ILS Social Compliance Audit

Transcription

1 V ILS Social Compliance Audit Audit ID #: A Date Audit Conducted Yr/Mo/Day: Code Conducted to: Disney Audit Report Date Yr/Mo/Day: Audit Type Initial First F/U Second F/U Third F/U F/U Facility Information Facility ID No. Facility Name: NA Alancos S.R.L. Address Line 1: Lavalle 1892 Address Line 2: Address Line 2: City: Buenos Aires State/Province: Buenos Aires Town: Villa Maipú, San Martin Country: Argentina Postal Code: 1650 GPS Location: Contact Last Name: Yramis Contact First Name: Lugones Portal Primary r Telephone: (011) Contact Person Title: Manager Fax: (011) Name/Address/Ownership Updates Facility Name: ALANCOS S.R.L. Facility Address: Lavalle 1892, Villa Maipú, San Martín Facility Ownership Update: Upcoming Relocation or Expansion:

2 Audit Team Audit Firm Lead/ Exclusive Auditor Intertek NA Number of Auditors 2 Audit Team Member 1 Ana Capelle Audit Team Member 2 Jorge Garramuño Audit Team Member 3 Audit Team Member 4 Audit Team Member 5 Audit Team Member 6 Audit Team Member 7 Audit Team Member 8 Audit Details & Assessment Facility Details Access to Facility: Accepted Denied Denied by phone Predetermined Comments Unable to Access No fault of facility Auditors attempted to conduct an audit and were denied access. Additional Comments Current % Capacity Devoted to Disney Products Produced Disney Products Observed: None 0% Past % Capacity Devoted to Disney Cosmetics None 0% Production Processes: Fractionation quality control and packaging # Total Employees: 3 #Production Employees: # Buildings 1 3 # Buildings by Purpose 1/Production, Administration, Deposit /01

3 Peak Production Months: Unknown None April May September October January June November February July December March August Low Production Months: Unknown None April May September October January June November February July December March August Facility Regular Hours Brands Present? Establishment Date Yr/Mo/Day NA Facility # of Shifts/Hours Wal-Mart, El Pocket, Eco Hear and Novarsa. 2003/01/01 #1/ 08:00-12:30 Audit Details Attendance Records Reviewed: Unknown April September None May October January June November February July December March August Payroll Ledgers Reviewed: Unknown April September None May October January June November February July December March August Last Pay Date Yr/Mo/Day 31/07/15 Number of Records Sampled: 9 # Individual Employee Interviews 3 # Employee Group Interviews 0 Numbers per Group /01

4 Additional Locations Audited? No Yes; Location under same business license Yes; Locations not under same business license Yes; unknown Explain Additional Location Details: Comments/Observations: None Communicated Findings With: Yramis Lugones Portal Agreed to and Signed CAPAR? Yes No Unknown Audit Entered by (Name) NA Comments Details Comments: Name and Title of s Present (ex. translators, observers, trainees): None Attendance Records Provided: Current: July , June , May Payroll Records Provided: 12 / June 2014-July 205 Number of Records Sample: 3 Resources Received from Facility (i.e. transportation, meals): None Factory Representative in opening meeting (name/title): Yramis Lugones Portal / Manager Factory Representative in closing meeting (name/title): Yramis Lugones Portal / Manager (Note: other comments may include but not limit to: details if Agreed to and signed CAPAR is indicated No ; further details regarding audit scope; special observation or comments on the audit process; etc.) /01

5 Audit Violations Age Requirement Child Labor: Needs Improvement Unable to Verify Compliance with minimum age requirements could not be verified because complete proof-of-age documents were not provided. One or more employees are younger than 16 years of age. Additional Comments: Non concern on this issue it was detected. The company complies with Law No which forbids child labor. The youngest employee has 26 years old. : Needs Improvement Unable to Verify Facility management did not ensure the safe return of previously hired underage worker(s) to his/her parents or legal guardians. One or more employees were less than 16 years of age when hired. Additional Comments: No apparent violations. All pertinent documents were examined. Young Persons: Needs Improvement Unable to Verify /01

6 A register of juvenile employees is not maintained. Juvenile employees are assigned normal work hours or overtime hours prohibited by local law. Juvenile employees are assigned to jobs that are prohibited by local law. Juvenile employees are assigned to work with harmful substances. Juvenile employees are not provided regular health examinations. Juvenile employees are not registered with the local Labor Bureau. Juvenile employees are required to pay for their own health examinations. Juvenile employees have not obtained tokens and fitness certificates. Additional Comments: No apparent violation. It was confirmed by the documents review and audit interviews. There is no evidence of any young worker in the present or in the past. The youngest employee is 26 years old /01

7 Association: Needs Improvement Unable to Verify Collective bargaining agreement has not been established. Employees are punished and/or dismissed for participating in labor strike. Employees are punished and/or dismissed for participating in union activities. Additional Comments:During the document review it was noted in the facility there is one collective bargaining. There are no employees representatives at the facility.during the interviews the employees mentioned they have freedom of association without any restriction. The union collective bargaining is: Sindicato de Trabajadores Perfumistas CCT 157/ /01

8 Coercion and Harassment: : Needs Improvement Unable to Verify Employees were intimidated by facility management during interviews with auditors. Employees were verbally abused by facility management. Employees who disagree with job arrangements are restricted from working overtime. The training for protecting women against harassment in the workplace is not provided. Additional Comments: No apparent violations. Physical Abuse or Sexual Harassment: Needs Improvement Unable to Verify Employees were physically abused by facility management. Employees were sexually harassed. Additional Comments: No apparent violations. During the audit interviews it was noted employees do not receive any physical abuse or sexual harassment. Additionally, during the facility tour it was verified the conditions for working are properly and without any kind of abuses /01

9 Compensation: Minimum Wage: Needs Improvement Unable to Verify Employees are dismissed during the probation period without pay. Employees were not compensated for downtime. Employees are paid less than minimum wage. Additional Comments: No concern on this issue was detected. During the audit interviews it was noted employees are paid taking into account the Minimum Wage. Minimum Legal Wage is ARS $4.996,50 per month as per the Collective Bargaining Agreement. Remarks: Local minimum wage standard: (wage per hour or per month): ARS $4996, 50 per month. Overtime Hours: Needs Improvement Unable to Verify Employees worked in excess of 60 hours per week for more than 17 weeks per year. Employees worked in excess of 72 hours per week. Employees worked in excess of six consecutive days without a day of rest. Employees worked in excess of the legal daily overtime hour limit. Employees worked in excess of the legal monthly overtime hour limit. Employees worked in excess of the limits allowed by the comprehensive work hour system /01

10 The facility's normal work hours exceed the legal limit. Additional Comments: During the document review it was noted employees do not work overtime hours. The normal hours worked per week are 22,5 hours. This do not exceed the legal limit. Through reviewing of the provided timecards, working hour statistics was as the following: 1) For July 2015 (Current month), The maximum weekly working hours were 22, 50 hours (3 out of 3 samples). The maximum monthly overtime were 0 hours per month (3 out of 3 samples). 2) For June 2015, The maximum weekly working hours were 22,50 hours (3 out of 3 samples).the maximum monthly overtime were 0 hours per month (3 out of 3 samples). 3) For May 2015, The maximum weekly working hours were 22,50 hours (3 out of 3 samples).the maximum monthly overtime were 0 hours per month (3 out of 3 samples). Remarks: Attendance Recorded by: (automated/electronic, timecard, manual, no recording, etc.): Manual sheet Overtime Wage: Needs Improvement Unable to Verify Employees are not properly compensated for hours worked on statutory holidays. Employees are not properly compensated for overtime. Additional Comments: During document review it was noted employees do not work overtime hours. Social Benefits and Compensation /01

11 Needs Improvement Unable to Verify A child care facility is not provided. Employee benefit contributions are not made in a timely manner. Employees are charged for work-related necessities. Employees are fined for taking unauthorized leave. Employees are fined for violating facility rules. Employees are not compensated for unused annual leave. Employees are not fully compensated for downtime. Employees are not paid at the time of resignation. Employees are not properly compensated for sick leave. Employees are not properly compensated for statutory holidays. Employees are not properly compensated for work-related injury leave. Employees are not provided all required paid annual leave. Employees are not provided the required paid statutory holidays. Employees are not provided the required paid work-related injury leave. Employees are not provided the required sick leave. Employees are not provided with an Agreement of the Board of Directors of the Workers' Recreational Institute (IRTRA) card. Employees pay for their own health examinations. Employees who are nursing do not receive the required break periods. Employees who resign are not paid at the time of resignation. Employees work on required paid rest days. Employees' wages are deducted for arriving late. Facility management deducts fees from employees' wages. Female employees are not provided paid maternity leave. Male employees are not provided paid paternity leave /01

12 Not all employees receive all required social insurance benefits. Not all employees receive the required medical benefits. Proof that the facility-provided healthcare complies with legal requirements was not provided. Provident Fund deductions are not calculated correctly. Retirement fund contributions are not properly collected and/or Social security benefit deductions are not based on the employee's total wages. The cafeteria size is insufficient for the number of employees. Wages are not paid within the legal time limit. Additional Comments: No apparent violations. Based on the Pay Slips and Impositive Payment of Social Benefits, the facility fulfills with the Legal Requirements. Remarks: Regular Pay Date: Monthly Wage pay in/by (cash, check, direct deposit, etc.): Deposit in a bank account of Banco Credicoop /01

13 Health and Safety: Dormitories: Needs Improvement Unable to Verify A fire alarm system is not installed. A fire alarm with visual signals is not installed. A fire prevention and firefighting program has not been established. A firefighting brigade has not been established. A first aid brigade has not been established. A proper ventilation system is not installed. Adequate privacy is not provided. An evacuation assembly point has not been established and marked. Authorization letters for the facility doctor and the health and safety expert are not available. Bathrooms are not maintained in a sanitary condition. Bathrooms are not marked by gender. Bathrooms are not stocked with soap and paper. Bathrooms do not have doors for privacy. Blade guards installed on electric fans are insufficient. Combustible materials are stored in evacuation stairwells. Contact information for first aid personnel is not posted. Dormitory areas are not maintained in a sanitary condition. Drinking water is not located in a suitable area. Drinking water is not periodically tested. Electrical devices are not properly insulated. Electrical panels are obstructed. Electrical wiring and switches are not properly covered. Electrical wiring is not properly insulated. Emergency exit doors are locked. Emergency exit doors are obstructed. Emergency exit doors are rolling and/or sliding doors. Emergency exit doors do not open in the direction of evacuation. Emergency information is not displayed. Emergency lights and illuminated exit signs are not installed in some areas. Emergency lights and illuminated exit signs are not installed. Emergency lights are not connected to the electrical supply. Emergency lights are not installed in some areas. Emergency lights are not installed. Emergency lights are not regularly inspected. Emergency lights do not function. Emergency procedures have not been established. Employees cook in dormitory rooms. Employees do not receive firefighting training. Employees do not receive first aid training. Employees use high-powered electrical appliances in the dormitory rooms. Evacuation passages are not clearly marked. Evacuation passages are obstructed. Evacuation passages are too narrow. Evacuation plans are not posted in some areas. Evacuation plans are not posted. Evacuation routes are not clearly marked. Evacuation signs are installed too high. Evacuation signs are not installed in some areas /01

14 Evacuation signs are not installed. Evacuation signs are not visible. Evacuation signs do not function properly. Evacuation signs installed are not the illuminated type. Exit signs are not installed in some areas. Exit signs are not installed. Exit signs are not visible. Exit signs do not function properly. Exit signs installed are not the illuminated type. Fire alarm switches are not installed in some areas. Fire alarm switches are not installed. Fire drill records do not contain detailed information. Fire drill records were not provided for review. Fire drills are not conducted. Fire drills are not regularly conducted. Fire extinguisher locations are not marked. Fire extinguishers are covered in rust. Fire extinguishers are not accessible due to improper mounting or installation. Fire extinguishers are not distributed throughout the facility. Fire extinguishers are not properly maintained. Fire extinguishers are not provided in some areas. Fire extinguishers are not provided. Fire extinguishers are not regularly inspected. Fire extinguishers are obstructed. Fire extinguishers are placed directly on the floor. Fire extinguishers do not function properly. Fire extinguishers do not have operating instructions in the local language. Fire extinguishers provided are the incorrect type. Fire hydrants are not connected to the electrical supply. Fire hydrants are not connected to the water supply. Fire hydrants are obstructed. Fire safety measures are non-existent. Fire safety signs are not posted in some areas. Fire safety signs are not posted. Fire safety training is not provided. Fire safety training records are not provided. Firefighting equipment is not regularly inspected. First aid kits are locked. First aid kits are not adequately stocked. First aid kits are not provided in all areas. First aid personnel are not on staff. Gas cylinders are stored too close to a heat source. Heating facilities are installed under the stairwell. Hot water is not provided in the dormitory. Illuminated exit signs are not installed in some areas. Illuminated exit signs are not installed. Incompatible fire extinguishers are installed together. Open electric wires were found near water. Some areas of the dormitory building are being used for production. Some areas of the production building are used as dormitories. The audit report and / or certificate for completed construction projects were not provided for review. The dormitories are not separated by gender. The dormitories are overcrowded /01

15 The fire acceptance approval document is not available for review. The fire service certificate is expired. The fire service certificate provided does not include all buildings. The fire service certificate was not provided for review. The number of emergency exits provided is insufficient. The number of fire extinguishers provided is insufficient. The number of toilets is insufficient. Toilets are not equipped with seats and lids. Toilets do not function. Warning signs are not posted on electrical panels. Warning signs posted on electrical panels do not meet legal requirements. Water and sand buckets are not provided near the generator. Additional Comments: There are no dormitories. Fire & Emergency Safety: Needs Improvement Unable to Verify A fire alarm is not installed. A fire alarm with visual signals is not installed. A fire prevention and firefighting program has not been established. A firefighting brigade has not been established. An evacuation assembly point has not been established and marked. Combustible materials are stored in evacuation stairwells. Emergency exit doors are locked. Emergency exit doors are obstructed. Emergency exit doors are rolling and/or sliding doors. Emergency exit doors do not open in the direction of evacuation. Emergency information is not displayed. Emergency lights and illuminated exit signs are not installed in some areas. Emergency lights and illuminated exit signs are not installed. Emergency lights are not connected to the electrical supply. Emergency lights are not installed in some areas. Emergency lights are not installed. Emergency lights are not regularly inspected. Emergency lights do not function. Emergency procedures have not been established. Employees do not receive firefighting training. Evacuation passages are not clearly marked. Evacuation passages are obstructed. Evacuation passages are too narrow. Evacuation plans are not posted in some areas. Evacuation plans are not posted. Evacuation routes are not clearly marked. Evacuation signs are installed too high. Evacuation signs are not installed in some areas. Evacuation signs are not installed. Evacuation signs are not visible /01

16 Evacuation signs do not function properly. Evacuation signs installed are not the illuminated type. Exit signs are not installed in some areas. Exit signs are not installed. Exit signs installed are not the illuminated type. Fire alarm switches are not installed in some areas. Fire drill records do not contain detailed information. Fire drill records were not provided for review. Fire drills are not conducted. Fire drills are not regularly conducted. Fire extinguisher locations are not marked. Fire extinguishers are not accessible due to improper mounting or installation. Fire extinguishers are not distributed throughout the facility. Fire extinguishers are not properly maintained. Fire extinguishers are not provided in some areas. Fire extinguishers are not provided. Fire extinguishers are not regularly inspected. Fire extinguishers are obstructed. Fire extinguishers are placed directly on the floor. Fire extinguishers do not function properly. Fire extinguishers do not have operating instructions in the local language. Fire extinguishers provided are the incorrect type. Fire hydrants are not connected to the electrical supply. Fire hydrants are not connected to the water supply. Fire hydrants are obstructed. Fire safety measures are non-existent. Fire safety signs are not posted in some areas. Fire safety signs are not posted. Fire safety training is not provided. Fire safety training records are not provided. Firefighting equipment is not regularly inspected. Gas cylinders are stored too close to a heat source. Heating facilities are installed under the stairwell. Illuminated exit signs are not installed in some areas. Illuminated exit signs are not installed. Incompatible fire extinguishers are installed together. Materials are stacked too close to ceiling light fixtures. Materials are stacked too high. Materials in the warehouse are stacked against posts and walls. Materials in the warehouse are stacked too closely together. Non-explosive lights are not installed in the warehouse. Some materials are stacked in a precarious manner and appear ready to collapse. The fire acceptance approval document is not available for review. The fire service certificate is expired. The fire service certificate provided does not include all buildings. The fire service certificate was not provided for review. The number of emergency exits provided is insufficient. The number of fire extinguishers provided is insufficient. Water and sand buckets are not provided near the generator /01

17 Additional Comments: During the facility tour it was noted the facility has all the neccessary fire equipment. The facility has evacuation maps, emergency lights, fire extinguishers, signals. Every employee is trained on fire issues. The last evacuation drill was performed on 21/11/14. Hazardous Material: Needs Improvement Unable to Verify A hazardous chemical study has not been conducted. Chemical containers are not properly and clearly marked. Chemical emergency drills are not conducted. Chemical safety training is not provided. Chemical safety training records were not provided for review. Chemicals are not properly and clearly marked. Chemicals are not stored in a separate storage area. Chemicals are not stored in proper containers. Dangerous chemical emergency drills are not conducted. Dangerous chemical emergency plans are not available. Empty chemical containers are not properly stored. Explosion-proof electrical devices are not installed where chemicals are stored. Material Safety Data Sheets (MSDS) are not available for chemicals. Secondary containment is not provided for chemicals. Warning signs are not posted in areas requiring Personal Protective Equipment (PPE). Warning signs are not posted where occupational disease hazards are produced. In accordance with the Argentinean Health and Safety Law N and National Decree 351/79, Article 8, Section a), facility buildings, equipment and installations must avoid any kind of risk, particularly for prevent work accidents (abolished by decree 1338/96), and the National Decree 351/79, article 145/148, all facilities that make, use, or manipulate containers having hazardous and dangerous substances must provide methods to avoid spills, that could cause any risk to the employee. In case of loss or spills an appropriated action safety plan should be faced, depending on the nature of the establishment and the text will be displayed in a visible place. Additional Comments: During the facility tour, auditors noticed that in the area of warehouse of chemical products does not find a system of secondary containment in case of spillage. Machine & Electrical Safety: Needs Improvement Unable to Verify A machinery risk analysis has not been conducted /01

18 Blade guards installed on electric fans are insufficient. Common daylights are not equipped with protective covers. Cutting machines are not equipped with dual button control devices. Electrical devices are not properly insulated. Electrical panels are not equipped with protective covers. Electrical panels are not fenced. Electrical panels are obstructed. Electrical wiring and switches are not properly covered. Electrical wiring is not properly insulated. Equipment is not registered. Handrails are not the correct height. Lights in the chemical storage areas are not explosion proofed. Machine operators' certificates are expired. Machine operators' certificates were not provided for review. Machinery maintenance records are not maintained. Machinery warning signs are not posted in the local language. Machines are not equipped with safety devices. Machines are not properly maintained. Machines are not regularly inspected. Non-explosive lights are not installed in the warehouse. Open electric wires were found near water. Rubber mats are not provided in front of electrical panels. Sharp tools are not fastened to their respective workstations. Special equipment operators have not received the periodic training required to keep their certifications current. Stairs are not equipped with handrails. Stairs on the injection machine(s) are not equipped with guardrails. The electrician is not licensed. The electrician's license is expired. The electrician's license is not regularly inspected. The electrician's license was not provided for review. The generator installation permit has not been obtained. Warning signs are not posted near machines. Warning signs are not posted on electrical panels. Warning signs posted on electrical panels do not meet legal requirements. Additional Comments: No concern on this issue was detected. All Machines are provided with different Security Protections in order to avoid Risks and Accidents. Regarding to the Electrical Safety, during the facility tour it was verified a Correct and Safety Electrical Installation. Medical & First Aid: Needs Improvement Unable to Verify A medical clinic is not available. Authorization letters for the facility doctor and the health and safety /01

19 expert are not available. Contact information for first aid personnel is not posted. Employees do not receive first aid training. Eye wash stations are not installed where chemicals are used and stored. Eye washing facilities are not easily accessed. Eye washing facilities do not function properly. First aid kits are locked. First aid kits are not adequately stocked. First aid kits are not provided in all areas. First aid kits are not provided. First aid personnel are not on staff. Additional Comments: No concern on this issue was detected. During the document review it was noted employees are trained in first aid issues. : Needs Improvement Unable to Verify A drinking water point is not marked. A health and safety commission has not been established. A procedure for working at heights has not been established. A proper ventilation system is not installed. A risk analysis procedure for new components and products has not been established. A work safety officer is not on staff. Accident and injury records are not maintained. An Accident Register is not maintained. An Accident and Injury Register is not maintained. An amended building plan and certificate of stability have not been obtained. Anti-fatigue mats are not provided to employees who stand while working. Auditors were not allowed to conduct a health and safety inspection of subleased areas of the facility. Employees are exposed to unacceptable noise levels. Employees do not receive basic health and safety training. Employees do not receive periodic occupational health examinations. Employees worked an exceptionally high number of overtime hours. Environment, Health and Safety (EHS) meetings are not conducted. Guardrails are not the correct height. Loading and unloading areas are not properly marked. Mirrors are not installed at intersections to prevent traffic accidents. Occupational hazards factors testing is not conducted annually /01

20 Risk analyses are not conducted. The audit report and / or certificate for completed construction projects were not provided for review. The loading platform is not equipped with a guardrail. The work safety officer's certificate is expired. Ventilation is insufficient in some areas. Ventilation is insufficient. Additional Comments: No apparent violations Personal Protective Equipment (PPE): Needs Improvement Unable to Verify Employees are not provided with Personal Protective Equipment (PPE). Employees are not provided with proper Personal Protective Equipment (PPE). Employees do not receive training on proper usage of Personal Protective Equipment (PPE). Employees do not wear provided Personal Protective Equipment (PPE). Personal Protective Equipment (PPE) training records were not provided for review. Warning signs are not posted in areas requiring Personal Protective Equipment (PPE). Additional Comments: No concern on this issue was detected. During the facility tour it was observed every employee uses the correspondient PPE. Sanitation: Needs Improvement Unable to Verify Bathrooms are not maintained in a sanitary condition. Bathrooms are not marked by gender. Bathrooms are not stocked with soap and paper. Bathrooms do not have doors for privacy. Drinking water is not located in a suitable area. Drinking water is not periodically tested. Employees drink water in the presence of dust and toxic fumes. Kitchen employees do not have valid health certificates /01

21 Production areas are not maintained in a sanitary condition. The canteen does not have a catering service license. The canteen's catering service license is expired. Toilets are not equipped with seats and lids. Toilets do not function. Additional Comments: No concern on this issued it was detected. Throughout the facility tour it was observed that hygienic conditions in restrooms, dressing rooms and dining room are optimal /01

22 Involuntary Labor: Mandatory Overtime: Needs Improvement Unable to Verify Employees are fined for refusing to work overtime. Overtime is not voluntary. Additional Comments: No apparent violations. During the audit interviews it was noted employees have freedom to leave they work when finish and to perform overtime hours only voluntary. : Needs Improvement Unable to Verify Employee access to the dormitories is restricted. Employee access to the restroom is restricted. Employee movement is restricted during working hours. Employees have difficulty obtaining resignation approval. Employees who resign without approval must forfeit wages. Facility management collects a deposit from employees' wages and does not return it until the employee has worked for a specified time period. Facility management retains employees identification documents. The resignation notice required of employees exceeds the legal requirement. Additional Comments: No apparent violations. Prison, Bonded, Indentured, Forced Labor: Needs Improvement Unable to Verify The facility utilizes prison labor for some or all production /01

23 Additional Comments: No apparent violations /01

24 Monitoring and Compliance: Ethics: Needs Improvement Unable to Verify Facility management attempted to influence auditors through intimidation. This audit reveals that undue influence occurred during the audit process. Additional Comments: At no time auditors were intimidated during the audit process. The treatment received by the management was coordial. Insufficient or Inadequate Records: Needs Improvement Unable to Verify Attendance records and payroll ledgers are not signed by employees for acknowledgement. Attendance records do not contain detailed in and out times and are not signed by employees for acknowledgment. Auditors attempted to conduct an audit and were denied access to required documents. Bank transfer statements are not maintained. Compliance with social benefit requirements could not be verified because discrepancies were noted between social insurance payment receipts and government records. Compliance with social benefit requirements could not be verified because social insurance payment receipts provided are incomplete. Compliance with social benefit requirements could not be verified because social insurance payment receipts were not available for review. Compliance with social insurance benefits could not be verified because the number of employees provided social insurance benefits could not be determined. Compliance with wage requirements and overtime hour limitations could not be verified because attendance records and payroll ledgers are not signed by employees for acknowledgement. Compliance with wage requirements and overtime hour limitations could not be verified because attendance records do not contain detailed in and out times and are not signed by employees for acknowledgment. Compliance with wage requirements and overtime hour limitations could not be verified because bank transfer statements are not maintained. Compliance with wage requirements and overtime hour limitations could not be verified because not all required attendance records and payroll ledgers were available for review /01

25 Compliance with wage requirements and overtime hour limitations could not be verified because payroll ledgers are neither signed by employees nor stamped by the bank for acknowledgment. Compliance with wage requirements and overtime hour limitations could not be verified because the attendance system does not record actual time worked. Employment contracts for resigned employees were not provided for review. Not all required attendance records and payroll ledgers were available for review. Payroll ledgers are neither signed by employees nor stamped by the bank for acknowledgment. Social insurance payment receipts provided are incomplete. The attendance system does not record actual time worked. Additional Comments: No concern on this issue was detected. The facility has shown open to give all information required during the whole audit. : Needs Improvement Unable to Verify Auditors attempted to conduct an audit and were denied access to certain areas of the facility. Auditors attempted to conduct an audit and were denied access to employee interviews. Additional Comments: Auditors were allowed to access to all the facility and conduct interviews to employees. Transparency: Needs Improvement Unable to Verify Compliance with wage requirements and overtime hour limitations could not be verified due to discrepancies between the documents provided by facility management for review and/or the information provided by employees during interviews. Discrepancies were noted between the actual number of employees observed at the facility and the number of employees disclosed by facility /01

26 management. Employees appeared to have been influenced by facility management prior to private interviews. Unauthorized transfer of employees from the audited facility to another facility. Additional Comments: Facility was cooperative and transparent during the whole audit process. Non-Discrimination: Needs Improvement Unable to Verify Employees do not receive equal benefits. Female employees are prohibited from being pregnant. The facility has a policy of Hepatitis B (HBV) testing as part of the hiring process. The facility has a policy of pregnancy testing as part of the hiring process. The facility imposes discriminatory hiring restrictions. Additional Comments: No concern on this issue was detected. During the audit interviews it was noted employees do not recive or have seen any case of discrimination of any type. Additionally, there are no actions (related to opportunities for improve, salary, training, etc.) that could be interpreted as discrimination /01

27 Laws (if applicable): Labor Contract: Needs Improvement Unable to Verify Employees do not receive a copy of the employment contract. Employment contracts do not include information on potential occupational disease hazards and prevention. Employment contracts do not include some of the required information. Employment contracts have not been established with employees. Employment contracts state that facility management may dismiss employees during the probation period without pay. The probationary period in the employment contract exceeds the local limits. Additional Comments: It is not a legal requirement in Argentina. : Needs Improvement Unable to Verify A Leave with Wages Register is not maintained and employees are not provided with leave books. A record book of holiday compensation has not been established. A register for advances and deductions is not maintained. A register for advances and fines is not maintained. A register of contracted employees is not maintained. Certified standing orders have not been obtained. Contract employees are hired but the required license has not been obtained. Employee registers and muster rolls are not maintained. Employees do not receive a copy of the Collective Bargaining Agreement. Employees do not receive detailed payroll information. Facility management employs contract employees from contract labor agencies which do not have the required licenses. Facility management has failed to establish facility rules and regulations. Facility management has hired apprentices through a contractor's apprenticeship program that has not been registered with and approved by the Technical Education and Skills Development Authority (TESDA). Facility management has not obtained approval for shift work. Facility rules are not communicated to employees. Facility rules have not been approved. Leave Books are not issued to employees. Legal authorization to work overtime has not been obtained. Service cards are not maintained for some employees. Some employees are not provided with the required amount of rest /01

28 between shifts. Some employees' identification cards are expired. Some female employees work after 7:00 p.m. Some of the required abstracts and notifications are not displayed. Some outsourced or contract employees perform permanent jobs. Suggestion boxes are not provided. The Collective Bargaining Agreement has not been updated. The Internal Work Rules have not been properly registered. The business license does not meet the legal requirements. The business license has not been updated to reflect the most current facility information. The business license is expired. The employee roster does not include some of the required information. The facility does not have a grievance redressal system. The facility does not maintain signed privacy notices in employee personnel files. The facility has a policy of conducting unnecessary tests as part of the medical exam process. The facility has not prepared an employee roster. The facility is not registered with the Department of Labor & Employment. The facility registration is expired. The facility regulations have not been submitted to the authority for approval. The facility rules stipulate that employees will be fined for violating facility rules. The legal requirement for protecting women against harassment at the workplace is not posted. The notice of weekly off days has not been submitted to the inspector of factories and is not posted in the facility. The required committees do not meet on a regular basis. The required health and safety, grievance and anti-sexual harassment committees have not been established. The standing order is not displayed. Additional Comments: No apparent violations /01

29 Protection of the Environment: Needs Improvement Unable to Verify A water efficiency usage program has not been established. Air pollutants are discharged from the facility, but a pollutant discharge permit was not available for review. An Environmental Management Department has not been established. An acoustic enclosure for the generator does not meet the legal requirements. An analysis of the discharged waste water has not been conducted. An environmental management and monitoring plan is not maintained at the facility. Employees do not receive basic training on environmental safety procedures Facility management did not provide duplicate forms for transferring solid hazardous waste. Facility management has not signed a contract for hazardous waste disposal. Facility management was unable to provide the hazardous waste disposal contract and relevant transfer manifests for review. Hazardous waste containers are not properly stored. Hazardous waste is mixed with non-hazardous waste. Safety monitoring reports are not regularly submitted. The Environmental Compliance Certificate has not been obtained. The annual waste or unused material reports are not submitted to the Department of Industrial Works. The chimney height for the generator does not meet the legal requirements. The consent order (NOC), or No Objection Certificate, from the Local Pollution Control Board has not been obtained for water discharge and operation in an air pollution control area. The effluent treatment plant is not functioning. The environmental impact assessment approval reports have not been obtained. The environmental impact assessment approval reports were not available for review. The environmental protection acceptance check for the completed construction project has not been obtained. The environmental protection acceptance check for the completed construction project was not available for review. The environmental protection certificate has not been obtained. The environmental protection certificate was not available for review. The facility discharges airborne gases or particles that contain hazardous or poisonous substances to the atmosphere, and purification treatment is not added before discharge. The facility has not compiled an Environmental Impact Report or an Environmental Impact Report Form or filled out an Environmental Impact Registration Form. The facility has not conducted an atmospheric analysis. The facility has not registered and reported its atmospheric pollutants at the local administrative department of environmental protection /01

30 The facility has not registered and reported its water pollutants at the local administrative department of environmental protection. The facility has not resubmitted the Environmental Impact Assessment documents since the facility has expanded. The facility has not submitted the relevant technical data concerning the prevention and control of atmospheric pollution. The facility has not submitted the relevant technical data concerning the prevention and control of water pollution. The facility is not registered as a hazardous waste producer. The facility management does not keep a log detailing the volume of waste generated and how it is handled. The facility's hazardous waste is not collected by a supplier with the required permit. The hazardous waste containers are not properly labeled. The hazardous waste transfer manifest was not available for review. The pollutant discharge permit has not been obtained. The pollutant discharge permit was not available for review. The provided hazardous waste disposal contract is expired. The radiation safety permit for radioactive equipment was not provided for review. The report from the environmental protection administration for the polluted water discharging pool was not available for review. The stack height of the DG set (80 KVA) is not adequate. The updated Environmental Aptitude Certificate was not available for review. The waste discharge permit is expired. Untreated waste water is discharged directly into the local water source. Waste water is discharged without proper treatment. Water pollutants are discharged from the facility but the pollutant discharge permit was not available for review. Additional Comments: No concern on this issue was detected. Based on the document review it was verified that the facility has all permits related to generate and dispose special and common waste. The facility has an environmental certificate, Expedient N A /01

31 Publication: Needs Improvement Unable to Verify The Disney Code of Conduct is not posted in the facility and/or communicated to employees Additional Comments: During the facility tour it was noted the Disney Code of Conduct is posted in the facility. Subcontracting: Needs Improvement Unable to Verify All or some production processes are subcontracted to another facility without Disney's written consent. All or some production processes are subcontracted to home-workers without Disney s written consent. All or some production processes are subcontracted to illegal homeworkers. Additional Comments: No apparent violations. The facility does not subcontracts any proccess /01