我们为您包通过验厂，咨询热线：18305759080、QQ：375453467
VERIFYING THE SELF-ASSESSMENT QUESTIONNAIRE
In completing the Self-Assessment Process, the following lists each question from the Self-Assessment Questionnaire and the evidence that must be verified.
PERSONNEL ISSUES
Question 1.1 Does the factory obtain current information on local and national laws and regulations, and incorporate this information in its business practices?
The workers should be compensated according to the local and national labor laws. The payroll department should have the latest copies of these laws and amendments on file. These laws should cover, but not be limited to the following areas:
Wages and hours.
Legal benefits.
Minimum age for employment and related restrictions.
Health and safety standards.
Employment discrimination.
General labor law.
The factory should have a procedure that will ensure that the labor laws and regulations are being followed.
There should be a manager or supervisor responsible for monitoring and updating these laws. Any new laws should be adapted as soon as possible.
The factory should review the labor laws to ensure that the workers are being properly compensated.
If the factory uncovers a violation, that violation must be corrected as soon as possible. The factory should document the violation and what was done to correct it.
There should be a procedure to prevent the violation from re-occurring.
It should be part of the factories official company policy that all labor laws will be obeyed.
Question 1.2 Does the factory prohibit any condition within the facility, building and/or equipment that could cause injury or death to the workers, or any violation of law or a JCPenney standard?
An unsafe condition is anything that can cause injury or death to the worker. The factory should have a procedure for monitoring safety conditions within the facility.
This would include the building and all property that is attached to the building and owned, or used by the factory. There should also be a procedure for monitoring equipment and machinery for unsafe conditions. These procedures should be monitored by a manager or supervisor. This can be anyone that the factory designates, however, it is usually the responsibility of the Safety Manager or Safety Supervisor. Safety issues concerning machinery and equipment are usually monitored by an Equipment Maintenance Manager or Supervisor.
The building should be inspected on a regular basis for unsafe conditions. Unsafe conditions should be repaired as soon as possible. Building inspection records should be maintained indicating the type of inspection performed, date of the inspection and the results of the inspection. Any repairs made should also be listed. Machinery and equipment should be inspected and maintained on a regular basis. Defective machinery and equipment should not be used until the proper repairs have been made. Equipment inspection records should be maintained listing the type of inspection, date of the inspection, the results of the inspection and what repairs were made. Any repairs made should also be listed.
All workers using any machinery or equipment should be properly trained in the safe use of the equipment involved.
All local and national laws concerning labor issues and the operation of the factory must be obeyed.
However, there are situations where a JCPenney standard is more stringent than local or national law. When this occurs, the JCPenney standard must be followed.
Question 1.3 Does the factory effectively prohibit convict, involuntary, and forced labor?
The use of convict, involuntary, indentured or forced labor of any kind is prohibited. There are no exceptions.
Convict Labor
The factory is prohibited from hiring convicted criminals currently in prison for committing a crime.
Even though there are conditions where it is permitted to employ criminals under local or national law,it is expressly forbidden to import any product into the United States under United Stated Customs Laws, if that product was produced by convict labor.
Involuntary Labor or Forced Labor Anyone being forced to work against their will is considered involuntary or forced labor. Workers must be given complete freedom of movement to leave the facility at any time. Factories have the right to impose restrictions on workers entering the facility or entering certain rooms within the facility but should never prohibit workers from leaving.
Indentured Labor Workers should never be forced to work by contract or any other means. Workers should never be forced to work to pay off a debt for themselves, a family member or anyone else by signing a contract.
Worker Contracts
In some factories workers are required to sign an employment contract. These contracts will usually list the job description, job duties, disciplinary procedures, overtime requirements and the length of time that the contract is in effect. Some contracts are open ended. That is, the contract may be written with no ending date. If the contract is open ended, there must be a provision that will end the contract when the worker resigns the job. Employment contracts must not include anything that can be interpreted as forcing the worker to work. Workers must be allowed to resign at any time.
Occasionally factories use third party agents or brokers to hire workers. If third parties are used to hire workers, the workers’ wages must be paid directly to the worker and not the agency or broker. It is the factories responsibility to ensure that third party agents or brokers supply legal workers that are not convicts, indentured or forced to work in any way. Security guards employed by the factory, or security agencies contracted for their services, must not engage in practices that will cause workers to stay in the factory and work against their will. Security guards should be limited to normal security functions such as protecting the factory and products produced and the security of the workers and other factory personnel.
The factory should not retain the worker's original identification card, work permit or other form of identification.
Employees must have freedom of movement within the dormitories and be free to leave at any time.
Question 1.4 Does the factory obtain documentation for proof of age and eligibility for employment from all potential workers prior to hiring?
When hiring workers, the factory should verify proof of age and eligibility to work according to local and national laws or JCPenney standards. This proof must be in a form of legally acceptable documents. The following are examples of the type of documents that are acceptable:
Proof of age as required by the country where the factory is located, including but not limited to:
Official birth certificate.
Official identification card.
Official school records.
Proof of residence.
Immigration or other legal papers as required.
A statement of age containing:
Employee signature.
Employee identification number or other means of identification.
Date of signature.
All workers should fill out an employment application listing their name, address, date of birth, place of birth, citizenship, type of job applied for and any information as required by local and national law.
This application should be signed by the worker.
The factory should have a procedure that explains to the workers minimum age and eligibility requirements for the job applied for. The factory should explain all benefits that the workers are entitled to. This includes social security (medical and pension), savings, bonus, overtime hours,overtime pay, worker contracts, job requirements, disciplinary procedures, dormitory, meals and anything that will affect the worker.
All benefits and requirements should be prominently posted so they can be read by all the workers.
All worker personnel records should be periodically reviewed to ensure that the proper documents are on file and correctly updated.
Question 1.5 Does the factory prohibit the hiring of workers under the legal age or JCPenney standard, or ineligible workers, and does the factory keeps copies of age and eligibility?
It is the responsibility of the factory to ensure that
all workers hired are of legal age and meet the
eligibility requirements of the country where the
factory is located. If it is determined that these
requirements are below the JCPenney standards, then the
JCPenney standards will apply.
The factory should have a procedure to screen all
workers prior to hiring, to ensure that they meet all
applicable age and eligibility requirements. Copies of
all applicable proof should be kept on file for all
workers.
There should be a manager or supervisor responsible for
maintaining and updating worker files.
Question 1.6 Does the factory effectively prohibit all
forms of harassment, abuse, and physical and/or verbal
abuse?
Workers should be fairly treated according to the laws
of the country where the factory is located.
The factory should expressly prohibit all forms of
harassment, verbal and/or physical abuse. This includes,
but is not limited to:
• Physical or verbal coercion.
• Sexual abuse.
• Harassment, or abuse in the form of disciplinary
action.
• Any harassment or abuse from any person, such as
security guards, or any manager, supervisor
or worker.
Question 1.7 Does the factory have procedures to ensure
employees are compensated in accordance with local laws
and regulations?
The factory should have a payroll procedure that will
ensure workers are compensated in accordance
with local and national laws. The factory should have a
manager or supervisor responsible for the payment of
wages and all issues relating to wages. There should be
an itemized listing of all deductions. These procedures
should include, but not be limited to:
• A detailed method of payment as appropriate.
Check.
Cash.
Direct deposit.
• The basis for payment.
Hourly.
Weekly.
Monthly.
Piece rate.
Combination (Hourly and piece rate).
• A detailed procedure for wage calculation where
applicable.
Quota for piece rate or hourly calculation.
Adjustment to meet minimum.
Hourly or monthly minimum rate.
Bonus or other incentives.
• Itemized deductions.
Social Security (Medical and/or pension).
Required local and national taxes.
Issuing and repayment of loans.
Any other deductions.
• Frequency of payment.
Weekly.
Monthly.
Other.
• Specific length of the normal work day.
Number of hours.
Start and finish time.
• Define the normal week.
Number of consecutive days.
Specific days of the week.
• Rest and meal breaks.
Number of breaks.
Length of break.
Time of day or shift.
• Designate days off.
Normal day(s) off each week.
Holidays (Legal and/or religious).
Vacation.
• Define overtime.
Hours.
Compensation rate.
The factory should have a detailed pay slip that shows
all the deductions made and the method of calculation.
If workers receive cash payments there should be a
master payroll record with each workers’ signature
indicating that they received their pay.
The workers should be notified in writing of any changes
in their actual pay and/or payroll procedures and the
reasons for these changes.
Any miscalculations or under payment of wages must be
corrected immediately.
Any worker's complaints regarding wages must be
investigated immediately. If it is determined that the
workers were not correctly paid, an adjustment must be
made immediately.
Question 1.8 Are factory workers, at the time of hiring,
made aware of their legal rights regarding hours worked,
and wage compensation?
When factory workers are hired they should receive an
explanation of their legal rights concerning the working
hours of the factory. They should be told if overtime is
required and how many overtime hours they can expect to
work daily, weekly and monthly. They should be given an
explanation of the laws concerning overtime.
A written explanation of wage and overtime laws should
be provided to the workers. This explanation should be
signed by the worker and a copy should be kept in the
worker’s file.
The factory should periodically review the laws
concerning hours worked and wage compensation to ensure
they are in compliance with the most current laws. Any
areas that are not current should be corrected. Copies
of the latest laws should be kept on file.
Question 1.9 Does the factory prominently post minimum
wage rates, allowance information, benefits policies,
and regular and overtime wages in the native language(s)
of the factory workers and management personnel?
The factory should list its policies concerning minimum
wage rates, regular working hours, overtime hours and
benefits. Any applicable local and national wage laws
should also be listed. These postings should be located
in prominent areas, i.e., the worker entrance, time
clock, or cafeteria; so the workers can read them at any
time.
All postings should be in the native language of the
factory workers and factory management personnel. In the
event that the factory hires workers that speak a
language other than the language of the country where
the factory is located, these postings should also be in
that language. It is possible that the factory will need
postings in more than one language.
Question 1.10 Does the factory have, utilize, and
maintain an organized payroll system including an
accurate time recording device?
The payment of wages can be a complicated process. To
ensure that the workers are accurately paid, an
organized payroll system should be used. A computer
payroll system is recommended for accuracy and
consistency. All methods of payment, including time
work, piece work, incentives, bonus, and etc., should be
part of the payroll system. All benefits and allowances
such as meals,
housing, uniforms, etc., should be included. All
deductions such as social security (medical and
pension), taxes, loans, and etc., should also be
included.
If the factory is not equipped for an organized or
automated payroll system, a commercial payroll service,
if available, is an acceptable alternative.
For piece rate and/or quota payments, employee sign-off
sheets should be available confirming the correct unit
counts. The employee should sign off on any random
re-counts that are used for verification.
Since accurate payroll calculations are based on the
time that the factory workers work, an accurate time
recording device such as an electric or electronic time
clock should be used. The time clock should be
periodically checked for accuracy. Each worker should
have their own time card to record time in and time out
including meal breaks and rest breaks. If an electronic
recording device is used,
each worker should have a worker identification card to
record time in/time out, meal breaks and rest breaks.
The factory should maintain a summary sheet listing the
time worked for all the workers.
The factory should perform periodic reviews to determine
the accuracy for the method of paying the workers.
Mechanical and electronic equipment should be checked to
ensure that it is in proper working order. If this
equipment is found to be inaccurate, or not in working
order, corrective action should be taken, including
adjustment of back wages, if required, for the period of
time when the equipment malfunctioned.
Question 1.11 Does the factory produce and retain
payroll records to support compensation, including the
payment of overtime and the deduction or required taxes?
The factory should keep payroll records for at least one
year or longer if required by law. Payroll summaries
should also be retained with the following information:
• Name and identification number of each employee.
• Hourly, weekly, monthly rate or piece rate if
applicable.
• Payment of minimum wage.
• Gross pay.
• Net pay.
• Pay period.
• Payment date.
• Minimum wage.
Question 1.12 Does the factory provide all employees
with pay information which details
the current period's wage calculation?
The factory should provide each worker with a pay stub
or some other form of documentation listing the details
for the pay period involved. This information should
include, but not be limited to:
• Total hours worked including regular and overtime
hours.
• Gross wages including advances or loans.
• Calculation of overtime, quota incentive and piece
rate if applicable.
• Make up pay for piece rate under the minimum wage.
• Social Security, pension, savings.
• Other deductions including repayment of loans.
• Net Pay.
The factory should periodically interview workers,
selected at random, to verify that they have examined a
detailed pay record and that they understand the
calculation of their gross pay and net pay. Any
deviations from the established procedures are to be
corrected in a timely manner.
Question 1.13 Does the factory pay piece rate workers at
a rate equivalent to the minimum wage required by law?
The factory must ensure that all workers earn the
minimum rate according to law. If a piece rate worker
cannot make the standard, the factory must adjust the
standard of the wage rate so that the workers wage will
be equal to the legal minimum wage. The worker should be
advised of this and the payroll records should reflect
this adjustment.
Question 1.14 Does the factory ensure that the workers
do not work more hours per day and per week than the
legal limits, or the JCPenney standard?
There are times when it is necessary for a factory to
work overtime to meet production and delivery schedules.
However, workers who work excessive hours will loose
efficiency and production will decrease. In addition,
the injury rate will increase.
Workers must not exceed the maximum number of hours
allowed by law or the JCPenney standard.
In the event that there is no local or national law
governing maximum working hours or current law is in
conflict with the JCPenney standard, then the JCPenney
standard will apply.
If the factory determines that it is necessary to work
more hours then allowed by law, they must obtain a
waiver from the appropriate governing authority. This
waiver must list the period time covered and the amount
of hours to be worked. Workers must be paid for extra
overtime according to local or national law.
The department or individual responsible for payroll
must perform periodic time card reviews to ensure the
hours worked by employees (voluntarily or involuntarily)
in a given day, week or month do not exceed legal
limits. If official waivers have been issued, the limits
of the waiver must not be exceeded.
Question 1.15 Does the factory have policies that
explicitly prohibit discrimination?
The factory must hire workers based on their ability to
do the job not on any physical or personal
characteristics or beliefs.
The factory must have a policy that expressly prohibits
all forms of discrimination. The workers must be made
aware of this policy.
HEALTH AND SAFETY
Question 2.1 Does the Factory comply with national and
local health and safety laws and
regulations?
The factory must provide a safe working environment for
the workers. The building must be in good repair with no
safety hazards. Procedures should include, but not be
limited to:
• A plan for fire safety.
• Adequately equipped first aid kits.
• Easily accessible sanitary drinking water in work and
residential areas.
• Sanitary toilet facilities.
• Adequate ventilation throughout building and
dormitory.
• Structurally sound and clean building facilities,
including dormitories.
• Machinery and equipment that is safe and will not
cause injury to the workers.
• Emergency evacuation plans, in the native language(s)
of the employees, posted in view of factory workers
(i.e. a diagram of the factory layout with emergency
exits and routes highlighted).
The factory should maintain inspection records and
operating permits for building and equipment as required
by law. This should include, but not be limited to:
• Inspection certificates and citations issued by
government agencies.
• Operating permits issued by government agencies.
• Health and safety reports detailing findings,
recommendations and corrective actions.
• Machinery inspection and maintenance reports issued by
factory management.
• Fire extinguisher inspection records noting dates
inspected and expiration.
• Records of fire safety drills including the dates held
and any pertinent details on the results of the
drills.
• Work injury reports including the nature and frequency
of accidents.
• Clinic logs listing the reason for visit.
The factory should comply with all local and national
government health requirements. Records and
correspondence should be maintained for any on site
inspections. Deficiencies discovered during these
inspections should be recorded. The factory should
correct all deficiencies and notify the appropriate
government agency for a re-inspection. Records should be
maintained of the reinspection.
Once the factory passes the re-inspection, all
documentation should be kept as evidence of the passed
inspection.
Question 2.2 Does the Factory have procedures for
machinery and equipment, and chemical safety?
The factory should have procedures in place for the safe
operation and use of machinery and equipment. This
should include the handling, use and storage of
chemicals. These procedures should include, but not be
limited to:
• Machinery and equipment safety:
Training workers in the safe use of machinery and
equipment.
Providing appropriate personal protective equipment,
free of charge, to factory workers and requiring them to
use it. This equipment includes:
Respiratory protection
Skin protection
Eye and face protection
Hearing protection
Foot protection
Hand protection
Head protection
Providing appropriate safety guards and features on all
machinery and equipment and ensuring that they are
functioning properly.
Ensuring through routine inspection that electrical
equipment and outlets are not overloaded.
Ensuring that boilers have operational pressure release
valves.Chemical safety:
Ensuring proper storage of hazardous and toxic
materials.
Providing periodic physical exams for workers handling
hazardous materials.
Training workers in chemical safety.The factory should
perform the following functions to ensure that the
workers are performing under the safest conditions
possible:
Periodically review all safety procedures to ensure that
they are adequate and being followed by the workers.
Develop programs and materials to train workers and
managers on procedures for machinery and equipment and
chemical safety.
Train the workers on the use of personal protective
equipment and safety guards. This equipment should be
accessible and the workers should be required to use it.
Store hazardous or toxic materials properly.
Continually inspect equipment and machinery to ensure
proper operation of required safety features and that
the workers using this equipment are properly trained.
Periodically review files to ensure required health and
safety records are appropriately maintained and
distributed.
Require the workers to follow all safety procedures and
discipline workers who do not.
Question 2.3 Has the Factory implemented procedures for
fire safety which include worker housing and
dormitories?
Fire safety is extremely important. The factory should
have procedures in place that will ensure the workers
are protected against fire and fire related hazards.
This should include worker housing.
The building and/or dormitory should have fire
extinguishers placed in every room. A fire extinguisher
should be placed within 50 feet of each worker, and be
of an appropriate size that can be handled by the
average worker. The type of fire extinguisher used
depends upon the type of fire. For example,
an area that uses electrical equipment will need a
different type of fire extinguisher than an area where
chemicals are used. All workers should be trained in the
proper use of fire extinguishers. In addition, selected
workers should receive extensive fire training and be
organized as a fire fighting brigade. Fire extinguishers
are intended for spot fires which are usually small
fires. These fires can start by spontaneous combustion,
defective or overheating machinery and equipment,
careless smoking or other causes. Sprinkler systems,
fire hoses or other fire fighting devices are intended
for large fires, but should not replace fire
extinguishers. Fire extinguishers should be serviced
annually.
Each fire extinguisher should be tagged indicating the
date and type of service.
The building should have enough emergency exits to allow
the workers to leave the building in a fast and orderly
manner. Exits should be on opposite sides of the
building. If the building is more than one story there
should be sufficient stairways to allow the workers to
get to the ground floor and exit the building in a fast
and orderly manner. A traditional fire escape on the
outside of the building is
preferred, however, any stairway that leads to the
ground floor and is near an exit to the outside is
acceptable.
All exits should be clearly marked and accessible. Exits
must not be locked or blocked in any way. If building
security or theft is a concern then push bars should be
used on the exit doors. This will
prevent the door from being opened from the outside, but
allows the door to be easily opened from the inside in
case of an emergency. For additional security an alarm
can be installed on the door to advise security
personnel when it is opened.
The factory should conduct periodic fire drills to
ensure that all workers know how to leave the building
in a fast and orderly manner.
The factory should have procedures to train all managers
and workers in fire safety.
The factory should develop a fire evacuation plan. This
plan should clearly define the nearest exit path and be
prominently posted for the workers. For large buildings,
several evacuation plans should be posted at different
locations throughout the building.
The factory should conduct periodic fire safety
inspections of the building, machinery and equipment.
Any failure of this inspection should result in
immediate corrective action.
FACILITY AND ENVIRONMENT
Question 3.1 Is there sufficient work space for each
worker to perform their duties in a safe manner without
interference from other workers, machinery or equipment,
and raw materials used in production?
The factory should be designed and operated in a manner
that will allow sufficient area for each worker to
perform their duties without interference from other
workers. This area should include sufficient space for
materials, tools and other items that are necessary for
manufacturing the product.
There should be sufficient room between workers to allow
them to leave their work area in a fast and orderly
manner in case of fire or other emergency. Each work
station should have adequate lighting to reduce the risk
of eye strain.
The factory should perform periodic inspections to
ensure that the condition of each work station is safe
and well lit. Any defective areas should be repaired or
replaced as required. Work station inspection records
and a corrective action procedure should be maintained.
VERIFYING THE SELF-ASSESSMENT QUESTIONNAIRE
In completing the Self-Assessment Process, the following
lists each question from the Self-Assessment
Questionnaire and the evidence that must be verified.
PERSONNEL ISSUES
Question 1.1 Does the factory obtain current information
on local and national laws and regulations, and
incorporate this information in its business practices?
The workers should be compensated according to the local
and national labor laws. The payroll department should
have the latest copies of these laws and amendments on
file. These laws should
cover, but not be limited to the following areas:
• Wages and hours.
• Legal benefits.
• Minimum age for employment and related restrictions.
• Health and safety standards.
• Employment discrimination.
• General labor law.
The factory should have a procedure that will ensure
that the labor laws and regulations are being followed.
There should be a manager or supervisor responsible for
monitoring and updating these laws. Any new laws should
be adapted as soon as possible.
The factory should review the labor laws to ensure that
the workers are being properly compensated.
If the factory uncovers a violation, that violation must
be corrected as soon as possible. The factory should
document the violation and what was done to correct it.
There should be a procedure to prevent the violation
from re-occurring.
It should be part of the factories official company
policy that all labor laws will be obeyed.
Question 1.2 Does the factory prohibit any condition
within the facility, building and/or equipment that
could cause injury or death to the workers, or any
violation of law or a JCPenney standard?
An unsafe condition is anything that can cause injury or
death to the worker. The factory should have a procedure
for monitoring safety conditions within the facility.
This would include the building and all property that is
attached to the building and owned, or used by the
factory. There should also be a procedure for monitoring
equipment and machinery for unsafe conditions. These
procedures should
be monitored by a manager or supervisor. This can be
anyone that the factory designates, however, it is
usually the responsibility of the Safety Manager or
Safety Supervisor. Safety issues concerning machinery
and equipment are usually monitored by an Equipment
Maintenance Manager or Supervisor.
The building should be inspected on a regular basis for
unsafe conditions. Unsafe conditions should be repaired
as soon as possible. Building inspection records should
be maintained indicating the type of inspection
performed, date of the inspection and the results of the
inspection. Any repairs made should also be listed.
Machinery and equipment should be inspected and
maintained on a regular basis. Defective machinery and
equipment should not be used until the proper repairs
have been made. Equipment inspection records should be
maintained listing the type of inspection, date of the
inspection, the results of the inspection and what
repairs were made. Any repairs made should also be
listed.
All workers using any machinery or equipment should be
properly trained in the safe use of the equipment
involved.
All local and national laws concerning labor issues and
the operation of the factory must be obeyed.
However, there are situations where a JCPenney standard
is more stringent than local or national law. When this
occurs, the JCPenney standard must be followed.
Question 1.3 Does the factory effectively prohibit
convict, involuntary, and forced labor?
The use of convict, involuntary, indentured or forced
labor of any kind is prohibited. There are no
exceptions.
Convict Labor
The factory is prohibited from hiring convicted
criminals currently in prison for committing a crime.
Even though there are conditions where it is permitted
to employ criminals under local or national law,
it is expressly forbidden to import any product into the
United States under United Stated Customs Laws, if that
product was produced by convict labor.
Involuntary Labor or Forced Labor Anyone being forced to
work against their will is considered involuntary or
forced labor. Workers must be given complete freedom of
movement to leave the facility at any time. Factories
have the
right to impose restrictions on workers entering the
facility or entering certain rooms within the facility
but should never prohibit workers from leaving.
Indentured Labor Workers should never be forced to work
by contract or any other means. Workers should never be
forced to work to pay off a debt for themselves, a
family member or anyone else by signing a contract.
Worker Contracts
In some factories workers are required to sign an
employment contract. These contracts will usually list
the job description, job duties, disciplinary
procedures, overtime requirements and the length of time
that the contract is in effect. Some contracts are open
ended. That is, the contract may be written with no
ending date. If the contract is open ended, there must
be a provision that will end the
contract when the worker resigns the job. Employment
contracts must not include anything that can be
interpreted as forcing the worker to work. Workers must
be allowed to resign at any time.
Occasionally factories use third party agents or brokers
to hire workers. If third parties are used to hire
workers, the workers’ wages must be paid directly to the
worker and not the agency or broker. It is the factories
responsibility to ensure that third party agents or
brokers supply legal workers that are not convicts,
indentured or forced to work in any way. Security guards
employed by the factory, or security agencies contracted
for their services, must not engage in practices that
will cause workers to stay in the factory and work
against their will. Security
guards should be limited to normal security functions
such as protecting the factory and products produced and
the security of the workers and other factory personnel.
The factory should not retain the worker's original
identification card, work permit or other form of
identification.
Employees must have freedom of movement within the
dormitories and be free to leave at any time.
Question 1.4 Does the factory obtain documentation for
proof of age and eligibility for employment from all
potential workers prior to hiring?
When hiring workers, the factory should verify proof of
age and eligibility to work according to local and
national laws or JCPenney standards. This proof must be
in a form of legally acceptable documents. The following
are examples of the type of documents that are
acceptable:
Proof of age as required by the country where the
factory is located, including but not limited to:
• Official birth certificate.
• Official identification card.
• Official school records.
• Proof of residence.
• Immigration or other legal papers as required.
• A statement of age containing:
• Employee signature.
• Employee identification number or other means of
identification.
• Date of signature.
All workers should fill out an employment application
listing their name, address, date of birth, place of
birth, citizenship, type of job applied for and any
information as required by local and national law.
This application should be signed by the worker.
The factory should have a procedure that explains to the
workers minimum age and eligibility requirements for the
job applied for. The factory should explain all benefits
that the workers are entitled to. This includes social
security (medical and pension), savings, bonus, overtime
hours,
overtime pay, worker contracts, job requirements,
disciplinary procedures, dormitory, meals and anything
that will affect the worker.
All benefits and requirements should be prominently
posted so they can be read by all the workers.
All worker personnel records should be periodically
reviewed to ensure that the proper documents are on file
and correctly updated.
Question 1.5 Does the factory prohibit the hiring of
workers under the legal age or JCPenney standard, or
ineligible workers, and does the factory keeps copies of
age and eligibility?
It is the responsibility of the factory to ensure that
all workers hired are of legal age and meet the
eligibility requirements of the country where the
factory is located. If it is determined that these
requirements are below the JCPenney standards, then the
JCPenney standards will apply.
The factory should have a procedure to screen all
workers prior to hiring, to ensure that they meet all
applicable age and eligibility requirements. Copies of
all applicable proof should be kept on file for all
workers.
There should be a manager or supervisor responsible for
maintaining and updating worker files.
Question 1.6 Does the factory effectively prohibit all
forms of harassment, abuse, and physical and/or verbal
abuse?
Workers should be fairly treated according to the laws
of the country where the factory is located.
The factory should expressly prohibit all forms of
harassment, verbal and/or physical abuse. This includes,
but is not limited to:
• Physical or verbal coercion.
• Sexual abuse.
• Harassment, or abuse in the form of disciplinary
action.
• Any harassment or abuse from any person, such as
security guards, or any manager, supervisor
or worker.
Question 1.7 Does the factory have procedures to ensure
employees are compensated in accordance with local laws
and regulations?
The factory should have a payroll procedure that will
ensure workers are compensated in accordance
with local and national laws. The factory should have a
manager or supervisor responsible for the payment of
wages and all issues relating to wages. There should be
an itemized listing of all deductions. These procedures
should include, but not be limited to:
• A detailed method of payment as appropriate.
Check.
Cash.
Direct deposit.
• The basis for payment.
Hourly.
Weekly.
Monthly.
Piece rate.
Combination (Hourly and piece rate).
• A detailed procedure for wage calculation where
applicable.
Quota for piece rate or hourly calculation.
Adjustment to meet minimum.
Hourly or monthly minimum rate.
Bonus or other incentives.
• Itemized deductions.
Social Security (Medical and/or pension).
Required local and national taxes.
Issuing and repayment of loans.
Any other deductions.
• Frequency of payment.
Weekly.
Monthly.
Other.
• Specific length of the normal work day.
Number of hours.
Start and finish time.
• Define the normal week.
Number of consecutive days.
Specific days of the week.
• Rest and meal breaks.
Number of breaks.
Length of break.
Time of day or shift.
• Designate days off.
Normal day(s) off each week.
Holidays (Legal and/or religious).
Vacation.
• Define overtime.
Hours.
Compensation rate.
The factory should have a detailed pay slip that shows
all the deductions made and the method of calculation.
If workers receive cash payments there should be a
master payroll record with each workers’ signature
indicating that they received their pay.
The workers should be notified in writing of any changes
in their actual pay and/or payroll procedures and the
reasons for these changes.
Any miscalculations or under payment of wages must be
corrected immediately.
Any worker's complaints regarding wages must be
investigated immediately. If it is determined that the
workers were not correctly paid, an adjustment must be
made immediately.
Question 1.8 Are factory workers, at the time of hiring,
made aware of their legal rights regarding hours worked,
and wage compensation?
When factory workers are hired they should receive an
explanation of their legal rights concerning the working
hours of the factory. They should be told if overtime is
required and how many overtime hours they can expect to
work daily, weekly and monthly. They should be given an
explanation of the laws concerning overtime.
A written explanation of wage and overtime laws should
be provided to the workers. This explanation should be
signed by the worker and a copy should be kept in the
worker’s file.
The factory should periodically review the laws
concerning hours worked and wage compensation to ensure
they are in compliance with the most current laws. Any
areas that are not current should be corrected. Copies
of the latest laws should be kept on file.
Question 1.9 Does the factory prominently post minimum
wage rates, allowance information, benefits policies,
and regular and overtime wages in the native language(s)
of the factory workers and management personnel?
The factory should list its policies concerning minimum
wage rates, regular working hours, overtime hours and
benefits. Any applicable local and national wage laws
should also be listed. These postings should be located
in prominent areas, i.e., the worker entrance, time
clock, or cafeteria; so the workers can read them at any
time.
All postings should be in the native language of the
factory workers and factory management personnel. In the
event that the factory hires workers that speak a
language other than the language of the country where
the factory is located, these postings should also be in
that language. It is possible that the factory will need
postings in more than one language.
Question 1.10 Does the factory have, utilize, and
maintain an organized payroll system including an
accurate time recording device?
The payment of wages can be a complicated process. To
ensure that the workers are accurately paid, an
organized payroll system should be used. A computer
payroll system is recommended for accuracy and
consistency. All methods of payment, including time
work, piece work, incentives, bonus, and etc., should be
part of the payroll system. All benefits and allowances
such as meals,
housing, uniforms, etc., should be included. All
deductions such as social security (medical and
pension), taxes, loans, and etc., should also be
included.
If the factory is not equipped for an organized or
automated payroll system, a commercial payroll service,
if available, is an acceptable alternative.
For piece rate and/or quota payments, employee sign-off
sheets should be available confirming the correct unit
counts. The employee should sign off on any random
re-counts that are used for verification.
Since accurate payroll calculations are based on the
time that the factory workers work, an accurate time
recording device such as an electric or electronic time
clock should be used. The time clock should be
periodically checked for accuracy. Each worker should
have their own time card to record time in and time out
including meal breaks and rest breaks. If an electronic
recording device is used,
each worker should have a worker identification card to
record time in/time out, meal breaks and rest breaks.
The factory should maintain a summary sheet listing the
time worked for all the workers.
The factory should perform periodic reviews to determine
the accuracy for the method of paying the workers.
Mechanical and electronic equipment should be checked to
ensure that it is in proper working order. If this
equipment is found to be inaccurate, or not in working
order, corrective action should be taken, including
adjustment of back wages, if required, for the period of
time when the equipment malfunctioned.
Question 1.11 Does the factory produce and retain
payroll records to support compensation, including the
payment of overtime and the deduction or required taxes?
The factory should keep payroll records for at least one
year or longer if required by law. Payroll summaries
should also be retained with the following information:
• Name and identification number of each employee.
• Hourly, weekly, monthly rate or piece rate if
applicable.
• Payment of minimum wage.
• Gross pay.
• Net pay.
• Pay period.
• Payment date.
• Minimum wage.
Question 1.12 Does the factory provide all employees
with pay information which details
the current period's wage calculation?
The factory should provide each worker with a pay stub
or some other form of documentation listing the details
for the pay period involved. This information should
include, but not be limited to:
• Total hours worked including regular and overtime
hours.
• Gross wages including advances or loans.
• Calculation of overtime, quota incentive and piece
rate if applicable.
• Make up pay for piece rate under the minimum wage.
• Social Security, pension, savings.
• Other deductions including repayment of loans.
• Net Pay.
The factory should periodically interview workers,
selected at random, to verify that they have examined a
detailed pay record and that they understand the
calculation of their gross pay and net pay. Any
deviations from the established procedures are to be
corrected in a timely manner.
Question 1.13 Does the factory pay piece rate workers at
a rate equivalent to the minimum wage required by law?
The factory must ensure that all workers earn the
minimum rate according to law. If a piece rate worker
cannot make the standard, the factory must adjust the
standard of the wage rate so that the workers wage will
be equal to the legal minimum wage. The worker should be
advised of this and the payroll records should reflect
this adjustment.
Question 1.14 Does the factory ensure that the workers
do not work more hours per day and per week than the
legal limits, or the JCPenney standard?
There are times when it is necessary for a factory to
work overtime to meet production and delivery schedules.
However, workers who work excessive hours will loose
efficiency and production will decrease. In addition,
the injury rate will increase.
Workers must not exceed the maximum number of hours
allowed by law or the JCPenney standard.
In the event that there is no local or national law
governing maximum working hours or current law is in
conflict with the JCPenney standard, then the JCPenney
standard will apply.
If the factory determines that it is necessary to work
more hours then allowed by law, they must obtain a
waiver from the appropriate governing authority. This
waiver must list the period time covered and the amount
of hours to be worked. Workers must be paid for extra
overtime according to local or national law.
The department , or in, di, , , , , , , vidual
responsible for payroll must perform periodic time card
reviews to ensure the hours worked by employees
(voluntarily or involuntarily) in a given day, week or
month do not exceed legal limits. If official waivers
have been issued, the limits of the waiver must not be
exceeded.
Question 1.15 Does the factory have policies that
explicitly prohibit discrimination?
The factory must hire workers based on their ability to
do the job not on any physical or personal
characteristics or beliefs.
The factory must have a policy that expressly prohibits
all forms of discrimination. The workers must be made
aware of this policy.
HEALTH AND SAFETY
Question 2.1 Does the Factory comply with national and
local health and safety laws and
regulations?
The factory must provide a safe working environment for
the workers. The building must be in good repair with no
safety hazards. Procedures should include, but not be
limited to:
• A plan for fire safety.
• Adequately equipped first aid kits.
• Easily accessible sanitary drinking water in work and
residential areas.
• Sanitary toilet facilities.
• Adequate ventilation throughout building and
dormitory.
• Structurally sound and clean building facilities,
including dormitories.
• Machinery and equipment that is safe and will not
cause injury to the workers.
• Emergency evacuation plans, in the native language(s)
of the employees, posted in view of factory workers
(i.e. a diagram of the factory layout with emergency
exits and routes highlighted).
The factory should maintain inspection records and
operating permits for building and equipment as required
by law. This should include, but not be limited to:
• Inspection certificates and citations issued by
government agencies.
• Operating permits issued by government agencies.
• Health and safety reports detailing findings,
recommendations and corrective actions.
• Machinery inspection and maintenance reports issued by
factory management.
• Fire extinguisher inspection records noting dates
inspected and expiration.
• Records of fire safety drills including the dates held
and any pertinent details on the results of the
drills.
• Work injury reports including the nature and frequency
of accidents.
• Clinic logs listing the reason for visit.
The factory should comply with all local and national
government health requirements. Records and
correspondence should be maintained for any on site
inspections. Deficiencies discovered during these
inspections should be recorded. The factory should
correct all deficiencies and notify the appropriate
government agency for a re-inspection. Records should be
maintained of the reinspection.
Once the factory passes the re-inspection, all
documentation should be kept as evidence of the passed
inspection.
Question 2.2 Does the Factory have procedures for
machinery and equipment, and chemical safety?
The factory should have procedures in place for the safe
operation and use of machinery and equipment. This
should include the handling, use and storage of
chemicals. These procedures should include, but not be
limited to:
• Machinery and equipment safety:
Training workers in the safe use of machinery and
equipment.
Providing appropriate personal protective equipment,
free of charge, to factory workers and requiring them to
use it. This equipment includes:
Respiratory protection
Skin protection
Eye and face protection
Hearing protection
Foot protection
Hand protection
Head protection
Providing appropriate safety guards and features on all
machinery and equipment and ensuring that they are
functioning properly.
Ensuring through routine inspection that electrical
equipment and outlets are not overloaded.
Ensuring that boilers have operational pressure release
valves.Chemical safety:
Ensuring proper storage of hazardous and toxic
materials.
Providing periodic physical exams for workers handling
hazardous materials.
Training workers in chemical safety.The factory should
perform the following functions to ensure that the
workers are performing under the safest conditions
possible:
Periodically review all safety procedures to ensure that
they are adequate and being followed by the workers.
Develop programs and materials to train workers and
managers on procedures for machinery and equipment and
chemical safety.
Train the workers on the use of personal protective
equipment and safety guards. This equipment should be
accessible and the workers should be required to use it.
Store hazardous or toxic materials properly.
Continually inspect equipment and machinery to ensure
proper operation of required safety features and that
the workers using this equipment are properly trained.
Periodically review files to ensure required health and
safety records are appropriately maintained and
distributed.
Require the workers to follow all safety procedures and
discipline workers who do not.
Question 2.3 Has the Factory implemented procedures for
fire safety which include worker housing and
dormitories?
Fire safety is extremely important. The factory should
have procedures in place that will ensure the workers
are protected against fire and fire related hazards.
This should include worker housing.
The building and/or dormitory should have fire
extinguishers placed in every room. A fire extinguisher
should be placed within 50 feet of each worker, and be
of an appropriate size that can be handled by the
average worker. The type of fire extinguisher used
depends upon the type of fire. For example,
an area that uses electrical equipment will need a
different type of fire extinguisher than an area where
chemicals are used. All workers should be trained in the
proper use of fire extinguishers. In addition, selected
workers should receive extensive fire training and be
organized as a fire fighting brigade. Fire extinguishers
are intended for spot fires which are usually small
fires. These fires can start by spontaneous combustion,
defective or overheating machinery and equipment,
careless smoking or other causes. Sprinkler systems,
fire hoses or other fire fighting devices are intended
for large fires, but should not replace fire
extinguishers. Fire extinguishers should be serviced
annually.
Each fire extinguisher should be tagged indicating the
date and type of service.
The building should have enough emergency exits to allow
the workers to leave the building in a fast and orderly
manner. Exits should be on opposite sides of the
building. If the building is more than one story there
should be sufficient stairways to allow the workers to
get to the ground floor and exit the building in a fast
and orderly manner. A traditional fire escape on the
outside of the building is
preferred, however, any stairway that leads to the
ground floor and is near an exit to the outside is
acceptable.
All exits should be clearly marked and accessible. Exits
must not be locked or blocked in any way. If building
security or theft is a concern then push bars should be
used on the exit doors. This will
prevent the door from being opened from the outside, but
allows the door to be easily opened from the inside in
case of an emergency. For additional security an alarm
can be installed on the door to advise security
personnel when it is opened.
The factory should conduct periodic fire drills to
ensure that all workers know how to leave the building
in a fast and orderly manner.
The factory should have procedures to train all managers
and workers in fire safety.
The factory should develop a fire evacuation plan. This
plan should clearly define the nearest exit path and be
prominently posted for the workers. For large buildings,
several evacuation plans should be posted at different
locations throughout the building.
The factory should conduct periodic fire safety
inspections of the building, machinery and equipment.
Any failure of this inspection should result in
immediate corrective action.
FACILITY AND ENVIRONMENT
Question 3.1 Is there sufficient work space for each
worker to perform their duties in a safe manner without
interference from other workers, machinery or equipment,
and raw materials used in production?
The factory should be designed and operated in a manner
that will allow sufficient area for each worker to
perform their duties without interference from other
workers. This area should include sufficient space for
materials, tools and other items that are necessary for
manufacturing the product.
There should be sufficient room between workers to allow
them to leave their work area in a fast and orderly
manner in case of fire or other emergency. Each work
station should have adequate lighting to reduce the risk
of eye strain.
The factory should perform periodic inspections to
ensure that the condition of each work station is safe
and well lit. Any defective areas should be repaired or
replaced as required. Work station inspection records
and a corrective action procedure should be maintained.
| 