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Facility Name:
Address and Country of factory location: B
Month: January
Audit date: 24 -01-2018
Audited By: Abu Sayeed Md.Zakaria
Company Title: Compliance Auditor
E-Mail & Cell No : sayeedzakaria321@gmail.con & 01924649374
1. Compliance with Laws and Workplace Regulations
Sl.No Question Yes No N/A Comment
Responsible
Person
Corrective Action
1
Do you have policies and procedures for current information on all relevant laws and
regulations?
2
Does your facility have a program to train relevant individuals regarding the changes for any new
laws or revisions to existing laws and regulations? Are training materials are appropriate?
3 Does your facility sub-contract any of its production operations or any other operations?
4 How has your facility informed the sub-contractor of their obligations under the local labor law?
5
Does your facility keep evidence of how the sub-contractor(s) has/have been made aware of
these requirements?
6 Does your facility keep receipt of sub-contractor acknowledgement of these requirements?
2. Prohibition of Forced Labor:
7
Does your facility have a qualified person responsible for communicating, deploying, and
monitoring the practices of effectively prohibiting involuntary, forced or trafficked labor?
8
Does your facility have a program and materials used to train relevant individuals, including all
individuals responsible for the hiring process, on the facility's policies and procedures prohibiting
forced, involuntary, or trafficked labor?
"SOCIAL COMPLIANCE AUDIT"
9 Are all employees working at this facility voluntarily?
10 Are employees' movements restricted?
11
Do security personnel act in a non-threatening manner? Are they posted for normal security
reasons?
12 Are the doors and gates of your facility locked in normal business hour?
13 Does the factory have a qualified Electrician,If yes what is his name?
14
Does the facility prohibit all relevant individuals from coercing employees in any way, or
unnecessary limiting employees' freedom of movements?
15 Is employee freedom of movement unimpeded upon their shift's conclusion?
16
Does the facility require all hiring documents, such as an employment application or contract to,
1) include a statement affirming that applicants are seeking employment voluntarily and are not
under threat of any penalty, 2) be signed by each applicant, and 3) be maintained in the
employee's personal file?
17
Does the facility obtain proof that anyone seeking employment is legally to work in the country of
manufacture with national immigration laws?
18
Are all security service agreements free of any language or terminology that may imply the
existence of forced, indentured, trafficked or involuntary labor confitions?
19
Do the job descriptions or individual contracts for security employees limit their tasks to normal
security matters such as protection of facility property of facility personnel?
20 Does the facility issue wages/compensation directly to employees only?
21 Does the facility hold the identification papers, travel documents or passports of the employees?
22 Does your facility rquire any employee deposits or have any withholding payment practices?
23
Does your facility use prison labor? or is there any policy that is relevant to use/non-use of prison
labor?
24 Are all work contracts signed by both parties (employer and employee)?
3. Prohibition of Child Labor:
25
Does your facility obtain proof of age documentation from all potential workers and review the
documentation for authenticity prior to hiring and keep this age document in employee's
personnel file for the length of time as required by law?
26 Does your facility has a interview questions check list to ask to the applicant?
27
Does your facility require a completed and signed employment application that includes the date
of birth?
28
Does your facility have a assigned qualified person responsible for dealing with child labor
practices?
29
Do the programs and materials used to train relevant individuals on the child labor practices,
including all individuals responsible for the hiring process, cover the requirements: obtain age
documentation, review age documentation for authenticity, and interview all prospective
empolyees?
4. Prohibition of Harassment or Abuse:
30
Does your facility have a written policy on the prohibition of harassment, abuse, and corporal
punishment?
31
Has your facility formally designated a qualified person for monitoring the harassment and abuse
policies and procedures as prescribed by law?
32
Does the policy include resonable punitive repercussions for non-compliance and repeated non-
compliance?
33
Does your facility have signed statements by your facility's management affirming their
understanding of the facility's anti-harassment and abuse policies?
34
Does your facility communicate the policy on the prohibition of harassment and abuse to
workers, and third party services (e.g., securith guard)?
35 If any incidents of harassment or abuse were reported, were they resolved in a timely manner?
36
Is there an effective and mandatory program to train relevant individuals, including all individuals
responsible for the supervision of workers, on the facility's policies and procedures prohibiting all
forms of harassment, abuse, and corporal punishment?
5. Compensation and Benefits:
37
Has your facility formally designated a qualified person for monitoring the payroll and benefit
system and ensuring that wage rates and compensation calculations are adequately
communicated to all workers in the facility?
38
Does your facility have practices to ensure employees are compensated consistent with their
terms of employment and in accordance with local laws and regulations?
39
Does the lowest record of payment by your facility meet(or exceed) the legal minimum
compensation?
40
Does your facility post legal minimum wage rates, benefit policies, and additional payment
information in the native language of the facility workers?
41 Does your facility utilize and maintain an organized system of record keeping?
42
Does the facility produce and retain payroll records to support compensation, including
overtime?
43
In case the facility pays its employees through wire transfers, do you produce and retain proof of
bank statements showing all the transactions in a verifiable way?
44
Does your facility provide all employees with a pay record or stub which lists the components of
the wage paid?
45
Are all legally mandated withholdings (e.g. taxes, social security, etc.) remitted to the
government?
46 Are there any piece rate workers in the facility?
47
Does your facility have a written and coherent policy on piece rate compensation that ensures
the piece rate compensation at leat satisfies the minimum compensation prescribed by law?
48
Do employees sign off on material counts or random independent recounts for piece rate
systems?
49
Are employees provided with adequate communication of their legally mandated minimum
compensation rights? The communication include:
a) details description of the employees compensation and benefits at the time of employment?
b) both a written and verbal explanation of wage calcuations provided at the time of
employment?
c) Changes to compensation rates or methods of wage calculations communicated timely and
effectively?
6. Hours of Work:
50
Has your facility formally designated a qualified person for monitoring the working hour per day,
per week and ensure that no employee works more than the legal limit?
51
Is there an effective and mandatory program to train relevant individuals, including all individuals
responsible for production coordination and scheduling, to ensue that employees work not more
than the legal maximum, including overtime ceilings?
52
At the time of hiring, are employees made aware of facility policies and procedures, specifically
the legal limitaions on the maximum hours of work per day, week and month, both regular and
overtime, and the maximum number of consecutive days they can legally be required to work?
53
Does your facility retain time records that reflect the day and date employees worked, the
number of hours worked each day, and the employees' acknowledgements?
54
Does the facility have a written, rational and well communicated policy defining "urgent business
needs"?
55
Are notifications of maximum regular and overtime hour policies visibly posted in the native
language of your facility's workers and management personnel?
56
Does your facility require that all new workers, at the time of hiring, be made aware of the
facility's policies on required hours of labor?
7. Prohibition of Discrimination:
57 Does your facility have a written policy that explicitly prohibits discrimination?
58
Does your facility have a written policy visibly posted in the languages of the employees and
management personnel?
59
Does your facility have a formally designated qualified person with responsibility for
communicating, deploying and monitoring the non-discrimination policy?
60
Is there an effective and mandatory program to train relevant individuals, including all individuals
responsible for the supervisons of workers and for the hiring process, on the discrimination
practices?
61
Are the facility's policy, practices and procedures on discriminatory behaviour effectively
communicated to all employees?
62
Does your facility effectively communicate in wirting the requirements of this principle to third
parties (industrial parks, export processing zones, free trade zones, sub-contractors etc.) that
may recruit and screen applicants on its behalf?
63
Has your facility had any discrimination charges filed against it by employees, regulatory agencies
or any outside agency during the past two years?
64
Does your facility prohibit mandory pregnancy testing as a condition of employment or continued
employment?
65
Are workers with the same job and seniority paid the same rate, irrespective of gender, age, or
other characteristics?
66
Do employees sign statements (statements may be included in an employment application or
contract), written in the native language of the employees, affiriming their receipt and
understanding of the facility's ani-discrimination practices?
8. Health & Safety:
67 Does your facility comply with all relevant health and safety laws and regulations?
68
Does your facility have all relevant government health, safety, and fire safety certificates/permist,
insurance policies and any relevant correspondence or documents from government officials?
69
Does your facility undertake internal monitoring of your health and safety systems, including fire
safety, to ensure your are following the written procedures and processes and meeting the
requirements of all relevant laws?
70 Have risk assessments heen carried our throughout your facility, including fire risk assessments?
71
If there were any risks or deficiencies that were identified by the health, safety and fire risk
assessment, were they corrected?
72 Does your facility conduct regular occupational health checks for hazardous job duties?
73
Is there an effective and mandatory program to train relevant individuals, including all individuals
responsible for the supervisons of workers, on all the relevant occupational health and safety
issues?
74
Does your facility have a written safety program, including written procedures to handle natural
disasters, fire safety, and emergencies and industrial accidents?
75 Are the following safety documents maintained by your facility:
a) Health and safety reports?
b) Heavy machinery inspection?
c) Maintenance reports?
d) Fire extinguiser records, noting date inspection and expiration?
e) Emergency drill records, noting date and detailed results?
f) Work injury reports?
g) Clinic logs, noting date and reason for visit?
76
Have any government agencies inspected your facility for compliance with safety and health
regulations during the past two days?
77
Does your facility address the following occupational health and safety needs required by the
relevant laws and regulations for the following:
a) Heat stress/extreme temperatures?
b) Paint spray/spot cleanding booths?
c) Welding safety?
d) Respirator safety?
e) Blood borne pathogen program?
f) Hearing (noise control program)?
g) Indoor air quality?
h) Cotton dust ventilation?
i) Sanitary waste disposal?
GENERAL BUILDING REQUIREMENTS
78
Does a visual inspection of your entire facility premises suggest any concerns anout the physical
integrity of the facility?
79 What is the overall general appearance of your facility: Excellent, good, fair or unacceptable?
80
Is the overall general appearance of the maintenance shop acceptable and not in a condition that
can cause serious injuty or harm?
81 Is trash properly disposed of both inside and outside the facility?
82
Are the toilets and washrooms in your facility in sanitary and serviceable condition and meeting
minimum quantity required established by relevant laws?
83
Are exits unlocked during times when the facility is occupied to allow free, unobstructed exit from
the facility?
84 Are any aisles blocked or restricting easy access to emergency exits?
85
Has your facility appropriately identified areas that , for fire safety purposes, should be
designated as"non-smoking"?
86 Is your facility properly enforcing the "non-smoking" policy for areas so designated?
87
Does your facility maintain first aid supplies as required by law or if no legal requirement exits, as
recommended by a local medical provider?
88 Are these first aid supplies available and accessible to all areas of the facility?
89 Is there clean drinking water and is it easily accessible at the facility?
90 Is drinking water provided at no cost to employees?
91 Is your facility's child care area opearted and maintained in a safe and healthy manner?
92 Is your facility's canteen/cafeteria opearted and maintained in a safe and healthy manner?
PERSONAL PROTECTION EQUIPMENT (PPE)
93
Does your facility conduct hazard assessments to determine if any personal protective equipment
is required?
94 If personal protective equipment is required, is it provided to affected employees, at no cost?
95 Are the PPE appropriate and adequate for the workers' job and in good condition?
ELECTRICAL SAFETY
96
Is there a qualified electrician in your facility responsible for maintaining electrical safety? If not
what is the facility doing to ensure electrical safety?
97
Does a visual inspection of the wiring indicate good general condition of the cabling, tidiness and
no exposed or loose wires?
98
Does a visual inspection of the electrical boxes and cabinets verify: complete enclosures with
covers provided, switches and outlets maintained in good working order, and all knockout/trips
are in place?
WORKER SAFETY AWARENESS
99
Does your facility maintain a safety committee comprised of workers and management, which
holds qualrterly meetings and keeps minutes of proceedings?
100
Does your facility conduct an orientation health and safety and fire training for all new
employees?
101 Does the training cover the following in regards t ofire safety?
a) Workers are informed of the locations of fire alarm pull and button stations?
b) Workers are informed of the locations of fire extinguishers in and near their work area?
c) Workers have specific training concerning the dangers of smoke inhalation?
d) Workers are informed of location of nearest exits and assembly points?
102 Is employee training conducted for first aid and safety?
103 Are first aid responders/emergency safety personnel identified and property trained?
104 Have selected employees been trained on the proper use of firefighting equipment?
105
Have all employees who have any contact with chemicals been trained on how to safely handle
and dispose of the specific chemicals and eliminate fire risk?
106 Are MSDS available (in appropreate language) for all chemicals used by the facility?
FIRE SAFETY
107
Does your facility have an emergency evacuation plan in the native language posted in view of
the facility's workers?
108 Does your facility conduct regular emergency evacuation drills (at least once in a month)?
109
Does the facility have adequate numbers and locations of unimpeded emergency exits that open
ourwards and lead to a safe assembly point?
110 Is the following safety equipment:
a) visible
b) appropriate in functionality and number?
c) propertly distributed throughout the facility?
d) easily accessible?
e) properly mounted?
f) unblocked and free of obstruction?
g) fire extinguishers are appropriate for the class(es) for fires expected in the area?
111 Are the fire-fighting water hoses and connections in usable condition?
112
Does your facility have appropriate measures to ensure adequate water pressure for fire fighting
water hoses and sprinkler systems?
Sprinkler Valves
113 Are sprinkler valves in good working order?
114 Are all sprinkler heads kept unobstructed from storage or other materials?
Fire Alarm Boxes
115 Are fire alarms clear, unobstructed, and identified?
116 Does the facility have a test schedule for all fire alarm boxes?
117
Are combustible scrap, debris, and waste materials stored in covered metal receptacles, and
removed from the work site promptly? If not explain how they are stored.
EMERGENCY EVACUATION
118 Are lighting and alarm systems adequate and fitted with back-up systems?
Emergency Lighting
119 Is appropriate lighting in place in your facility?
120 Is the emergency power system working and in good condition?
121 Does the facility regularly conduct tests to ensure the system is functioning properly?
Stairwells
122 Are all stairwell handrails in good condition?
123 Are all stair treads in good condition?
124 Are all stair widths in compliance with requirements of all relevant laws?
125 Are the stairways provided with artificial and emergency lighting?
126 Are stairwells completely clear of obstructions?
127 Does the facility ensure stairwells are not used for storage?
CHEMICAL SAFETY
128 Does your facility have a chemical safety program?
129 Where applicable, does your facility properly store hazardous/toxic materials?
130
Does your facility have the required government storage and usage permits for chemicals, if
required?
131
Does your facility maintain documentation for chemical labeling (including fire safety), chemical
usage warning, and proper handling instruction?
132
Does your facility ensure that all solvent wastes and flammable liquids are properly stored
(including being kept in closed containers when not in use) at all times and kept away from
potential ignition sources?
133 Are the chemical storage areas free of ignition sources?
BOILER & COMPRESSOR ROOMS
134
Is the location of the boiler room compressor room consistent with all relevant requirements? (If
no local or national laws apply, please describe the location of the boiler and compressor room.)
135
Are there housekeeping and maintenance procedures in plance for the boiler and compressor
rooms?
136 Are there any fuel leaks?
137 Are the boilers and compressors inspected and serviced periodically?
138 Are the boiler licenses valid and authentic?
139 Is the boiler operator certificate valid and authentic?
9. Free of Association & Collective Bargaining:
140
Does your facility have written policies and procedures that recognize and respect the right of
employees to exercise their lawful rights of free association?
141
Does your facility have a designated qualified person with responsibility for communicating,
deploying, and monitoring the freedom of association practices as prescribed by labor law?
142 Does your facility have a union, association, or collective representation of employees?
143
If a union or collective associateion which represents the employees exits, does facility consult
with the worker representatives on any issues that are a requirement by law such as facility
disclosures, mass lay-offs, restructuring of the business etc.?
144
If the workers do have an organized group that addresses workplace issues, does this wrokers'
group operate free from coercion or illegal restrictions to its operations?
145
If a lawful association exits, is there any bargaining agreement or labor-management negotiation
on workplace issues?
146 Are there formal communication procedures between worker representative and management?
147
Does your facility enter into discussions with the workers representatives in an open manner and
within the terms of local law?
148
Are minutes of facility / worker representative meetings documented and available to the
workers?
149 Are workers representatives elected on a free and confidential basis by the workers?
150
Does your facility discriminate against employees who form or participate in lawful
associateions?
151 Does your facility discriminate against those who choose not join any association?
152
Does your facility communicate its policies and practices pertaining to this Principle to all facility
employees and third parties that may perform recruitment or screening of applicants?
10. Environment:
153 Does your facility have an environmental management system relevant to its industry?
154
Does your facility have a designated qualified person with responsibility for communicating,
deploying, and monitoring the environment practices elaborated upon in the environmental
management system?
155
Does your facility have a program and materials used to train relevant individuals on each
practice of the environmental management system?
156
Does your facility assess its ability to prevent and control harmful releases of industrial waste into
the environment as a part of the environmenatal managemnt system?
157
Does your facility maintain a detailed plan for handling accidental release or discharge of
environmentally dangerous materials?
158 Does your facility maintain records of emission events?
159
Does your facility's environmental management system address where and how solid, chemical,
sanitary and wastewater substances are disposed?
160
Does the facility adequately communicate to all facility employees the relevant local and national
laws and regualtion sas well as pertinent facility procesures concerning th e environemnt
principle?
11. Customs Compliance:
161 Does your facility keep copies of all applicable customs laws and regulations?
162
Does your facility's policies and procedures on customs compliance cover the following
requirements:
Compliance with all applicable customs laws and maintains practices to comply with customs
laws regarding illegal transshipment of poructs. In the event possible illegal transshipment
actiivity, appropriate host government agency will be notified?
163 Monitors its productions on a per style basis?
164
Traces country of origin using records such as production, shipping, verification reports, quality
control reports, and individual piecework sheets, for all inputs?
165 Varifies production on an ongoing basis on site and at sub-contracting facilities?
166 Maintains a facility machine inventory and updates it annually?
167
Ensures that the proper category designation is determined for all goods destined fo rthe US
market.
168 Does your facility maintain an organized system of production documentation?
169 Are the following records maintained?
a) Records of the country of origin for all goods produced in this facility.
b) A production profile of any subcontracting facility. This facility requests documents from the
subcontracting facilities when questions regarding goods produced at those facilities arise.
c) Production/purchase orders ( with information such as conditions of production, payment, and
finished product specifications).
d) Raw materials invoices (indicating country/origin/manufacturing facility).
e) Shipping / receiving documents (outgoing and incoming records of components/inputs sent to
or received from another facility).
f) Employee work records - accurate records of emplyee work hours that can be linked to the
production of specific products.
g) Quality control records (which may include facility name and address, purchase order number,
style number, date of the quality check, buyer, name, stamp or signature of inspector, comments
on production).
h) Export documents (including: packing list, manifest, bill of lading/airway bill from truck, ship,
plane or train indicating the export date, exporting entity, destination, shipping lines, importing
entity, and any charges incurred).
i) Outward processing production ( if applicable, copies of the ourward processing program
disignated by the domestic government, copies of compliance review reports, documentation
demonstrting the flow of goods from one facility to another).
j) Number of units produced marked with a traeable mark.
k) Documentation on how the qualified person with responsibility for the Principle
communicates, deploys, and monitors the facility's customs compliance policies?
170
Has the facility designated a qualified person with responsibility for communicating, deploying
and monitoring customs compliance?
171
Does the responsible person ensure that such origin determining documents are maintained for
at least the period of record retention required by law?
172
Does the responsible person ensure that all subcontracting facilities complete a production
profile and keeps such profiles on file?
12. Security:
173
Does your facility have practices to guard against the introduction of contraband (e.g. drugs
explosives, biohazards, and/or other contraband; any non-manifested cargo will be referred to as
contraband.)?
174
Has your facility designated a qualified person with responsibility for communicating, deploying,
and monitoring security policies and procedures?
Container and Trailer Security
Container Inspection
175
Does your facility have documented procedures in place to verity the physical integrity of the
container structure prior to loading?
176 Does the procedure include the reliability of the locking mechanisms of the doors?
177
Does the facility conduct a seven-point inspection process (see list below) for all containers and
keep records of all inspections?
a) Front wall
b) Left side
c) Right side
d) Floor
e) Ceiling/Roof
f) Inside/outside doors
g) Outside/Undercarriage
Trailer Inspection
178
Does your facility have procedures in place to verify the physical integrity of the trailer structure
prior to loading, including the reliability of the locking mechanisms of the doors?
179 Is the facility following five-point inspection process is recommended for all trailers?
a) Fifth wheel area - check natural compartment / skid plate
b) Exterior - Front/sides
c) Rear - bumpers/doors
d) Front wall
e) Left side
Container & Trailer Seals
180 Does your facility affix a high security seal to allloaded trailers and containers bound for the US?
181 Do seals meet or exceed the current ISO 17712 standards for high security seals?
182
Does your facility have documented procedures stipulating how seals are to be controlled and
affixed t loaded containers and trailers?
183 Does your facility have designated employees for the distribution of seals for integrity purposes?
Container & Trailer Storage
184 Is the secutiry of containers and trailers located within the facility maintained?
185 Are they in a secure area to prevent unauthorized access and/or manipulation?
186
Does your facility have documented procedures in plac efor reporting and reutralizing
unauthorized entry into containers/trailer storage areas?
Physical Access Controls
187 Does your facility have a physical access control procedure?
Employees
188
Does your facility have an employee identification system in palce for positive identification and
access control purposes?
189
Does your facility ensure that employees are only given access to those areas needed for the
performance of their duties?
190
Does your facility control the issuance and removal of employee, visitor and vendor identification
badges?
191
Does your facility have documented procedures for the issuance, removal and chanding of access
devices(e.g. keys, key cards, etc.)?
Visitors
192 Does visitors present photo identification for documentation purposes upon arriaval?
193
Is vendor ID and/or photo identification required to be presented for documentation purposes
upon arrival by all vendors?
Challenging and Removing Unauthorized Persons
194
Does your facility have documented procedures in place to identify, challenge and address
unauthorized/unidentified persons?
Personnel Security
195
Does your facility have documented procedures in place to screen prospective employees and to
periodically check current employees?
Pre-Employment Verification
196
Does your facility verity application information, such as employment history and references,
prior to employment?
Background Checks / Investigations
197 How does your facility conduct background checks and investifations for prospective employees?
198
One emplyed, are periodic checks and reinvestifations performed based on cause, and/or the
secsitivity of the emplyee's position?
Personnel Termination Procedures
199
Does your facility have procedures in plac eot remove identification, facility, and system access
for terminated employees?
Procedural Security
Documentation Processing
200
Are documented procedures in place to ensure that all information used in the clearing of
merchandise/cargo is legible, complete, accurate, and protected against the exchange, loss or
introduction of erroneous information?
201 Does document control include safeguarding computer access and information?
Manifesting Procedures
202 Are documented procedures in place to help ensure the integrity of cargo?
Shipping and Receiving
203 Is cargo that is being shipped reconciled against information on the cargo manifest?
204
Is all cargo accurately described and are the weights, labels, marks,and piece count indicated and
verified?
205 Does your facility verify departing cargo against purchase or delivery orders?
206 Are drivers delivering or receiving cargo positively identified before cargo is received or released?
207
Are documented procedures in place to track the timely movement of incoming and outgoing
goods?
Cargo Discrepancies
208
Are all shortages, overages, and other significant discrepancies or anomalies resolvd and/or
investigated appropriately?
209
Are customs and/or other appropriate law enforcement agencies notified if anomalies, illegal or
suspicious activities are detected - as appropriate?
Physical Security
Fencing
210 Does perimeter fencing enclose the areas around cargo handling and storage facilities?
211
Is interior fencing within a cargo handling structure used to segregate domestic, international,
high value, and hazardous?
212 Is all fencing regularly inspected for integrity and damage?
Gates and Gate Houses
213 Are the gates through which vehicles and/or personnel enter or exit manned and/or monitored?
Parking
214
Are private passenger vehicles prohibited from parking in or adjacent to cargo handling and
storage area?
Building Structure
215 Are buildings constructed of materials that resist unlawful entry?
216 Is the integrity of structures maintained by periodic inspection and repair?
Locking Devices and Key Controls
217 Are all external and internal windows, gates, and fences secured with locking devices?
Lighting
218
Is adequate lighting provided inside and outside the facility including in the following areas:
entrances and exits, cargo handling and storage areas, fence lines and parking areas?
Alarms Systems and Video Surveillance Cameras
219
Are alarm systems and video surveillance cameras utilized to monitor premises and present
unauthorized access to cargo handling and storage areas?
Information Technology Security
Password Protection
220
Does your facility have automated systems for individually assigned accounts that require a
periodic change of password?
221 Does your facility have documented IT security policies, procedures, and standards in place?
222 Are they provided to employees in the form of training?
Accountability
223
Does your facility have a system in place to identify the abuse of IT including improper access,
tampering, or the altering of business data?
224 Are all system violators subject to appropriate disciplinary actions for abuse?
Security Training and Threat Awareness
225
Does your facility have a threat awareness program in place and is it maintained by security
personnel to recognize and foster awareness of the threat posed by terrorists and contraband
smugglers at each point in the supply chain?
226
Does your facility make employees aware of the procedures the company has in place to address
a security situation and how to report it?
227
Does your facility give additional training to employees in the shipping and receiving areas, as
well as those receiving and opening mail?
228
Does your facility undertake additional , specific training to assist employees in maintaining cargo
integrity, recognizing internal conspiracies, and protecting access controls?
229 Do these programs offer incentives for active employee participation?

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Monthly social audit version 2, date 06 09 14(lam mim)

  • 1. Facility Name: Address and Country of factory location: B Month: January Audit date: 24 -01-2018 Audited By: Abu Sayeed Md.Zakaria Company Title: Compliance Auditor E-Mail & Cell No : sayeedzakaria321@gmail.con & 01924649374 1. Compliance with Laws and Workplace Regulations Sl.No Question Yes No N/A Comment Responsible Person Corrective Action 1 Do you have policies and procedures for current information on all relevant laws and regulations? 2 Does your facility have a program to train relevant individuals regarding the changes for any new laws or revisions to existing laws and regulations? Are training materials are appropriate? 3 Does your facility sub-contract any of its production operations or any other operations? 4 How has your facility informed the sub-contractor of their obligations under the local labor law? 5 Does your facility keep evidence of how the sub-contractor(s) has/have been made aware of these requirements? 6 Does your facility keep receipt of sub-contractor acknowledgement of these requirements? 2. Prohibition of Forced Labor: 7 Does your facility have a qualified person responsible for communicating, deploying, and monitoring the practices of effectively prohibiting involuntary, forced or trafficked labor? 8 Does your facility have a program and materials used to train relevant individuals, including all individuals responsible for the hiring process, on the facility's policies and procedures prohibiting forced, involuntary, or trafficked labor? "SOCIAL COMPLIANCE AUDIT"
  • 2. 9 Are all employees working at this facility voluntarily? 10 Are employees' movements restricted? 11 Do security personnel act in a non-threatening manner? Are they posted for normal security reasons? 12 Are the doors and gates of your facility locked in normal business hour? 13 Does the factory have a qualified Electrician,If yes what is his name? 14 Does the facility prohibit all relevant individuals from coercing employees in any way, or unnecessary limiting employees' freedom of movements? 15 Is employee freedom of movement unimpeded upon their shift's conclusion? 16 Does the facility require all hiring documents, such as an employment application or contract to, 1) include a statement affirming that applicants are seeking employment voluntarily and are not under threat of any penalty, 2) be signed by each applicant, and 3) be maintained in the employee's personal file? 17 Does the facility obtain proof that anyone seeking employment is legally to work in the country of manufacture with national immigration laws? 18 Are all security service agreements free of any language or terminology that may imply the existence of forced, indentured, trafficked or involuntary labor confitions? 19 Do the job descriptions or individual contracts for security employees limit their tasks to normal security matters such as protection of facility property of facility personnel? 20 Does the facility issue wages/compensation directly to employees only? 21 Does the facility hold the identification papers, travel documents or passports of the employees? 22 Does your facility rquire any employee deposits or have any withholding payment practices? 23 Does your facility use prison labor? or is there any policy that is relevant to use/non-use of prison labor? 24 Are all work contracts signed by both parties (employer and employee)? 3. Prohibition of Child Labor: 25 Does your facility obtain proof of age documentation from all potential workers and review the documentation for authenticity prior to hiring and keep this age document in employee's personnel file for the length of time as required by law? 26 Does your facility has a interview questions check list to ask to the applicant?
  • 3. 27 Does your facility require a completed and signed employment application that includes the date of birth? 28 Does your facility have a assigned qualified person responsible for dealing with child labor practices? 29 Do the programs and materials used to train relevant individuals on the child labor practices, including all individuals responsible for the hiring process, cover the requirements: obtain age documentation, review age documentation for authenticity, and interview all prospective empolyees? 4. Prohibition of Harassment or Abuse: 30 Does your facility have a written policy on the prohibition of harassment, abuse, and corporal punishment? 31 Has your facility formally designated a qualified person for monitoring the harassment and abuse policies and procedures as prescribed by law? 32 Does the policy include resonable punitive repercussions for non-compliance and repeated non- compliance? 33 Does your facility have signed statements by your facility's management affirming their understanding of the facility's anti-harassment and abuse policies? 34 Does your facility communicate the policy on the prohibition of harassment and abuse to workers, and third party services (e.g., securith guard)? 35 If any incidents of harassment or abuse were reported, were they resolved in a timely manner? 36 Is there an effective and mandatory program to train relevant individuals, including all individuals responsible for the supervision of workers, on the facility's policies and procedures prohibiting all forms of harassment, abuse, and corporal punishment? 5. Compensation and Benefits: 37 Has your facility formally designated a qualified person for monitoring the payroll and benefit system and ensuring that wage rates and compensation calculations are adequately communicated to all workers in the facility? 38 Does your facility have practices to ensure employees are compensated consistent with their terms of employment and in accordance with local laws and regulations? 39 Does the lowest record of payment by your facility meet(or exceed) the legal minimum compensation? 40 Does your facility post legal minimum wage rates, benefit policies, and additional payment information in the native language of the facility workers?
  • 4. 41 Does your facility utilize and maintain an organized system of record keeping? 42 Does the facility produce and retain payroll records to support compensation, including overtime? 43 In case the facility pays its employees through wire transfers, do you produce and retain proof of bank statements showing all the transactions in a verifiable way? 44 Does your facility provide all employees with a pay record or stub which lists the components of the wage paid? 45 Are all legally mandated withholdings (e.g. taxes, social security, etc.) remitted to the government? 46 Are there any piece rate workers in the facility? 47 Does your facility have a written and coherent policy on piece rate compensation that ensures the piece rate compensation at leat satisfies the minimum compensation prescribed by law? 48 Do employees sign off on material counts or random independent recounts for piece rate systems? 49 Are employees provided with adequate communication of their legally mandated minimum compensation rights? The communication include: a) details description of the employees compensation and benefits at the time of employment? b) both a written and verbal explanation of wage calcuations provided at the time of employment? c) Changes to compensation rates or methods of wage calculations communicated timely and effectively? 6. Hours of Work: 50 Has your facility formally designated a qualified person for monitoring the working hour per day, per week and ensure that no employee works more than the legal limit? 51 Is there an effective and mandatory program to train relevant individuals, including all individuals responsible for production coordination and scheduling, to ensue that employees work not more than the legal maximum, including overtime ceilings? 52 At the time of hiring, are employees made aware of facility policies and procedures, specifically the legal limitaions on the maximum hours of work per day, week and month, both regular and overtime, and the maximum number of consecutive days they can legally be required to work?
  • 5. 53 Does your facility retain time records that reflect the day and date employees worked, the number of hours worked each day, and the employees' acknowledgements? 54 Does the facility have a written, rational and well communicated policy defining "urgent business needs"? 55 Are notifications of maximum regular and overtime hour policies visibly posted in the native language of your facility's workers and management personnel? 56 Does your facility require that all new workers, at the time of hiring, be made aware of the facility's policies on required hours of labor? 7. Prohibition of Discrimination: 57 Does your facility have a written policy that explicitly prohibits discrimination? 58 Does your facility have a written policy visibly posted in the languages of the employees and management personnel? 59 Does your facility have a formally designated qualified person with responsibility for communicating, deploying and monitoring the non-discrimination policy? 60 Is there an effective and mandatory program to train relevant individuals, including all individuals responsible for the supervisons of workers and for the hiring process, on the discrimination practices? 61 Are the facility's policy, practices and procedures on discriminatory behaviour effectively communicated to all employees? 62 Does your facility effectively communicate in wirting the requirements of this principle to third parties (industrial parks, export processing zones, free trade zones, sub-contractors etc.) that may recruit and screen applicants on its behalf? 63 Has your facility had any discrimination charges filed against it by employees, regulatory agencies or any outside agency during the past two years? 64 Does your facility prohibit mandory pregnancy testing as a condition of employment or continued employment? 65 Are workers with the same job and seniority paid the same rate, irrespective of gender, age, or other characteristics? 66 Do employees sign statements (statements may be included in an employment application or contract), written in the native language of the employees, affiriming their receipt and understanding of the facility's ani-discrimination practices? 8. Health & Safety:
  • 6. 67 Does your facility comply with all relevant health and safety laws and regulations? 68 Does your facility have all relevant government health, safety, and fire safety certificates/permist, insurance policies and any relevant correspondence or documents from government officials? 69 Does your facility undertake internal monitoring of your health and safety systems, including fire safety, to ensure your are following the written procedures and processes and meeting the requirements of all relevant laws? 70 Have risk assessments heen carried our throughout your facility, including fire risk assessments? 71 If there were any risks or deficiencies that were identified by the health, safety and fire risk assessment, were they corrected? 72 Does your facility conduct regular occupational health checks for hazardous job duties? 73 Is there an effective and mandatory program to train relevant individuals, including all individuals responsible for the supervisons of workers, on all the relevant occupational health and safety issues? 74 Does your facility have a written safety program, including written procedures to handle natural disasters, fire safety, and emergencies and industrial accidents? 75 Are the following safety documents maintained by your facility: a) Health and safety reports? b) Heavy machinery inspection? c) Maintenance reports? d) Fire extinguiser records, noting date inspection and expiration? e) Emergency drill records, noting date and detailed results? f) Work injury reports? g) Clinic logs, noting date and reason for visit? 76 Have any government agencies inspected your facility for compliance with safety and health regulations during the past two days? 77 Does your facility address the following occupational health and safety needs required by the relevant laws and regulations for the following:
  • 7. a) Heat stress/extreme temperatures? b) Paint spray/spot cleanding booths? c) Welding safety? d) Respirator safety? e) Blood borne pathogen program? f) Hearing (noise control program)? g) Indoor air quality? h) Cotton dust ventilation? i) Sanitary waste disposal? GENERAL BUILDING REQUIREMENTS 78 Does a visual inspection of your entire facility premises suggest any concerns anout the physical integrity of the facility? 79 What is the overall general appearance of your facility: Excellent, good, fair or unacceptable? 80 Is the overall general appearance of the maintenance shop acceptable and not in a condition that can cause serious injuty or harm? 81 Is trash properly disposed of both inside and outside the facility? 82 Are the toilets and washrooms in your facility in sanitary and serviceable condition and meeting minimum quantity required established by relevant laws? 83 Are exits unlocked during times when the facility is occupied to allow free, unobstructed exit from the facility? 84 Are any aisles blocked or restricting easy access to emergency exits? 85 Has your facility appropriately identified areas that , for fire safety purposes, should be designated as"non-smoking"? 86 Is your facility properly enforcing the "non-smoking" policy for areas so designated?
  • 8. 87 Does your facility maintain first aid supplies as required by law or if no legal requirement exits, as recommended by a local medical provider? 88 Are these first aid supplies available and accessible to all areas of the facility? 89 Is there clean drinking water and is it easily accessible at the facility? 90 Is drinking water provided at no cost to employees? 91 Is your facility's child care area opearted and maintained in a safe and healthy manner? 92 Is your facility's canteen/cafeteria opearted and maintained in a safe and healthy manner? PERSONAL PROTECTION EQUIPMENT (PPE) 93 Does your facility conduct hazard assessments to determine if any personal protective equipment is required? 94 If personal protective equipment is required, is it provided to affected employees, at no cost? 95 Are the PPE appropriate and adequate for the workers' job and in good condition? ELECTRICAL SAFETY 96 Is there a qualified electrician in your facility responsible for maintaining electrical safety? If not what is the facility doing to ensure electrical safety? 97 Does a visual inspection of the wiring indicate good general condition of the cabling, tidiness and no exposed or loose wires? 98 Does a visual inspection of the electrical boxes and cabinets verify: complete enclosures with covers provided, switches and outlets maintained in good working order, and all knockout/trips are in place? WORKER SAFETY AWARENESS 99 Does your facility maintain a safety committee comprised of workers and management, which holds qualrterly meetings and keeps minutes of proceedings? 100 Does your facility conduct an orientation health and safety and fire training for all new employees? 101 Does the training cover the following in regards t ofire safety? a) Workers are informed of the locations of fire alarm pull and button stations?
  • 9. b) Workers are informed of the locations of fire extinguishers in and near their work area? c) Workers have specific training concerning the dangers of smoke inhalation? d) Workers are informed of location of nearest exits and assembly points? 102 Is employee training conducted for first aid and safety? 103 Are first aid responders/emergency safety personnel identified and property trained? 104 Have selected employees been trained on the proper use of firefighting equipment? 105 Have all employees who have any contact with chemicals been trained on how to safely handle and dispose of the specific chemicals and eliminate fire risk? 106 Are MSDS available (in appropreate language) for all chemicals used by the facility? FIRE SAFETY 107 Does your facility have an emergency evacuation plan in the native language posted in view of the facility's workers? 108 Does your facility conduct regular emergency evacuation drills (at least once in a month)? 109 Does the facility have adequate numbers and locations of unimpeded emergency exits that open ourwards and lead to a safe assembly point? 110 Is the following safety equipment: a) visible b) appropriate in functionality and number? c) propertly distributed throughout the facility? d) easily accessible? e) properly mounted? f) unblocked and free of obstruction? g) fire extinguishers are appropriate for the class(es) for fires expected in the area? 111 Are the fire-fighting water hoses and connections in usable condition? 112 Does your facility have appropriate measures to ensure adequate water pressure for fire fighting water hoses and sprinkler systems? Sprinkler Valves
  • 10. 113 Are sprinkler valves in good working order? 114 Are all sprinkler heads kept unobstructed from storage or other materials? Fire Alarm Boxes 115 Are fire alarms clear, unobstructed, and identified? 116 Does the facility have a test schedule for all fire alarm boxes? 117 Are combustible scrap, debris, and waste materials stored in covered metal receptacles, and removed from the work site promptly? If not explain how they are stored. EMERGENCY EVACUATION 118 Are lighting and alarm systems adequate and fitted with back-up systems? Emergency Lighting 119 Is appropriate lighting in place in your facility? 120 Is the emergency power system working and in good condition? 121 Does the facility regularly conduct tests to ensure the system is functioning properly? Stairwells 122 Are all stairwell handrails in good condition? 123 Are all stair treads in good condition? 124 Are all stair widths in compliance with requirements of all relevant laws? 125 Are the stairways provided with artificial and emergency lighting? 126 Are stairwells completely clear of obstructions? 127 Does the facility ensure stairwells are not used for storage? CHEMICAL SAFETY 128 Does your facility have a chemical safety program?
  • 11. 129 Where applicable, does your facility properly store hazardous/toxic materials? 130 Does your facility have the required government storage and usage permits for chemicals, if required? 131 Does your facility maintain documentation for chemical labeling (including fire safety), chemical usage warning, and proper handling instruction? 132 Does your facility ensure that all solvent wastes and flammable liquids are properly stored (including being kept in closed containers when not in use) at all times and kept away from potential ignition sources? 133 Are the chemical storage areas free of ignition sources? BOILER & COMPRESSOR ROOMS 134 Is the location of the boiler room compressor room consistent with all relevant requirements? (If no local or national laws apply, please describe the location of the boiler and compressor room.) 135 Are there housekeeping and maintenance procedures in plance for the boiler and compressor rooms? 136 Are there any fuel leaks? 137 Are the boilers and compressors inspected and serviced periodically? 138 Are the boiler licenses valid and authentic? 139 Is the boiler operator certificate valid and authentic? 9. Free of Association & Collective Bargaining: 140 Does your facility have written policies and procedures that recognize and respect the right of employees to exercise their lawful rights of free association? 141 Does your facility have a designated qualified person with responsibility for communicating, deploying, and monitoring the freedom of association practices as prescribed by labor law? 142 Does your facility have a union, association, or collective representation of employees? 143 If a union or collective associateion which represents the employees exits, does facility consult with the worker representatives on any issues that are a requirement by law such as facility disclosures, mass lay-offs, restructuring of the business etc.? 144 If the workers do have an organized group that addresses workplace issues, does this wrokers' group operate free from coercion or illegal restrictions to its operations?
  • 12. 145 If a lawful association exits, is there any bargaining agreement or labor-management negotiation on workplace issues? 146 Are there formal communication procedures between worker representative and management? 147 Does your facility enter into discussions with the workers representatives in an open manner and within the terms of local law? 148 Are minutes of facility / worker representative meetings documented and available to the workers? 149 Are workers representatives elected on a free and confidential basis by the workers? 150 Does your facility discriminate against employees who form or participate in lawful associateions? 151 Does your facility discriminate against those who choose not join any association? 152 Does your facility communicate its policies and practices pertaining to this Principle to all facility employees and third parties that may perform recruitment or screening of applicants? 10. Environment: 153 Does your facility have an environmental management system relevant to its industry? 154 Does your facility have a designated qualified person with responsibility for communicating, deploying, and monitoring the environment practices elaborated upon in the environmental management system? 155 Does your facility have a program and materials used to train relevant individuals on each practice of the environmental management system? 156 Does your facility assess its ability to prevent and control harmful releases of industrial waste into the environment as a part of the environmenatal managemnt system? 157 Does your facility maintain a detailed plan for handling accidental release or discharge of environmentally dangerous materials? 158 Does your facility maintain records of emission events? 159 Does your facility's environmental management system address where and how solid, chemical, sanitary and wastewater substances are disposed? 160 Does the facility adequately communicate to all facility employees the relevant local and national laws and regualtion sas well as pertinent facility procesures concerning th e environemnt principle? 11. Customs Compliance:
  • 13. 161 Does your facility keep copies of all applicable customs laws and regulations? 162 Does your facility's policies and procedures on customs compliance cover the following requirements: Compliance with all applicable customs laws and maintains practices to comply with customs laws regarding illegal transshipment of poructs. In the event possible illegal transshipment actiivity, appropriate host government agency will be notified? 163 Monitors its productions on a per style basis? 164 Traces country of origin using records such as production, shipping, verification reports, quality control reports, and individual piecework sheets, for all inputs? 165 Varifies production on an ongoing basis on site and at sub-contracting facilities? 166 Maintains a facility machine inventory and updates it annually? 167 Ensures that the proper category designation is determined for all goods destined fo rthe US market. 168 Does your facility maintain an organized system of production documentation? 169 Are the following records maintained? a) Records of the country of origin for all goods produced in this facility. b) A production profile of any subcontracting facility. This facility requests documents from the subcontracting facilities when questions regarding goods produced at those facilities arise. c) Production/purchase orders ( with information such as conditions of production, payment, and finished product specifications). d) Raw materials invoices (indicating country/origin/manufacturing facility). e) Shipping / receiving documents (outgoing and incoming records of components/inputs sent to or received from another facility). f) Employee work records - accurate records of emplyee work hours that can be linked to the production of specific products. g) Quality control records (which may include facility name and address, purchase order number, style number, date of the quality check, buyer, name, stamp or signature of inspector, comments on production).
  • 14. h) Export documents (including: packing list, manifest, bill of lading/airway bill from truck, ship, plane or train indicating the export date, exporting entity, destination, shipping lines, importing entity, and any charges incurred). i) Outward processing production ( if applicable, copies of the ourward processing program disignated by the domestic government, copies of compliance review reports, documentation demonstrting the flow of goods from one facility to another). j) Number of units produced marked with a traeable mark. k) Documentation on how the qualified person with responsibility for the Principle communicates, deploys, and monitors the facility's customs compliance policies? 170 Has the facility designated a qualified person with responsibility for communicating, deploying and monitoring customs compliance? 171 Does the responsible person ensure that such origin determining documents are maintained for at least the period of record retention required by law? 172 Does the responsible person ensure that all subcontracting facilities complete a production profile and keeps such profiles on file? 12. Security: 173 Does your facility have practices to guard against the introduction of contraband (e.g. drugs explosives, biohazards, and/or other contraband; any non-manifested cargo will be referred to as contraband.)? 174 Has your facility designated a qualified person with responsibility for communicating, deploying, and monitoring security policies and procedures? Container and Trailer Security Container Inspection 175 Does your facility have documented procedures in place to verity the physical integrity of the container structure prior to loading? 176 Does the procedure include the reliability of the locking mechanisms of the doors? 177 Does the facility conduct a seven-point inspection process (see list below) for all containers and keep records of all inspections? a) Front wall
  • 15. b) Left side c) Right side d) Floor e) Ceiling/Roof f) Inside/outside doors g) Outside/Undercarriage Trailer Inspection 178 Does your facility have procedures in place to verify the physical integrity of the trailer structure prior to loading, including the reliability of the locking mechanisms of the doors? 179 Is the facility following five-point inspection process is recommended for all trailers? a) Fifth wheel area - check natural compartment / skid plate b) Exterior - Front/sides c) Rear - bumpers/doors d) Front wall e) Left side Container & Trailer Seals 180 Does your facility affix a high security seal to allloaded trailers and containers bound for the US? 181 Do seals meet or exceed the current ISO 17712 standards for high security seals? 182 Does your facility have documented procedures stipulating how seals are to be controlled and affixed t loaded containers and trailers? 183 Does your facility have designated employees for the distribution of seals for integrity purposes?
  • 16. Container & Trailer Storage 184 Is the secutiry of containers and trailers located within the facility maintained? 185 Are they in a secure area to prevent unauthorized access and/or manipulation? 186 Does your facility have documented procedures in plac efor reporting and reutralizing unauthorized entry into containers/trailer storage areas? Physical Access Controls 187 Does your facility have a physical access control procedure? Employees 188 Does your facility have an employee identification system in palce for positive identification and access control purposes? 189 Does your facility ensure that employees are only given access to those areas needed for the performance of their duties? 190 Does your facility control the issuance and removal of employee, visitor and vendor identification badges? 191 Does your facility have documented procedures for the issuance, removal and chanding of access devices(e.g. keys, key cards, etc.)? Visitors 192 Does visitors present photo identification for documentation purposes upon arriaval? 193 Is vendor ID and/or photo identification required to be presented for documentation purposes upon arrival by all vendors? Challenging and Removing Unauthorized Persons 194 Does your facility have documented procedures in place to identify, challenge and address unauthorized/unidentified persons? Personnel Security 195 Does your facility have documented procedures in place to screen prospective employees and to periodically check current employees? Pre-Employment Verification
  • 17. 196 Does your facility verity application information, such as employment history and references, prior to employment? Background Checks / Investigations 197 How does your facility conduct background checks and investifations for prospective employees? 198 One emplyed, are periodic checks and reinvestifations performed based on cause, and/or the secsitivity of the emplyee's position? Personnel Termination Procedures 199 Does your facility have procedures in plac eot remove identification, facility, and system access for terminated employees? Procedural Security Documentation Processing 200 Are documented procedures in place to ensure that all information used in the clearing of merchandise/cargo is legible, complete, accurate, and protected against the exchange, loss or introduction of erroneous information? 201 Does document control include safeguarding computer access and information? Manifesting Procedures 202 Are documented procedures in place to help ensure the integrity of cargo? Shipping and Receiving 203 Is cargo that is being shipped reconciled against information on the cargo manifest? 204 Is all cargo accurately described and are the weights, labels, marks,and piece count indicated and verified? 205 Does your facility verify departing cargo against purchase or delivery orders? 206 Are drivers delivering or receiving cargo positively identified before cargo is received or released?
  • 18. 207 Are documented procedures in place to track the timely movement of incoming and outgoing goods? Cargo Discrepancies 208 Are all shortages, overages, and other significant discrepancies or anomalies resolvd and/or investigated appropriately? 209 Are customs and/or other appropriate law enforcement agencies notified if anomalies, illegal or suspicious activities are detected - as appropriate? Physical Security Fencing 210 Does perimeter fencing enclose the areas around cargo handling and storage facilities? 211 Is interior fencing within a cargo handling structure used to segregate domestic, international, high value, and hazardous? 212 Is all fencing regularly inspected for integrity and damage? Gates and Gate Houses 213 Are the gates through which vehicles and/or personnel enter or exit manned and/or monitored? Parking 214 Are private passenger vehicles prohibited from parking in or adjacent to cargo handling and storage area? Building Structure 215 Are buildings constructed of materials that resist unlawful entry? 216 Is the integrity of structures maintained by periodic inspection and repair? Locking Devices and Key Controls 217 Are all external and internal windows, gates, and fences secured with locking devices?
  • 19. Lighting 218 Is adequate lighting provided inside and outside the facility including in the following areas: entrances and exits, cargo handling and storage areas, fence lines and parking areas? Alarms Systems and Video Surveillance Cameras 219 Are alarm systems and video surveillance cameras utilized to monitor premises and present unauthorized access to cargo handling and storage areas? Information Technology Security Password Protection 220 Does your facility have automated systems for individually assigned accounts that require a periodic change of password? 221 Does your facility have documented IT security policies, procedures, and standards in place? 222 Are they provided to employees in the form of training? Accountability 223 Does your facility have a system in place to identify the abuse of IT including improper access, tampering, or the altering of business data? 224 Are all system violators subject to appropriate disciplinary actions for abuse? Security Training and Threat Awareness 225 Does your facility have a threat awareness program in place and is it maintained by security personnel to recognize and foster awareness of the threat posed by terrorists and contraband smugglers at each point in the supply chain? 226 Does your facility make employees aware of the procedures the company has in place to address a security situation and how to report it? 227 Does your facility give additional training to employees in the shipping and receiving areas, as well as those receiving and opening mail?
  • 20. 228 Does your facility undertake additional , specific training to assist employees in maintaining cargo integrity, recognizing internal conspiracies, and protecting access controls? 229 Do these programs offer incentives for active employee participation?