly holiday

(Friday) of 06, 13, 20, and 27 June 2014. So,
56 out of 90 employees tested record showed
consecutive 10 to 18 days of work in the month
of June 2014.
b) Facility was open on facility weekly holiday
(Friday) of 1, 22 and 29 November 2013. So,
35 out of 56 employees tested record showed
consecutive 08 to 10 days of work in the month
of November 2013.
Appointment Letter Regular New In accordance with ETI Base Code 8.1 and Lack of It is recommended that 30 Follow Y Worker interview Open
Employment Bangladesh Labor Law 2006, Section-5 awareness facility management should Days -Up Mr. Monir and document
No employer shall employ any worker without provide appointment letter Hossain – review required to
giving such worker a letter of appointment and to all the employees. Sr. verify this issue of
every such employed worker shall be provided Manager- follow up audit that
with an identity card with photograph. Compliance facility provided
& IMS appointment letter.
It was noted through documents review,
employee and management interview, facility
management did not provide appointment letter
to all employee.
Appointment Letter 8. Regular New It was noted through facility visit, management Lack of It is recommended that 30 Deskto Yes- Uploading photo Open
Employment Is interview (Manager- HRD) that, employer proper facility should ensure Days p Mr. Abu evidence to
Provided 8.1 signature were found missing in appointment documentati employer sign in the Hayat Md. SEDEX showing
letter of 05 out of 10 randomly checked on control appointment letter for all Jaman – employer sign in
employees personal file from HR department . employees. Asst. the appointment
Those employees joined in the month of March Manager letter.
2015. As per management interview, in the (HR &
month of March 2015 total 35 employees had Compliance)
joined in the facility.
ID card Regular New In accordance with ETI Base Code 8.1 and Lack of It is recommended that 30 Follow Y Worker interview Open
Employment Bangladesh Labor Law 2006, Section-5 awareness facility management should Days -Up Mr. Monir and document
No employer shall employ any worker without provide ID card to all the Hossain – review required to
giving such worker a letter of appointment and employees. Sr. verify this issue of
every such employed worker shall be provided Manager- follow up audit that
with an identity card with photograph. Compliance facility provided ID
& IMS card.
It was noted through documents review,
employee and management interview; facility
management did not provide ID card to all
employees.
Service Book Regular New In accordance with ETI Base Code 8.1 and Lack of It is recommended that 30 Follow Y Worker interview Open
Employment Bangladesh Labor Law 2006, Section-6(1) awareness facility management should Days -Up Mr. Monir and document
provide service book to all Hossain – review required to
Every employer shall, at his own cost, provide a the employees. Sr. verify this issue of
service book for every worker employed by him. Manager- follow up audit that
Compliance facility provided
It was noted through documents review, & IMS service book.
management and employees interview, that the
facility management did not provide service
book to the employees who have joined near
about six months. -- out of – interviewed
employees did not get service book.

Service Book not Regular New In accordance with ETI Base Code 8.1 and Due to work It is recommended that 30 Follow Y Document review Open
updated Employment Bangladesh Labor Law 2006, Section 7(1) (2) pressure facility management Days -Up Mr. Monir required to verify
(1) The service book shall be of such size and should update the Hossain – this issue of follow
service book with
in such form as may be prescribed and necessary information Sr. up audit that
photograph of the worker shall be affixed to it. as per requirement of Manager- facility updated
(2) The service book shall contain the following law. Compliance employee service
particulars, namely: & IMS book.
(a) Name of the worker, name of mother and
father and address of the worker, (In
appropriate case name of husband/ wife shall
be written)
(b) Date of birth,
(c) Particulars necessary for identification,
(d) Name and address of the employer under
whom previously employed, if any,
(e) Period of employment,
(f) Occupation or designation,
(g) Wages and allowance, if any,
(h) Leave availed, and
(i) Conduct of the worker.

It was noted through employee service book

review, facility management did not preserve
the service book with necessary information.
E.g. service book were found without the
information of previous employment, wage and
allowance, leave availed. Moreover service
book were not signed by the employer.

Service Book not 8.1: Regular New It was noted through employee personal file Lack of It is recommended that the 30 Deskto Y Uploading photo Open
updated Employment Is review and management interview that 20 out monitoring facility should update Days p Mr. Nurul evidence to
Provided of 42 employees service book found not employee’s service book Haque- SEDEX showing
ETI Base updated with updated salary status. with their updated salary Assistant updated service
Code, point: status. General book.
8.1 and Manager
Bangladesh (HR Admin
Labour Act & CSR)
2006,
Section 7
Service book blank 12. Regular New It was noted from sample employee personal Lack of It is recommended that 30 Deskto Y Uploading photo Open
employment is file review, 10 out 67 sample employee service monitoring facility shall update all days p Mr. Faysal evidence to
provided 8.2 book was found blank without any information. clause/column in service Islam – SEDEX showing
and BLL 2006, books time to time. Manager that facility
Section: 7 (2-f (HR & updated all service
& g) Compliance) book time to time.
Provident fund 4. Living New In Accordance with ETI base code 5.1 and Lack of It is recommended that the 30 Follow Y Follow up audit Open
interest not paid wages are The EPZ Employees (Contributory) knowledge facility management shall Days up Mr. Salim required for verify
paid and The Provident Fund Policy 2012, Clause: 15 provide full amount of Uddin - Sr. this issue.
EPZ employees and employer Executive (HR
Employees A member of the provident fund shall be subscription with bank &
(Contributory) entitled to following financial or other benefits. interest amount during final Compliance)
Provident separation of resign
Fund Policy a) If any member continues his job for three employees as per BEPZA
2012, Clause: years or more without interruption and resigns provident policy.
15 from his job at his will, he will get full amount of
money from both sides along with profit of the
provident fund.
b) If any member continues his job less than
three years but two years or more and resign
his job, he will get full amount of money of his
paid subscription along with profit and half
portion of the subscription of the
industry/owner/factory/employer. In this case
remaining amount of money including profit
shall be transferred to the account of the
employer.
c) If a subscriber resigns before two years of
his job, he shall be eligible to get only his total
subscriptions along with profit. In this case,
deposited subscription by the employer along
with profit shall be transferred to the account of
the employer.

It was noted through randomly checked resign

05 employees personal file and management
interview that, during final settlement or
separation the facility management did not
share bank interest or interest amount of
his/her deposited subscription along with
employer subscription.
Warning letter 13. No Harsh New It was noted through randomly checked 04 out Lack of It is recommended that 30 Follow Y Follow up audit Open
or Inhumane of 67 personal file and employee interview that, knowledge facility shall maintained days up Mr. Faysal required to verify
Treatment is facility management issued direct warning letter punishment procedure as Islam – this issue.
Allowed 9.1 to the employees without legal procedure such per law with clear Manager
and BLL 2006, as: show cause letter, given copy thereof and explanation in show cause (HR &
Section : 24 seven day’s time to explain, given an letter. Compliance)
opportunity of being heard, inquiry for that
event.