should never be revealed with any of their responses to management. However, responses may be shared with management as a general finding if it is confirmed by others, or by documentary evidence. Union representatives may be present, if requested by the employee. The management is never allowed to be present during employee interviews. In countries where ECCO does not have representatives (e.g. Vietnam, South Korea), an interpreter arranged by ECCO is necessa r y. An interview sheet is available as an advisory tool. See: “Template CoC Audit Suppliers under Interviews”. d. Document review Documents to be reviewed during the audit typically include: • Waste handling procedures and records/reports • Water and energy saving and records/reports • Material Safety Data Sheets • Emergency action plans • Work accident reports • EHS training • Employee contracts • Time cards • Pay rolls Concerning working terms, such as minimum wages, working hours, overtime, overtime payment, see: “Template CoC Audit Supplier under Overview Working Terms”. Impressions from factory interviews and document reviews are cross-checked. e. Conclusion meeting This meeting finalises the audit visit and usually takes about one hour. The participants are the management team and the persons involved in the audit. At this meeting, the lead auditor presents the results from the audit, supported by photos and explanations of good examples and improvements in performance. The audit score based on “The ECCO Code of Conduct Audit Form, Suppliers” is presented, together with suggestions for an action plan (typically with 10-15 topics) based on the supplier’s suggestions. The audit findings in the action plan are categorised according to definitions of Critical, Major, and Minor findings. See: “Audit Policy, the ECCO Code of Conduct” and “Template, CoC Audit Suppliers incl. audit findings categories”. After the audit The lead auditor completes a draft for the audit summary and action plan within five working days. See: “Template CoC Audit Suppliers”. The draft document identifies performance issues to be improved in the action plan, as discussed during the audit. The draft document is sent for review to ensure consistency before it is released to the supplier. The review is done by the CoC audit specialist function. For the audits for which a CoC audit specialist has been lead auditor, the review is done by a CoC auditor at Global Procurement Office or Corporate Conduct. The deadline for the review is five working days. This draft is sent to the supplier’s audit contact person, who is asked to state a realistic deadline and name a responsible person in the action plan (send the whole document; it is not necessary to delete any sheets in the template CoC Audit Suppliers). 52
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