Title Page
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Lanko (Pty) Ltd
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Exporter name
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Conducted on
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Conducted by
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Location
Ethical Assessment
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Revised Date: January 2024
General information
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Senior management should hold overall accountability for implementation of ethical trade standards.
Management should appoint a person responsible for ethical trade and/ or human resources who reports to senior management whose responsibilities include implementing a comprehensive set of policies concerning equality, diversity, discrimination, harassment and grievances/complaints that apply to both permanent and temporary workers -
Who has overall responsibility for ethical trade and worker wellbeing?
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Are temporary or seasonal contracts used (or are all workers permanent)
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On average, how long are seasonal / Temporary contracts for?
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Are the same workers repeatedly employed on short term contracts
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Are agents used to recruit workers
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Are the labour providers audited by the site? when was the last audit?
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How many labour agencys /providers are used? (list GLAA numbers if in UK)
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Is there a service level agreement between the site and labour providers?
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Which of the following are used to recruit workers
- Labour provider
- Seasonal workers scheme
- Directly employed by site
- other
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where do temporary workers live - please select all that apply
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Is this accommodation inspected?
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How often is accommodation checked for suitability and issues
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How does the site communicate workers rights and the sites ethical trading policy's (please photograph noticeboards)
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Do workers receive full training at the start of - and during their employment (please list training and take a photo of records )
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Are there functioning worker committees or unions
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Are members of the committee elected by the workforce
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what are the communication channels between workers and management (noticeboard, meetings etc)
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Are open meetings held
Young Workers
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Are any workers aged 18 or younger employed?
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What is the minimum age of workers on site
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How is this verified
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Are contracts for young workers signed by a parent or legal guardian
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Do young workers engage in any of the following : Working at height, Working alone, operating machinery, working at night
- Working at height
- Operating Machinery
- Working with chemicals
- Overtime
- Working at night
- Working alone
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Does the site conduct risk assessments for young workers (please photograph Risk Assessment)
Policies - are the following policies in place?
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Please choose the policy's that are in place
- Young Worker Policy
- Grievance Procedure
- Health & Safety Policy
- Equal Opportunities Employment
- Other -please list
Working hours are not excessive - please ask to see a selection of payslips to check this section.
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Working hours must comply with national laws, collective agreements, and the provisions below, whichever affords the greater protection for workers. Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week* All overtime shall be voluntary. Overtime shall be used responsibly, considering all the following: the extent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used to replace regular employment. Overtime shall always be compensated at a premium rate, which is recommended to be not less than 125% of the regular rate of pay. The total hours worked in any 7 day period shall not exceed 60 hours, except where covered by clause below.
Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all of the following are met: this is allowed by national law;
o this is allowed by a collective agreement freely negotiated with a workers’ organisation representing a significant portion of the workforce;
o appropriate safeguards are taken to protect the workers’ health and safety; and
o the employer can demonstrate that exceptional circumstances apply such as unexpected production peaks, accidents or emergencies.
• Workers shall be provided with at least one day off in every 7 day period or, where allowed by national law, 2 days off in every 14 day period.
*International standards recommend the progressive reduction of normal hours of work, when appropriate, to 40 hours per week, without any reduction in workers’ wages as hours are reduced. -
How are hours managed - What systems are used?
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who is responsible for ensuring laws, agreements and the ETI Base code are met?
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ideally you should be given access to two or three workers payslips over the course of a month or more - in order to undersand how many hours they are working and how thier pay is structured
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Are payslips clear and show all hours worked, deductions and overtime rates?
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What entitlements do workers have to breaks and rest periods? (Workers should be entitled to sufficient and reasonable breaks, recommended at least 15 minutes every 4 hours)
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How many days of paid leave do the workers receive each year?
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Do temporary workers have access to paid leave
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How do temporary workers accrue leave
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Are there any restrictions to them taking time off?
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Please explain these restrictions
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Can they be paid in leu of annual leave
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Are employees contracted to work national holidays?
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How are they remunerated if they work on national holidays
Living wages are paid
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What is the minimum wage for the country?
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What is the minimum wage paid by the organisation? (National laws and/ or industry averages need to be complied with.)
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Do all workers (permanent and Temporary) have a written contract.
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- In a language they understand
- Does it cover all conditions of employment
- does it include an explanation of deductions
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Does it include an explanation of deductions
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Are any deductions taken from workers gross pay?
- Accommodation
- Uniform
- PPE (other than standard uniform)
- Other
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are they clearly communicated to the worker
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Are deductions used for disciplinary purposes
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Is overtime voluntary
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Does the site realise that this contravenes the ETI base code
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How often is overtime required
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How often do workers receive thier wages?
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How are workers paid
Grievance and disciplinary procedures
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Grievance mechanisms and disciplinary procedures should be in place to deal with any violations of workers rights, physical abuse or disciplined, threats of abuse or harassment, verbal abuse or other forms of intimidation. Auditor should reference the documented viewed during audit
WI worker interviews, should be completed on a % of the workforce
Any critical issues highlighted -
Is there a clear disciplinary procedure
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How is it communicated to workers
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Does the policy contain the following (please chose all that apply)
- Clear policy and system to prevent improper disciplinary practice
- Harassment and Bullying are not tolerated
- Mechanism for all workers to raise any type of grievance
- Clear that no punishment for highlighting problems
- Transparent disciplinary procedure for all supervisors or managers who treat workers unfairly
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What grounds are allowed for dismissal?
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What period of notice is given to workers who are dismissed?
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Does the management have an adequate system in place for recording disciplinary measures.
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Is there a clear Grievance procedure in place
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Is the Grievance process available to all workers including temporary
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Is it clear that works will not be punished for highlighting problems
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Is there a clear mechanism for workers to raise any kind of grievance
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Is information about the grievance process available publicly (noticeboards, training etc)
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Can a grievance be raised anonymously? please explain how
Employment is freely chosen
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There is no forced, bonded or involuntary prison labour. Workers are not required to lodge “deposits” or their identity papers with their employer and are free to leave their employer after reasonable notice.
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What systems are in place to ensure the site does not use workers who are employed by force, bonded labour or prison labour
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how does the site ensure that workers have not have paid to access their jobs and are not be in debt to their recruiter.
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Are workers free to leave their jobs once their shift ends, with full access to their earnings
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Are original documents or passports held, or are photocopies taken and originals returned - please photograph some documents saved
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Are deposits for work related materials (uniforms etc) required
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What items require a deposit?
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What systems are in place to ensure that all workers have permission to work in the country in which they are employed?
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Does the site speak to workers regularly - what questions are asked?
Working conditions are safe and hygienic
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A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of the industry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to health arising out of, associated with, or occurring in the course of work by minimising, so far as is reasonably practicable, the causes of hazards inherent in the working environments
•Workers shall receive regular and recorded health and safety training, and such training shall be repeated for new or reassigned workers
• Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage, shall be provided
• Accommodation, where provided, shall be clean, safe, and meet the basic needs of workers
• The company observing the code shall assign responsibility for health and safety to a senior management representative. -
Has the site had any serious accidents in the last 12 months
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What health and safety managment systems are in place
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What health and safety training is provided?
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How are health and safety issues discussed, managed and communicated
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Who is the Health and Safety representative
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Responsibility for use and content of the kits should be allocated to first aid personnel. Sites should have at least 1 well maintained and unlocked first aid box per 100 workers. This must be accessible and at least 1 person should be trained to use its content. When required by local law a first paid room must be provided.
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How is the First Aid managed on site?
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Are there separate toilets for Men and Women
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Is drinking water provided for workers?
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Are appropriate facilities for food storage provided?
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Are Fire Exits are accessible at all times?
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Is there sufficient and appropriate fire fighting equipment - please detail in notes
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How often are the site electrics checked and maintained and by whom? How often are electrical appliances, including those in accommodation, checked and by whom?
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What PPE Work instructions and documented training are available for workers handling heavy machinery and hazardous chemicals?
Sainsburys related supplier audit
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Sites are required to have sufficient experienced and trained resources within their business to appropriately implement Sainsburys Ethical Trade Requirements in their own operations and full supply chains and manage compliance against these requirements.
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Is this a Sainsburys related supplier audit
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access to safe accommodation with specific requirements on occupation /usage levels, space per person and access to facilities per head count based on peak use
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Access to safe transport to and from work
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Provision of PPE including protection from the elements (Sun, wet, cold)
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Access to field based facilities including rest areas, storage for personal effects, relief from exposure to temperature, sun and wet conditions
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Access to training including food safety, hygiene, Modern slavery and labour exploitation. This should include management training for all sites and for the auditors carrying out validation and verification checks. please make notes
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access to services for all workers including financial medical and community
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worker engagement to provide feedback and continual improvement though committees company board representation communication worker welfare checks, worker survey etc - please make notes
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Ensure ethical champions are in place and appropriately trained
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Effectively manage temporary labour including
- Responsible Recruitment
- Transparency of recruitment chains
- Contracts in place for all workers and meeting legal requirements
- wages deductions visible and transparent including fees paid by workers (transport/visa solution services)
- Induction training
- Worker welfare operational health and safety, working hours, fair treatment and equal opportunities