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SLCP Verification Protocol

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Converged Assessment.

Collaborative Action.
Improved Working Conditions.

Social and Labor Convergence Program (SLCP)


Verification Protocol

June 29, 2020

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Converged Assessment.
Collaborative Action.
Improved Working Conditions.

Change Log

Date Section Change Summary

2019/11/27 Glossary Multiple terms updated to match our one,


standard SLCP glossary

2019/11/27 Overview of the SLCP Assessment Diagram with new details about Passive
Process - 2019 Data Hosting & Accredited Host and sharing
Sharing

2019/11/27 Details of the SLCP Assessment Improved explanation of timeline/ timeframe


Process

2019/11/27 Pre-Onsite Verification Actions - 2. Place to find date of Self/Joint-Assessment


Facility discusses verification submission
cost/timeline offline with VBs

2019/11/27 Pre-Onsite Verification Actions - 9. More details around person-day requirements and
VB/ Verifier reviews Self/ Joint- documentation review
Assessment to determine correct
person-day requirements

2019/11/27 Onsite Verification Actions - 14. Requirement to use translators who are trained to
Verifier conducts onsite verification understand social compliance topics.

Wage and hour record sampling: If there are no


clear high and low production months, then the
selection must be random.

2019/11/27 Annex III Verification Information on on-site verification that must


Communication Template occur no more than 2 months after the
(suggested communication) completion of the Self/ Joint-Assessment.

2020/06/29 Entire document Updating of hyperlinks and email addresses


throughout the document

Edits to make language clearer

2020/06/29 Entire document Additions related to COVID-19, e.g. verification


scheduling, onsite verification procedures, etc.

2020/06/29 New Annex III: COVID-19 – Annex III gives detailed instructions on how to
Enhancement to Verified include COVID-19 information, as applicable, in
Assessment Report Information the self/joint-assessment and verification

2020/06/29 Terms of Use New CAF Terms of Use as referenced on the


Gateway

2020/06/29 Glossary Additions to the Glossary

2020/06/29 Overview of the SLCP Assessment Inclusion of short statement about Verification
Process Data for “Accurate” items (more details included
in Verifier Guidance)

Updated graphic to explain the assessment


process

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2020/06/29 Eligibility of Verifiers Clearer language about eligibility to conduct a


verification

Reference to Verifier Status Maintenance

2020/06/29 Details of the SLCP Assessment Added new statuses of VRE, VRQ and made some
Process additions/ changes to timeframes for edit/review
by Verifier and facility

Updated visual of SLCP assessment process with


VRQ, VRE

2020/06/29 3.-5. Facility account creation on AH Note for newly operation facilities; min. 3 months
platform, initiating self/joint- data required in self-assessment
assessment, completing self/joint-
assessment

2020/06/29 7. VB assigns Verifier on Gateway Ensuring meaning of no two verifications in a row


by same Verifier is clear

2020/06/29 9. VB/ Verifier reviews self/joint- More clarity on person-day assignments if step
assessment to determine correct 1+2 or step 1+2+3 is selected
person-day requirements

2020/06/29 11. Verifier reviews self/joint- Background check addition: previous social audit/
assessment in detail to prepare for SLCP reports
onsite verification, including facility
background check

2020/06/29 14. Verifier conducts onsite Additions to:


verification (opening meeting, walk o clarify potential change to person-days
through, interviews, document when onsite;
review, closing meeting) o ensure all types of production employees
are considered in verification;
o clarify language requirements;
o remind Verifier to add translator
information in Verification Details
o add detail around management
interviews;
o cover the topic of denied access
2020/06/29 15. Verifier focuses on Verification Addition of Verifier guidance around reporting
Summary; addresses facility verified assessment data to users other than the
questions/ concerns during closing facility
meeting

2020/06/29 16.-20. Resolving facility concerns, Explanation of new statuses VRQ and VRE and
filling in Tool, completing report Verifier responsibilities
online to run AH checks, VB quality
check, VRQ check with VRE edits, Recommendation for Verifier/ Verifier Body
changing assessment status to VRC downloading of verified assessment report for
document retention

2020/06/29 21.-24. Facility reviews verified Explanation of new status VRE and Verifier
assessment, connects offline with responsibilities
Verifier/ VB for concerns and

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requests edits as necessary, accepts New timeframe for facility report finalization as
verification or raises Dispute multiple edit rounds can occur (14 calendar days
instead of 10)
2020/06/29 Annex IV Verification Revision to make it easier to read/ understand
Communication Template
(suggested communication) Addition of COVID-19 document reference

2020/06/29 Annex VII Additional On-site More details about what types of employees to
Verification Information interview

Management Interview guidance

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Table of Contents

Terms of Use................................................................................................................................ 7
Glossary....................................................................................................................................... 8
Overview of the SLCP Assessment Process .................................................................................. 10
Overview of the Converged Assessment Framework ................................................................... 12
Introduction to the SLCP Verification Protocol ............................................................................ 13
Eligibility of Verifiers .................................................................................................................. 14
Details of the SLCP Assessment Process ...................................................................................... 15
Pre-Onsite Verification Actions ................................................................................................... 21
1. Account creation on Gateway ............................................................................................. 21
2. Facility discusses verification cost/timeline offline with VBs ................................................. 21
3.-5. Facility account creation on AH platform, initiating self/joint-assessment, completing
self/joint-assessment ............................................................................................................. 22
6. Facility selects VB on AH platform ....................................................................................... 23
7. VB assigns Verifier on Gateway ........................................................................................... 23
8. VB/ Verifier obtain access to self/joint-assessment on AH along with any uploaded documents
.............................................................................................................................................. 24
9. VB/ Verifier reviews self/joint-assessment to determine correct person-day requirements ... 24
10. Verifier conducts off-site documents review, if applicable .................................................. 26
11. Verifier reviews self/joint-assessment in detail to prepare for onsite verification, including
facility background check ....................................................................................................... 27
12. Pre-verification communication to facility (document list, verification planning information
et al.) ..................................................................................................................................... 27
13. Verifier downloads Data Collection Tool from AH platform for back-up during onsite
verification............................................................................................................................. 28
Onsite Verification Actions ......................................................................................................... 29
14. Verifier conducts onsite verification (opening meeting, walk through, interviews, document
review, closing meeting) ......................................................................................................... 29
15. Verifier focuses on Verification Summary; addresses facility questions/ concerns during
closing meeting ...................................................................................................................... 34
16.-20. Resolving facility concerns, filling in Tool, completing report online to run AH checks, VB
quality check, VRQ check with VRE edits, changing assessment status to VRC .......................... 36
21.-24. Facility reviews verified assessment, connects offline with Verifier/ VB for concerns and
requests edits as necessary, accepts verification or raises Dispute ........................................... 37
25. If accepted: facility shares verified assessment via the Gateway and/or the Accredited Host
.............................................................................................................................................. 38
26.–28. If Dispute: VOO deems substantiated or not substantiated .......................................... 38
29. VOO Quality Assurance Procedures for accepted verified assessments ............................... 38
Annex I Verifier Expectations ..................................................................................................... 40
Annex II: Filtering of Verifier Body and Verifier ........................................................................... 42
Annex III: COVID-19 – Enhancement to Verified Assessment Report Information ......................... 44
Annex IV Verification Communication Template (suggested communication) .............................. 52
Annex V Document List .............................................................................................................. 54

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Annex VI SLCP Code of Conduct .................................................................................................. 57


Annex VII Additional On-site Verification Information................................................................. 60

Disclaimer:
This file represents only one aspect of the SLCP assessment framework. The file should be viewed in conjunction with the other 2 elements
of the Converged Assessment Framework: Data Collection Tool and Verifier Guidance.

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Terms of Use

Visit the SLCP Gateway for the CAF terms of use.

Pay special attention to:


- Rules of conduct and restrictions on permissible use
- Accuracy of Results
- Feedback and Third-Party Information

In case of questions: please contact info@slconvergence.org

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Glossary

“Accredited Host“ Third party/ external service provider approved by SLCP to store SLCP assessment data on
their platform and provide additional data analytics and sharing services to users such as brands, standard
holders, and manufacturers.
“Passive Accredited Host” Third party/ external service provider approved by SLCP to 1) store SLCP
assessment data on their platform and 2) provide additional data analytics and sharing services to users such
as brands, standard holders, and manufacturers. The SLCP Gateway (central repository for all SLCP verified
assessments) can submit data to a Passive Accredited Host if a facility initiates this sharing process. Only
assessments in Verification Finalized (VRF) status are received by the Passive Accredited Host. The Passive
Accredited Host is not involved in the active execution of the SLCP assessment process, i.e. self/joint
assessment data gathering and verification data gathering.
“Active Accredited Host" Third party/ external service provider approved by SLCP to 1) provide a technology
platform to allow data entry by facilities and Verifiers during the SLCP assessment and
verification; 2) store SLCP assessment data on their platform and 3) provide additional data analytics and
sharing services to users such as brands, standard holders, and manufacturers. The SLCP process must be
completed on one of the Active Accredited Host platforms a facility can choose which one they want to use.
“Converged Assessment Framework” or “CAF” The Data Collection Tool and verification methodology,
developed by SLCP and downloadable from the Gateway. Consists of three elements: 1. Data Collection Tool;
2. Verification Protocol; and 3. Verifier Guidance.
“CAF Assessment Process” means a procedure, as developed in the context of SLCP, serving to implement the
Converged Assessment Framework, starting with self/joint-assessment for facilities that is augmented via
verification by external parties and verification oversight and a methodology for data sharing by the facility,
Verifier and Accredited Host via the ITC Gateway.
“Data Collection Tool” or “Tool” Element 1 of the Converged Assessment Framework. ‘Questionnaire’ used to
gather data on working conditions in a facility and used by the Verifier to verify this data. Contains all the
assessment questions that a facility must answer through a self/joint-assessment. When completed, includes
the answers by the facility and the Verifier. Can be filled in online on an Accredited Host platform or offline
through an excel file downloadable from an Accredited Host.
“ITC Gateway” or “Gateway” The central repository of SLCP verified assessments. All verified assessments are
stored safely on an UN server. Registered facilities have access to their verified assessments at all times and
can download these. Apart from this the Gateway serves 4 critical functions:
1. Central (and open) resource of Converged Assessment Framework, SLCP process and related information
and support material
2. Account Management and unique IDs for facilities, Verifier Bodies and Verifiers
3. Management of statuses of the SLCP assessment cycle – by continuous updates with each of the Accredited
Hosts. Facilities can see the status of their SLCP assessment throughout and at all times.
4. Re(distribution) of verified assessments (VRF status) to Accredited Hosts and other ad-hoc users, with
facility permission.
“Self-assessment” Facility alone fills in the Data Collection Tool (CAF Element 1).
“Joint-assessment” Facility contracts outside help to fill in the Data Collection Tool (CAF Element 1).
“SLCP” means the Social & Labor Convergence Program (SLCP), an independent multi-stakeholder program
which has developed the Converged Assessment Framework (CAF) and a data hosting and sharing process.
“User” means end users of the CAF including facilities, Verifier Bodies, Verifiers and Accredited Hosts,
registered with the ITC Gateway to use the Service.
“Verification Oversight Organization (VOO)” Entity responsible for the day-to-day management of SLCP
verifications. It manages the selection of Verifier Bodies and Verifiers (qualification criteria, application and
approval process), maintains an updated overview of SLCP approved Verifiers and associated VBs on the
Gateway, sets Quality Assurance (QA) procedures in collaboration with SLCP, executes QA activity, develops
the scoring system for SLCP approved Verifiers and VBs, collects Verifiers’ performance data, provides
verification support desk for all SLCP system users, gathers feedback from SLCP system users, and handles
dispute resolution between a facility and a Verifier.
“Verification Protocol” Element 2 of the Converged Assessment Framework. The document that contains the
procedures, rules and process requirements for conducting an SLCP verification.
“Verified assessment” uses the CAF and follows the CAF Assessment Process and results in a report in pdf,

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excel and html format made available to facilities and shareable by facilities on the ITC Gateway.
“Verifier” Person qualified to perform an SLCP verification to ensure the completeness and accuracy of the
data collected through self/joint-assessment of facilities, using the CAF.
“Verifier Body” The organization to which a Verifier belongs. Is responsible for assigning Verifiers when an
SLCP verification is requested.
“Verifier Guidance” Element 3 of the Converged Assessment Framework. The document that helps Verifiers
complete the verified assessment report by giving guidance on how to verify a facility’s answers to questions
in the Data Collection Tool.

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Overview of the SLCP Assessment Process

The SLCP process consists of three main steps:

Step 1) Data Collection


Step 2) Data Verification
Step 3) Data Hosting and Sharing

STEP 1: Data Collection


Collection can be done by either self-assessment (facility only) or joint-assessment (facility + external
assistance), online or offline by using the Data Collection Tool.
Self/joint-assessment can be carried out via an excel document downloaded from the Accredited Host (AH)
or online via an AH platform. If the facility has a stable internet connection, it is recommended to use the
online AH platform to complete the self/joint-assessment.
The objective of this Step 1 is for the facility to enter complete and accurate data into the Data Collection
Tool. SLCP believes in facility ownership. In the SLCP process, the facility owns the process. They start it, and
they own the data at the end of it. That is why SLCP asks the facility to first fill in the assessment data to get
a full understanding of its working conditions.
STEP 2: Data Verification
The Verifier will check the correctness and completeness of the data gathered through the Data Collection
Tool. They will confirm or provide corrections to the original self/joint-assessment data online on the AH
platform or offline via an excel document downloaded from the AH. If you have a stable internet
connection, it is recommended to use the online AH platform to complete the verification.
For each question in the Tool, even if the facility did not provide an answer in the self/joint-assessment, the
Verifier must indicate “Accurate/ Inaccurate/ No Response Provided/ Updated during Verification” in the
Data Collection Tool. If “Inaccurate/ No Response Provided/ Updated during Verification” the Verifier must
enter a “Corrected Response” and “Verification Data” to support the corrected outcome. If “Accurate”, the
Verifier is encouraged to provide “Verification Data” where there is a legal non-compliance or a concern
relating to general social compliance norms. More information about how to complete the Data Collection
Tool is in the Verifier Guidance.
A Verification Oversight Organization (VOO) is in place to oversee the integrity of SLCP verification and
quality of verified assessment data.
The objective of this Step 2 is to verify the completeness and correctness of data gathered in the self/joint-
assessment. Verification of self/joint-assessment data is a crucial step in the SLCP process to ensure end-
users’ acceptance of SLCP data and the replacement of their own audit methodologies with the SLCP
process.
STEP 3: Data Hosting & Sharing
The verified assessment report, with facility permission, will be shared through a semi-decentralized model
with a Gateway and AHs.
The objective of this Step 3 is to enable a secure way of sharing verified data with Users so multiple Users
can use the data to inform their (proprietary) social responsibility benchmarks and compliance programs.

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Below is a visual depiction of the assessment process.
Note:
o The SLCP process begins with registration of all active parties on the Gateway.
o The Active Accredited Host is used to facilitate the data collection for self/joint-assessment and verification and sharing of verified data.
o The Passive Accredited Host only receives verified data from the Gateway, after completion of the full assessment process on an Active AH, and shares verified
data with Users.

Facility chooses an
Accredited Host Facility uses an Active Accredited Host
Facilities can
Platform to:
share data with
ü Create an account brands, standard
ü Link to their SLCP Gateway account holders & other
Facility creates ü Complete the SLCP self-assessment stakeholders,
account in the ü Select a Verifier Body directly from the
SLCP Gateway ü Check verification results Gateway or via
an Accredited
Host.

Facility owns
the verified
data & can
choose how Facility can share their verified assessment
they share it report with any of the Active or Passive
Accredited Host Platforms, which can:

ü Add scoring or analysis


VERIFIED ü Provide options to create a CAP
ASSESSMENT
ü Share data with other platform users

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Overview of the Converged Assessment Framework

It consists of three elements:

Data Collection Tool Verification Protocol Verifier Guidance


• Used by facility & Verifier • Used mainly by Verifier for • Used by Verifier
• Records facility and verified verification methodology/ • Detailed information about
data procedures/ rules how to complete the Data
• Executed through AH online • FYI for facility to understand Collection Tool and provide
platform (recommended) or verification process data for the verified
through downloadable excel assessment
from AH

The Converged Assessment Framework is standard neutral. That means:

SLCP Converged Assessment SLCP Converged Assessment


Framework does Framework does NOT
• Collect self-reported demographic, compliance • Set minimum requirements
related and performance information from • Be a scoring/ranking system, certification
facilities program or Code of Conduct
• Employ a robust verification process • Provide corrective action plans or engage in
• Facilitate operation (data hosting & sharing) other follow-up actions

There is no judgement of the data collected through the SLCP process. It is objective data about the current
social and labor conditions in a facility. This makes SLCP compatible with all compliance and certification
programs. Users can use the data to come to their own conclusions and proceed with any applicable corrective
action, remediation efforts or capacity/ capability building.

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Introduction to the SLCP Verification Protocol

The SLCP Verification Protocol specifies procedures, rules and process requirements to complete the
verification. The objective of the verification is to verify the completeness and correctness of data gathered in
the self/joint-assessment.

It is important to highlight that this is not a conformance type of assessment/audit to determine to what
extent working conditions comply with a certification or social compliance standard. To differentiate that this
agnostic data collection (not dependent on a particular standard) and reporting varies from traditional
compliance auditing, we use different terminology. This program will specify:
o Verification rather than Audit or Assessment
o Verifier rather than Auditor

“Audit”: A systematic review or assessment of something.

“Verification”: The process of establishing the truth, accuracy, or validity of something.

Source: Oxford University Press

Audit SLCP Verification


• Inspection by external party (2nd or 3rd party • Verification of facility assessment of social and
auditor) to assess social and labor conditions labor conditions
• Pass or fail regarding social and labor • Agnostic data collection without judgement
conditions topics • Facility active participant in verification
• Facility subject to audit process process, e.g. by providing facility information
• Brand owner of audit report and attached upfront
Corrective Action Plan • Facility owner of verified assessment report
(facility permission needed for data sharing)

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Eligibility of Verifiers

Only SLCP approved Verifiers can produce a valid verified assessment report.

Verifiers will only be eligible for a specific verification if:


o They did not verify the facility’s previous assessment (this rule applies even if a facility has moved
locations);
o Their Verifier Body was not involved in the joint-assessment that is now undergoing verification.

For more information about the VB and Verifier application process, Verifier qualifications and Verifier Status
Maintenance, please read the SLCP Quality Assurance Manual.

In addition to specific Verifier criteria, SLCP has Verifier expectations (see Annex I) that address requirements
in terms of ethics, Verifier behavior and competencies, and personal and facility safety. The Verifier must meet
these expectations.

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Details of the SLCP Assessment Process

In the Overview of the SLCP Assessment Process, we presented the 3 main Steps to the process. Now, we dive deeper into the process and present the:
o Activities/ actions of all SLCP actors
o SLCP assessment status associated with each applicable action
o Estimated timeline associated with each action.

More information, if applicable, to each Action Number will be presented following the summary table below.

SLCP Assessment Statuses:


ASI-Assessment Initiated ASC-Assessment Completed
VRP-Verification in Progress VRQ-Verification Quality Check VRE-Verification being Edited VRC-Verification Completed VRF-Verification Finalized
VRD-Verification Disputed VRI-Verification Invalidated

SLCP Actors:
F-Facility V-Verifier VB-Verifier Body GW-Gateway AH-Accredited Host VOO-Verification Oversight Organization

SLCP ACTORS
NO. ACTION ESTIMATED TIMELINE1
STATUS F V VB GW AH VOO
1. Account creation on Gateway
2. Facility discusses verification cost/timeline offline with Verifier
Bodies; note verification can be semi-announced with a 10-day
window and cost/timeline will likely be estimates as self/joint- Week 0
assessment information is needed to determine exact person- All steps before Week 0 are prior to the start of the
day requirements for verification verification process. Note it takes facility on average
2 weeks to complete self/joint-assessment as Tool is
3. Facility creates account on Accredited Host platform using complex and multiple individuals may be required
Facility ID from Gateway to provide input/ documentation
4. Facility accesses Data Collection Tool through AH and initiates
ASI
self/joint-assessment
5. Facility completes self/joint-assessment; recommend online ASC

1There are various factors that impact the actual assessment process timeline. This is the recommended timeframe. It is not a strict requirement unless explicitly noted in
subsequent sections of the Protocol (e.g. time allowed between completion of self/joint-assessment and the onsite verification).

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SLCP ACTORS
NO. ACTION ESTIMATED TIMELINE1
STATUS F V VB GW AH VOO
completion but download into excel from AH is available with
final step of upload to AH required
6. Facility selects Verifier Body to conduct verification on ASI or
Accredited Host platform ASC
7. Verifier Body assigns Verifier on Gateway VRP
8. Verifier Body/ Verifier obtain access to non-editable/ locked
self/joint-assessment data on AH platform along with VRP
Week 1
documents the facility uploaded
9. Verifier Body/ Verifier reviews self/joint-assessment to
VRP
determine correct person-day requirements
10. Verifier conducts off-site documents review, if applicable Typically, no earlier than week 3
Typically, no later than week 6
Note self/joint-assessment must be delivered to
VRP Verifier at least 10 working days prior to scheduled
onsite visit. Some Verifier Bodies may need up to 4
weeks advanced notice to schedule a verification, as
Verifier schedules are booked well in advance.
11. Verifier reviews self/joint-assessment in detail to prepare for
VRP
onsite verification, which includes facility background check
12. Verifier or Verifier Body provide pre-verification communication
to facility, including document list and verification planning VRP Typically, no earlier than week 3
Typically, no later than week 7
information according to Verification Protocol requirements
Note Verifier availability may require up to 4 weeks
13. Verifier downloads Data Collection Tool from AH platform with advanced notice
non-editable/ locked self/joint-assessment data to have back-
VRP
up during onsite verification in case AH platform connectivity
issues occur
14. Verifier conducts onsite verification following Verification
Protocol requirements, including opening meeting, document
review, interviews, facility walk through, and closing meeting; VRP
facility cooperates with Verifier to provide access to site,
documents, personnel Typically, no earlier than week 4

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SLCP ACTORS
NO. ACTION ESTIMATED TIMELINE1
STATUS F V VB GW AH VOO
15. Verifier focuses on entering “Updated during Verification”, Typically, no later than week 8
“Inaccurate”, “Legal Flag” items to inform Verification Summary Note Verifier availability may require up to 4 weeks
for closing meeting; completion online or in downloaded excel VRP advanced notice and verification can be semi-
offline; Verifier addresses any facility questions/ concerns announced with 10-day window
during closing meeting
16. Verifier or Verifier Body resolves any further facility concerns/
questions about verification latest 48 hours after onsite
VRP
verification ends then proceeds with filling in the Data
Collection Tool (recommend online)
17. Verifier uploads offline verification to online AH platform
and/or fills in verification online and follows Accredited Host VRP Typically, no earlier than week 6
automated checks/flags for proper completion Typically, no later than week 10
18. Verifier Body conducts quality check of Verifier's work and
either Verifier or Verifier Body changes the assessment status to VRC
“Verification Completed” on AH
19. Automated Data Quality checks are performed on the verified
VRQ
assessment data submitted by the Verifier
20. If VRQ fails, the Verifier reviews the failures on AH platform and VRQ failures are almost immediately submitted to
makes necessary edits and -again- changes status to Verifier after Verifier completes verification (VRC);
“Verification Completed on AH Verifier can choose to immediately review and
VRE
make changes and submit again to VRC or after 4
calendar days status automatically changes from
VRE to VRC with or without edits by Verifier
21. Facility reviews the verified assessment online or offline in excel
through download from AH. The facility has 14 calendar days to
review and request edits by the Verifier before facility’s manual VRC
finalization by changing status to VRF or AH’s automated
finalization on calendar day 15.
22. Facility reaches out to Verifier Body/ Verifier directly (offline)
VRC and
with any concerns/ questions about the verification data. Once
maybe
edits agreed between Verifier Body/ Verifier and facility, facility
VRE
changes VRC to VRE to allow Verifier access to the assessment

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SLCP ACTORS
NO. ACTION ESTIMATED TIMELINE1
STATUS F V VB GW AH VOO
for edits. Typically, no earlier than week 8
23. Verifier reviews facility concerns and edits the assessment as Typically, no later than week 12
agreed. Verifier changes status to VRC so the facility can review
the edits and request further changes as necessary. Status
VRE then
change from VRC to VRE to VRC can occur as often as necessary
VRC
within the 14 calendar days. On calendar day 15 the process
ends and the assessment changes to VRF, unless the facility
manually changes to VRF before 14 calendar days are up.
24. Facility changes assessment status to “Verification Finalized" by
accepting the verification or opens a “Dispute” if there are
complaints about Verifier following procedure or Verifier VRF or
conduct. If facility takes no action, assessment status VRD
automatically changes to VRF after 14 calendar day review and
edit period ends.
25. In VRF, facility can share the accepted verified assessment via
the Gateway and/or the Accredited Host with other Users and VRF
other AH platforms
26. If Dispute opened, VOO evaluates the validity of the Dispute
and accesses the verified assessment data via the Gateway; VRD
facility can only open Dispute process once
27. If Dispute substantiated, depending on the outcome, Typically, no earlier than week 11
o VOO invalidates verified assessment (VOO notifies facility Typically, no later than week 15
VRI or
and 4 calendar days later changes to VRI) OR Note VOO evaluates validity of Dispute within 2
VRE and
o VOO returns assessment to Verifier for edits and final facility working days. If substantiated, VOO attempts to
VRC
review (Verifier and facility have 5 calendar days to make resolve Dispute within 10 days and gives 4 calendar
edits and review) day notice prior to change to VRI
28. If Dispute not substantiated, VOO finalizes verified assessment
and changes status to “Verification Finalized" after 4 calendar VRF
day notice to facility; see point 25 for next steps.
29. Note that in VRF, the VOO can choose to conduct quality Typically, no earlier than week 16
VRI
assurance procedures for any verified assessment; outcome of Typically, no later than week 22

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SLCP ACTORS
NO. ACTION ESTIMATED TIMELINE1
STATUS F V VB GW AH VOO
this verification oversight activity may result in invalidation of a Note duplicate verifications (most time intensive QA
verified assessment procedure) can take 8-10 weeks after VRF to
complete

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The following image also shows a summary of the SLCP assessment actions:

Facility starting and completing Self/ Joint-Assessment ASI ASC ASI or ASC

Facility creates an Facility initiates Facility contacts


assessment and VBs (list Gatew ay) Facility selects
account on the
completes it via telephone or eligible VB for
Gatew ay and Facility creates
links with AH online on AH e-mail for quotes. verification on AH
account on AH

ASI ASC

Facility initiates Facility fills in the Facility uploads


assessment and assessment assessment and
dow nloads Tool offline in Excel completes it on
(Excel) on AH AH

Verifier Body (VB) and Verifier taking action to complete or edit the verification VRP
VRQ
Verifier completes
VRE Verifier completes verification on- VB assigns
verification on- line on AH Verifier(s) to
Verifier edits line on AH VRP
SLCP/ VOO specific
verification as assessment
review
result of verification data
SLCP/ VOO QA, Verifier takes
and either send
facility QA or action on AH and
to edit or send to Verifier fills in the
VRD facility review Verifier uploads dow nloads Excel
verification offline
verification and
in Excel with facility data LEGEND
completes it on on AH
AH Accredited Host (AH)

Gatew ay
Facility reviewing, accepting or disputing the verification and sharing the verified assessment report
Offline
VRF
VRC Facility can view, ASI Assessment Initiated
dow nload and/ or ASC Assessment Completed
Facility approves
VRD share verified VRP Verification in Progress
and finalizes assessment VRQ Verification Quality check
Facility reviews verification VRE Verification being Edited
verification VOO finalizes VRC Verification Completed
Dispute not
verified assessment VRF VRF Verification Finalized
Dispute substantiated
resolution VRI or back to VRD Verification Disputed
VOO invalidates verified
Facility disputes process w ith Dispute assessment OR returns VRE without VRI Verification Invalidated
verification on AH VOO substantiated to Verifier for edits and VRD option ASD Assessment Deleted
Facility review

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Pre-Onsite Verification Actions

Any mandatory requirement applicable to the Verifier Body or Verifier will be highlighted through use of this
icon:

1. Account creation on Gateway

Follow instructions on the Gateway to create your account as a facility or as approved Verifier Body and
approved Verifier.

2. Facility discusses verification cost/timeline offline with VBs

A list that includes all SLCP approved Verifier Bodies is available on the Gateway. However, not all Verifier
Bodies will be eligible to conduct a verification in a specific facility. A list of Verifier Bodies available for the
specific verification becomes visible on an Accredited Host platform once the facility requests a verification.
Eligibility is based on whether the Verifier Body is operating in the country in which the verification will take
place and which languages the Verifier Body can support through its Verifiers.

Prior to Verifier Body selection, the facility should have offline conversations with Verifier Bodies regarding
quotes and services. If COVID-19 is a concern, the Verifier Body should communicate below Annex III to
facilities to educate them on how to incorporate specific information into the self/joint-assessment and how
the Verifier is going to address COVID-19 in the verified assessment report. Once agreement is reached
(offline) between the facility and the Verifier Body, the facility selects that Verifier Body on the Accredited
Host platform.

SLCP recommends having these offline conversations even prior to self/joint-assessment completion, as
timelines are short.

Verification must happen within 2 months of completion of the self/joint-assessment. The date the
Verifier must reference to determine completion of the self/joint-assessment is in the Data Collection Tool,
Facility Profile section, Row 30 far right column UVW (offline Excel location) question FP_BI-22: Date of self/ or
joint-assessment submission (DD/MM/YYYY). Should the facility/Verifier Body miss this timeframe for
verification, the facility must contact SLCP through the Helpdesk to change the status of the assessment back
to ASI-Assessment Initiated so the facility can update the self/joint-assessment.

SLCP also recommends scheduling the verification at a time where at least 80% of the workforce is active, i.e.
to avoid scheduling the verification during very low volume or holiday seasons.

During the scheduling process, the VB must discuss with the facility any changes in their workforce due
to COVID-19. If the facility has experienced a change of 50% or more of their workforce since the date of
completion of their self-assessment, the Verifier Body must advise the facility to review and update the self-
assessment. Note that if the workforce has changed considerably, there may be multiple questions that need
to be updated by the facility, not just worker demographic information.

The facility can ask potential Verifier Bodies (available on the Gateway) if they operate in the country of
verification and if their Verifiers speak the language(s) of the employees and also provide the estimated date
of completion of self/joint-assessment so Verifier Bodies can evaluate scheduling. SLCP is committed to the
principle of being able to communicate with any person at the facility. This can be challenging at sites with
multiple languages. See Action No. 14. for more information.

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Prior to Verifier Body selection, the Verifier Body does not have access to the self/joint-assessment data.
When providing quotes to the facility, the Verifier Body will request facility data, such as, location, number of
employees and languages spoken to estimate the onsite verification duration. The verification duration can
only be estimated until the Verifier Body has access to the self/joint-assessment data and can properly assess
verification requirements.

Further, in relation to COVID-19 and the amount of onsite time required: onsite time is based on the
facility’s current workforce (workforce at the time of onsite verification). Changes to the workforce due to
COVID-19 may impact the amount of time Verifier Bodies spend on site. During scheduling (and also when
onsite if prior information was not available see Action No 14. onwards), the Verifier Body must confirm if any
major changes to the workforce are permanent changes (e.g. terminations) or temporary changes (e.g.
furloughs). If the changes are temporary, then these furloughed employees must also be considered when
determining the amount of onsite time.

Verification can be announced or semi-announced with a 10-day window. The facility determines the
type of announcement. Should the facility wish to have an unannounced verification, this is also possible, but
SLCP does not require the verification to be unannounced. In planning, the Verifier Body must consider local/
national holidays as well as any specific dates or date ranges that the facility will be unavailable for
verification.

The verification must take place over consecutive days.

The facility and the Verifier Body must have a documented agreement with a specified date or date
range for onsite verification.

3.-5. Facility account creation on AH platform, initiating self/joint-assessment, completing


self/joint-assessment

Modules 3 and 7 of the SLCP e-learning explain these actions in detail. Facilities can also access the Helpdesk
FAQs to obtain more information. Once the facility initiates the self/joint-assessment on the Accredited Host
site, the assessment status is “Assessment Initiated”. Once the facility completes the self/joint-assessment on
the Accredited Host site, the assessment status changes to “Assessment Completed”.

Note for newly operational facilities: At minimum, the facility must include 3 months of operation in the
self or joint-assessment, because the Verifier needs to review 3 sets of records during verification. However,
before completing the self/joint-assessment, SLCP recommends the facility discusses the SLCP assessment
process with their customers to see if customers would prefer more months in operation prior to receiving a
verified assessment report.

If a facility has difficulties understanding or completing the self-assessment, they can seek external assistance
and thus complete a joint-assessment. Examples of entities that can provide external assistance are SLCP
approved Verifier Bodies, SLCP signatories like brands, agents, civil society organizations or other social
responsibility consultancies.

On the Accredited Host platform, the facility can upload documents or photos to provide more information for
every question. All uploads will be attached to the final verified assessment. Should the facility choose to share
the assessment with a business partner, the final verified assessment along with any attached documents/
photos will be shared.

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SLCP cannot police the type of documentation that the facility uploads. However, SLCP strongly recommends
not to upload records that can violate an individual’s privacy or data protection. Examples of appropriate
documents to upload are policies, procedures, handbooks, training content, (risk) assessments, and
organization’s certificates/ certifications.

6. Facility selects VB on AH platform

Modules 3 and 7 of the SLCP e-learning explain these actions in detail. Facilities can also access the Helpdesk
FAQs to obtain more information.

In either “Assessment Initiated” or “Assessment Completed” status, the facility can select a VB on the
Accredited Host platform.

Please refer to Annex II for more information on how Verifier Bodies are designated eligible for a specific
facility.

If there are no Verifier Bodies for selection on the AH platform, the facility must contact the Helpdesk.

7. VB assigns Verifier on Gateway

To ensure data integrity and prevent bias, the facility cannot choose the SLCP approved Verifier. Rather, the
Verifier Body assigns the SLCP approved Verifier to a verification. They do this on the Gateway where a list of
SLCP approved Verifiers is available for selection.

The Gateway already provides some filtering to ensure some rules are enforced for Verifier selection, but
it is still the Verifier Body’s responsibility to ensure all rules for Verifier selection are enforced.

The Verifier Body must follow verification person-day minimum requirements (see Action No. 9. below)
and must assign more than one Verifier accordingly.

Verifiers will only be eligible for a specific verification if:


o They did not verify the facility’s previous assessment (this rule applies even if a facility has moved
locations);
o Their Verifier Body was not involved in the joint-assessment that is now undergoing verification.

All Verifiers are encouraged to meet the following requirements to be eligible for a specific verification:
o Gender is appropriate for the facility circumstances;
o Gender is different from the previous assessment, if such switch in gender will facilitate gathering of
different perspectives during the present verification.

At least one Verifier must meet the following requirements to be eligible for a specific verification:
o Eligible to verify in the country of verification according to VOO qualification;
o Speaks at least one of the employee languages;

Any additional Verifiers are encouraged to meet the following requirements to be eligible for a specific
verification:
o Eligible to verify in the country of verification according to VOO qualification;
o Speaks at least one of the employee languages;

If the Verifier Body cannot follow the requirements, it must contact the VOO via slcp@sumerra.com.

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Verifier Bodies can also access the Helpdesk FAQs to obtain more instructions on how to use the Gateway.

Please refer to Annex II for more information on how Verifier Bodies and Verifiers are designated eligible for a
specific facility.

Once the Verifier takes action related to the assigned verification on the Accredited Host platform, the
assessment status changes from “Assessment Completed” to “Verification in Progress”.

8. VB/ Verifier obtain access to self/joint-assessment on AH along with any uploaded


documents

The Accredited Host platform is configured to ensure the self/joint-assessment is completed according
to SLCP minimum requirements to proceed to the next step of verification.

The self/joint-assessment must be accessible to the Verifier at least 10 working days prior to the
scheduled onsite visit. Failure by the facility to submit the assessment on time will be considered
grounds for re-scheduling the onsite visit date or date range.

E-learning module 7 presents each Accredited Host platform. Verifier Bodies/ Verifiers can also access the
Helpdesk FAQs to obtain more information.

9. VB/ Verifier reviews self/joint-assessment to determine correct person-day


requirements

It is likely that the Verifier Body has already provided the facility with a cost and person-day estimate for the
verification. However, the Verifier Body can only accurately determine how many person-days are needed and
if an off-site document review is possible once they have access to the self/ joint-assessment.
o Only facilities may request an off-site documents review, they must not be required by Verifier
Bodies. Based on the documentation submitted, the Verifier Body determines if off-site Verification is
possible. The Verifier Body/ Verifier can also determine if onsite person-days can be reduced if a
documentation review is conducted prior to onsite verification.
o The data now shows how much of the self/joint-assessment has been completed, in particular if step
2 (Management Systems) and step 3 (Above & Beyond) are included. Depending on how much data
there is to verify, the Verifier Body/ Verifier may change the person-day estimates. For example,
facilities with fewer policies in place with regards to the management system questions will require
less time to review policies.
o Ensure the steps (1 or 1+2 or 1+2+3) the facility has included in the self/joint-assessment match the
verification scope negotiated between the Verifier Body and the facility.
o Ensure the self/joint-assessment contains at minimum 3 months of operation/ 3 months of self-
assessed data.

If an off-site documents review is requested and deemed feasible/ appropriate by the Verifier Body/
Verifier, the onsite person-days can be reduced by maximum one person-day.

The number of calendar days for onsite verification must not exceed 4 consecutive working days unless
the facility provides express documented permission to exceed the 4 calendar day requirement. If the number
of calendar days exceeds 4 consecutive working days, the Verifier Body must send more than one Verifier.

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A person-day means one Verifier present for one 8 hour working day onsite for verification. Trainees,
assistants or other individuals who are not SLCP approved Verifiers cannot count toward the person-day
requirement. A half person-day means one SLCP approved Verifier present for 4 hours during a calendar day
onsite for verification.

The below table shows information that informs person-day, interview and documentation review
requirements.

Step 1 person-day listing is a minimum requirement and must be followed. Person-day requirements for
step 1 may only be decreased if off-site documents review is applicable. If the facility chooses more than step
1 (i.e. 1+2 or 1+2+3), person-day requirements must be at least half a person-day more than the indicated step
1 minimum. For example, if the facility has 1-100 employees, step 1 minimum is 2 person-days, step 1+2
minimum is 2.5 person-days, step 1+2+3 minimum is also 2.5 person-days.

Step 1+2 and 1+2+3 person-day listings are suggested timeframes, but the minimum addition to the step 1
timeframe is half a person-day. As the scope of verification can drastically differ from one facility to another in
the sections of Management Systems and Above and Beyond, SLCP cannot require Verifiers to adhere to the
suggested person-day information listed in these two columns. Rather, the information is a suggested duration
of verification and the Verifier can determine the necessary additional person-day requirements depending on
self/joint-assessment data. It is recommended that Verifier Bodies add additional onsite time if any of the
following conditionals apply: facilities have migrant workers and/ or multiple languages spoken; facilities have
specialized operations with additional health and safety hazards, such as vehicle fleets, water reservoirs or
large quantities of hazardous materials; facilities have large compounds or more than one location associated
with the business license.

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Any step in addition


to step 1 requires
minimum 0.5 person-
Minimum day more time than
requirement the “Minimum
requirement”. Below
are just suggested
total person days.

Person- Person-
Number Number of
Individual Personnel Person-Days Days Days
of Group Wage & Hour Records
Interviews* Files (Step 1) (Step (Step
Workers Interviews*
1+2) 1+2+3)

16-18 x set of 3 = 48-


1 - 100 10 1 16-18^ 2 3 4
54^
24-28 x set of 3 = 72-
101-200 12 2 24-28^ 2 3 4
84^
27-31 x set of 3 = 81-
201 - 500 15 2 27-31^ 3 4 5**
93^
501 - 32-36 x set of 3 = 96-
20 2 32-36^ 3 4 5**
1000 108^
44-50 x set of 3 = 132-
1001+ 26 3 44-50^ 4 5** 6**
150^
Workers in this context means the workers who are within scope of the SLCP assessment. These are
"Production Employees" (employees working on/with the facility's product or directly involved in the
operations of the facility). They are non-supervisory. Which means, no one reports to them.

* Time estimate: 15 minutes per individual interview, 30 minutes per group of 6-8. Group interviews are in
addition to individual interviews. E.g. 1-100 workers total 16-18 employees must be interviewed.

^ Range applicable, as group interviews are one group = 6-8 workers.

** VBs must send at least two Verifiers onsite to limit the calendar days onsite (unless facility provides express
permission to exceed the 4 calendar day requirement). Note, not all Verifiers need to be present every single
day of the onsite verification, however details about who was present on which day must be noted in the
Verification Details section of the report.

Exceptions to the person day-requirements or other requirements in the Verification Protocol may be made by
the VOO. Exceptions can be requested by completing an Exception Request form.

10. Verifier conducts off-site documents review, if applicable

An off-site Verification is only conducted if appropriate and sufficient documentation is provided.


o Appropriate documentation means the documents provide evidence or further context related to the
question.
o Sufficient documentation means that the Verifier can fully or partially verify the self/joint-assessment
answer to the question by documentation review only. More information through Verifier
observation or interviews onsite may be necessary to fully verify the answers.

If the documentation is neither appropriate nor sufficient, off-site review can be declined by the Verifier, as
the Verifier cannot execute proper off-site verification. The Verifier must explain in detail why off-site review is
not possible.

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If an off-site documents review is conducted, this must be completed prior to the onsite verification.

11. Verifier reviews self/joint-assessment in detail to prepare for onsite verification,


including facility background check

To prepare for the onsite verification, the Verifier must study the self/joint-assessment completed by the
facility. This will also help with creation of the facility-specific verification plan (see Action No. 12.). The Verifier
will gain an understanding of the facility’s management systems, including management personnel onsite,
scope of documentation and physical premises of the facility, as well as potential risk areas, such as presence
of migrant labor, dormitories and hazardous operations.

Verifier Body and Verifier must also obtain relevant social and labor information related to specific
conditions within the country and region of SLCP verifications, ensuring they have up-to-date knowledge.
Verifiers must be knowledgeable on employment laws such as minimum wage, working hours and social
benefits that pertain to the facility location, and on fundamental International Labour Organization (ILO)
conventions that have not been ratified or are not being adhered to.
Furthermore, a background check of the facility must be conducted and include, at a minimum:
o Web-based research on facility and its local area for any social and labor issues or labor unrest that
may have occurred in the last two years (potential sources of information are trade unions, regulatory
bodies, community members, non-governmental organizations and government websites that
provide information on present or past legal action);
o Employee demographics, especially the presence of migrant workers and young workers as well as
any possible language challenges;
o The type of laws that apply to this particular facility.
The Verifier may also request previous social audit reports or the previous SLCP verified assessment report to
obtain facility-specific information. The facility is not obligated to share this information with Verifiers. Also,
the Verifier should be aware of potential bias that can develop with review of previous reports.

Further resources provided by the ILO are: Industrial Relations Database and Working Conditions Laws
Database.

12. Pre-verification communication to facility (document list, verification planning


information et al.)

After a verification is scheduled, the Verifier/ VB must communicate the following information to the
facility no later than ten working days prior to the date of the verification:
1. The number of person-days and calendar days required to complete the verification
2. Reminder of how the facility must include information on COVID-19 in the self/joint-assessment (use
Annex III)
3. Document list (customized based on country of verification, but a basic document list is provided
under Annex V)
4. The expectation that onsite verification requires access to all areas of the facility and its grounds,
photographs (respecting and avoiding proprietary information) and confidential interviews between
the Verifier and employees and management
5. A statement on the need for senior management and employees’ representatives to be present at the
opening and closing meeting
6. Contact details for Verifiers/ VB in case facility needs a local contact (telephone number and email)
7. An explanation that only under exceptional circumstances (e.g., non-access to documentation or
information due to absence of key management personnel on the days of the verification
assessment), the facility may provide additional information after the onsite verification. Normal

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Protocol requires the facility to have all information ready during onsite verification. Delay of closing
the verification process can last only up to 2 working days, i.e., the facility can only provide additional
information up to 2 working days after the onsite verification. This gives the Verifier 8 working days to
complete the verified assessment report. Additional fees may apply depending on the scope of work
to be completed post verification.
8. This link for more information about SLCP and its process https://slconvergence.org/helpdesk
9. The SLCP Code of Conduct (see Annex V)
10. This link for the SLCP QA Manual, which explains the Dispute Process and how reports may be
invalidated https://slcp.zendesk.com/hc/en-us/articles/360014823394-Quality-Assurance-Manual

SLCP has created a template (see Annex IV) that can be used to communicate the above.

Closer to the scheduled verification, but no less than five working days prior, the Verifier/ Verifier Body
must send a verification plan outlining in more detail the daily activities of the verification, including, at
minimum:
1. The calendar days onsite (or number if verification is semi-announced)
2. The hours of verification (start and finish for each day)
3. The expectations for the opening meeting, including who should be in attendance (Verifier can infer
information about management, workers, workers’ representatives/ union representatives from the
self/joint-assessment)
4. The minimum number of interviews that have to be conducted
5. The minimum number of wage/hour/personnel records that have to be reviewed
6. The document request list either as a repeat, or slightly modified if off-site documents review
occurred or Verifier already has access to documents through the self/joint-assessment.

Should COVID-19 be a concern, the Verifier Body should check in with the facility to ensure there have
been no significant changes to the workforce or operations since the completion of the self/joint-assessment.
See requirements around scheduling in Action No. 2. In addition, closer to the verification, Verifier Bodies
should ensure that the processes the facility self-reported on will be in operation during the verification (e.g. if
certain parts of what the facility does are not operational, the verification should not take place).

Prior to travelling to the verification site, Verifier Bodies should check for any health and safety or travel
restrictions put in place by local governments. Additionally, Verifier Bodies and Verifiers should abide by any
health and safety policies factories implement or any applicable laws/ regulations in place, whichever stricter,
to protect workers and visitors (e.g. wearing a mask, temperature checks). Verifiers are expected to practice
good hygiene and to respect social distancing when conducting verifications.

13. Verifier downloads Data Collection Tool from AH platform for back-up during onsite
verification

If not already done to complete Action No. 11., SLCP recommends downloading the offline excel Tool for
verification in case the Verifier experiences Internet connectivity issues during the onsite verification.

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Onsite Verification Actions

14. Verifier conducts onsite verification (opening meeting, walk through, interviews,
document review, closing meeting)

What to verify?
A facility can decide to collect data on:
o Basic social and labor compliance topics (step 1),
o Basic social and labor compliance topics and facility management systems (steps 1+2), or
o Basic social and labor compliance topics, facility management systems and practices around
workplace well-being and community impact (steps 1+2+3)

The SLCP approved Verifier must verify all data (according to steps chosen in the self/joint-
assessment):
o Recruitment and Hiring (step 1)
o Working Hours (step 1)
o Wages and Benefits (step 1)
o Employee Treatment (step 1)
o Employee Involvement (step 1)
o Health and Safety (step 1)
o Termination (step 1)
o Management Systems (step 2)
o Above and Beyond (step 3)
All data means all questions that are applicable to the facility. Even if the facility did not provide an
answer to the applicable question, the Verifier has to verify what the correct answer is. Some Verifier
selections in the Tool can open up questions that the facility did not see during the self/joint-
assessment and therefore did not answer. The Verifier must provide the correct answer to these
unanswered questions. See Verifier Guidance for examples.

What is the verification scope?

TIMEFRAME: The timeframe of the initial self/joint-assessment is based on the previous 12


months from the date that the Tool is completed. The timeframe of the verification process is also
based on the same previous 12 months from the date that the Tool is completed. This is referred to as
the assessment period. The only exception to this is when filling in the Facility Profile. When the
Verifier arrives onsite the Facility Profile circumstances may be different from what they were during
the self/joint-assessment. For all other questions, the assessment period includes the 12 months prior
to the submission date of the self/joint-assessment. However, for Facility Profile information, the
Verifier must include the most up-to-date/ current as of the onsite verification date information which
may require an update and selection of “Updated during Verification”. These changes are not
considered “Inaccuracies” but rather updates to the provided facility data.

Note, should the difference between the Facility Profile self/joint-assessment and actual
circumstances during verification affect the person-day and/or other requirements, the Verifier must
follow all Verification Protocol requirements applicable to the current facility circumstances.

PHYSICAL SCOPE: Each verification must cover the area as defined by the facility in the Facility
Profile of the self/joint-assessment and all operations included therein. The physical scope reported, is
usually tied to the facility’s business license and operations permitted therein. Should the actual
physical scope greatly differ from the self-assessed/ facility-reported physical scope and the Verifier
decides the scheduled verification timeframe is not enough to complete a verification of the actual
physical scope, the Verifier may extend the verification person-days or reschedule the verification.

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WORKER SCOPE: The term "Employees" is used throughout the Tool. It refers to a facility's "Production
Employees". In other words, the facility's workers. "Production Employee" refers to those employees working
on/with the facility's product or directly involved in the operations of the facility. They are non-supervisory
which means that no one reports to them. As facilities might not only be involved in production of goods, but
also general operations activities, e.g. distribution, the term "production" should not be seen as limited to
production of goods only, but rather general operations of the facility. Examples of "Production Employees"
are cutters, sewers, QC, packers, etc. (all workers who contribute to produce the product), boiler workers,
mechanics (machine repair persons), and workers who load product onto trucks.
Verifiers must include all applicable types of “Production Employees” in the onsite verification:
o New hire, under probation, under age 18, union/ worker representative, pregnant, returning from
maternity leave, foreign migrants, domestic migrants, other vulnerable groups or minorities
o Part-time, fixed term, short-term (a person with a labor contract of limited or unspecified duration
with no guarantee of continuation), temporary (e.g. labor supplied by a third-party employment
agency)

In the event that Verifiers suspect potential issues among employees in the facility, Verifiers should also check
third-party service providers not directly working on the product and therefore not included in the worker
scope for the purposes of SLCP. These workers may shed more light on the situation. Examples of such workers
are those working in food service, security, childcare, and custodial.

How to verify?

The general principle of “triangulation” applies to verification activity as it applies to traditional social
auditing. Verifiers must cross-check information gained from observation and documentation review with
information gathered from the interview process with both management and employees to understand how
workers are affected by various situations.

Any verification activity, including the Verifier obtaining access to employee files and data for review and
retention of such data/ information, must be in compliance with any applicable data privacy laws and
regulations.

What is the verification process?

OPENING MEETING: The onsite verification must start with an opening meeting, including, to the extent
possible, facility management, workers’ representatives and those individuals responsible for managing
recruitment, contracts, wages, and health and safety to discuss verification objectives, scope, and
methodology.

o Verifiers must encourage the facility to be open and transparent during the SLCP process. Data
integrity is key to the success of SLCP. Data collection and verification should reflect actual labor
conditions.
o Authorization to take pictures must be requested. The Verifier will observe facility restrictions and not
photograph sensitive (i.e., proprietary) products, materials or processes. If photo authorization is
completely denied, the Verifier will note the denial in the verified assessment report. Should the
facility refuse the Verifier’s request to take photos and yet agree to take photos themselves on behalf
of the Verifier, this must be noted in the report along with any incidences where the Verifier did not
receive pictures they requested.
o Verifier must inform management that the Verifier selects the employees to interview, and that the
employee interviews are confidential, and that the employer is prohibited from taking retaliatory
action against those who are interviewed.
o If applicable, Verifiers must inform management that they wish to interview the head of the union(s)/
worker organization(s), and request that each union put forward a group of worker level union

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members/ representatives.
o If the facility management does not agree to the participation of workers and/or their representatives
in interviews, the Verifier must cancel the verification as information cannot be verified.

Opening meeting agenda recommendations:


o Introduction of the verification team and facility management personnel.
o Reviewing the scope and activities of verification.
o Reviewing a facility floor plan to ensure that all appropriate areas are part of the walk-through
activity. Facility should advise whether Verifiers need PPE or a safety orientation to mitigate any
health and safety risks.
o Clarifying that the verification goal is to check that the assessment was completed correctly, to
validate the accuracy of the data provided and to highlight any inaccurate data or circumstances of
not following legal requirements.
o Data, including potentially confidential data, will be gathered during the verification. Data that can be
linked back to a specific individual/ employee will be kept confidential and none will be shared
outside the verification team with one exception: data can be made available to the SLCP VOO for
quality review or investigation into the work of the Verifiers.
o Description of the report methodology and associated timelines for delivery of the verified
assessment data, review of the verified assessment report, raising of concerns or questions to the VB/
Verifier, and raising of a formal Dispute.

Throughout the verification, the Verifier informs facility management about any inaccuracies, notable
verification data entries and any legal flags. This will help the Verifier in conducting the closing meeting at the
end of the verification, as any gaps or updates to the original facility response will not come as a surprise. In
addition, the facility will likely have less questions and concerns about the Verifier Tool entries, as they will
have already had the opportunity to discuss the items with the Verifier during the verification.

WALKTHROUGH/ ONSITE OBSERVATION: The purpose of the walkthrough is to visually verify the
implementation of policies and procedures and observe workplace health and safety practices. The Verifier
must take time to first look at the 'big picture' before homing in on the detail.

Recommended items to look out for to understand the ‘big picture’:


o People being ushered out of the workplace (e.g. children, or those without contracts) 

o People being moved within the workplace (e.g. young people doing hazardous work or pregnant
women working with chemicals being moved) 

o Things being hastily hidden (chemicals in the general work area) or doors being quickly locked or
unlocked 

o PPE being hastily put on
o General demeanor of workers (are they willing to look up or do they avoid eye contact, are they
allowed to talk to each other, go to the toilet when they wish) 


Refer to Annex VII for tips concerning the walkthrough.

WORKER INTERVIEW sample size is based on Action No. 9. Verifier must meet or exceed the minimum
number of interviews. Verifier decides, based on real-time information at the facility, how to compose or
expand the sample to achieve the best quality possible. The Verifier and not the facility selects the employees
to interview. The Verifier may increase the number of interviewees as long as they are able to provide clear
justification in the Verification Details section of the Tool as to why they did so.

The Verifier must interview a representative sample of employees. This means, the Verifier must
consider both the types of contracts and types of people in the workforce.

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The Verifier must interview the trade union and/or worker representative, where they exist, to explore
their view of working conditions, management attitude as well as any specific issues. If the union is
independent of the employer, this interview can be an important source of leads on other issues in the facility.
If there are union/ worker representatives serving in committees, they must also be included in the interviews.

SLCP recommends that the Verifier speak with a worker representative – elected or not (this person could be a
trade union representative or elected through an internal system or appointed by the facility) – or equivalent
at the start of the Verification Process and also at the end of the process prior to the closing meeting. Where a
Verifier suspects the union chairperson is influenced by management, they should also interview the other
members of the trade union committee to determine the extent of management interference in the union,
including through tactics such as threats, transfers, or bribes. Verifiers should be very clear that the group
meeting should not involve management/ office staff even if they are union members/ representatives.

Worker interviews are strictly confidential and subsequent reports will not identify the names of
interviewees nor their individual responses. Verifiers must ensure that problems raised by employees are
discussed with management in a non-attributed way. Verifiers must never provide specific names,
identification numbers or other obvious indicators (e.g., if there is only one worker in a specific section and
that section is cited in the report) of facility workers to facility management or within the assessment report.
Verifiers may keep a confidential record of those with whom they have had interviews according to Verifier
Body policy.

Interviews must take place away from management and supervisors in a room or space where
interviewees feel comfortable sharing sensitive information.

Interviews must take place in a language understood by workers. This may involve the use of translators.
SLCP is committed to the principle of being able to communicate with any person at the facility. This can be
challenging at sites with multiple languages. Information about languages is in the Facility Profile, but for
scheduling purposes, the Verifier Body will have to inquire about the languages prior to receiving the
self/joint-assessment. The Tool asks for primary, secondary and third most prevalent language spoken by
production employees, as well as the primary language spoken by facility management. The verification team
must be able to support at least the top two languages spoken by employees and the primary language spoken
by management. Verifiers who are fluent in a language but cannot read/write are considered as being able to
support a language. However, the Verifier Body must take care in selecting the Verifier(s) to ensure they can
read the facility’s policies, procedures and other documentation relevant to completing the verification.

The facility has the right to insist on following a higher standard and requiring more language capability.

If the Verifier(s) cannot support the language requirements, the Verifier Body may use professional translation
services. Translators must be present on site. It is required to use translators who are trained to understand
social compliance topics to allow for a thorough, accurate and trusted communication.

Translators must be independent of the facility and any labor agents present at the facility. Finding and
contracting a translator is the responsibility of the Verifier Body. In cases where interpreter cost or lack of
qualified interpreters is an issue, the Verifier may appeal to the VOO for permission to provide less language
capability for the verification.

If a translator is present during the onsite verification, the Verifier must provide information on the
translator in the Verification Details section of the verified assessment report.

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Refer to Annex VII for tips concerning worker interviews.

MANAGEMENT INTERVIEW: To support understanding of management systems and documents, Verifiers


must engage in management interviews with applicable facility personnel, including, at minimum, personnel
working in Human Resources, Industrial Relations, and Health & Safety. Verifiers must conduct management
interviews to verify all Tool steps (1+2+3). Especially questions related to step 2 Management Systems and
step 3 Above and Beyond will require extensive engagement with management personnel, specifically those
who engage in the aspects of Plan, Do Check, Act "PDCA" around management systems and those engaged in
the management of employee well-being and community projects.

Refer to Annex VII for tips concerning management interviews.

DOCUMENTATION REVIEW: Verifiers must review documents to understand the infrastructure of the
facility’s management system and to verify specific claims about how the workforce is managed. The data
collected during interviews must be checked against documentation to ensure that all reports are congruent
with each other. The individuals interviewed will form part, but not necessarily all, of the sample of persons
whose files and payroll are verified. Sample size is based on Action No. 9. The Verifier may decide onsite to
concentrate a review of personnel files or payroll on a set of employees or on those persons with the highest/
lowest hours or wages per pay period. That decision is at the discretion of the Verifier. The personnel files will
be reviewed to verify facts about contracts, age and identity proof, training, job performance, disciplinary
action and resignation/ termination.

WAGE AND HOUR RECORDS: The process for reviewing wages and hours involves selecting three pay
periods from the 12-month assessment period to verify the self/joint-assessment data. The specific months
will represent the most recent pay period, one month of high production and one month of low production. If
there are no clear high and low production months, then the selection must be random. The Verifier may
extend the sample within the 12-month assessment period if s/he deems it necessary to substantiate the
verification.

If the facility experienced any closures, e.g. due to COVID-19, the Verifier must include this time period in
the record review to confirm that wages and benefits were paid in line with legal requirements. This means
more than 3 sets of records may need to be reviewed (high, low, recent, closure).

ATTACHING PHOTOS/ DOCUMENTS: At minimum, Verifiers must include photographic evidence and/or
documentation attached to the applicable question of the Tool in the following instances:
o Outside general overview of the building and area surrounding the facility
o Inside general overview – main section(s) of the interior, the “shop floor”
o Attendance recording system
o Work in progress: e.g. assembly, cutting, packing
o Canteen, kitchen and/or dormitory (if present)
o Waste handling and storage areas
o Hazardous substance storage areas
o Personal protective equipment
o Firefighting equipment
o Emergency exits and marked non-exits
o Bulk storage tanks and secondary containment
o Supporting facilities such as wastewater treatment and boiler
o Abatement equipment (items used to reduce intensity of pollution)
o Good practices

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o Issues identified as "Inaccurate" or “Legal Flags”


o Issues where more information would help the reader understand the facility circumstances, no
matter the outcome of the “Corrected Response”
Examples of instances for attachments are noted in the Verifier Guidance.
Photographs must only be taken with the permission of the facility as they may contain confidential
information, and all attachments should be free of personal/ private data. For example, if Verifiers
want to demonstrate a wage issue, they may use a sample to highlight the issue and must black out
any personal information.
Attachment of photos/ documentation is only possible through the online Accredited Host platform.
Verifiers can attach a file at question level and thus select the most applicable question that relates to
the attachment. Verifiers can also attach a file containing information of a more general nature or
information that does not fit a specific question to the last question in the Verification Details section
of the Tool: Are there any photos you would like to add to the verification that did not directly
correspond to a question?

If multiple photos are shared in one file/ attachment, SLCP recommends using a word processing
software (e.g. Microsoft Word or equivalent) or a presentation software (e.g. Microsoft PowerPoint or
equivalent) to capture the multiple photos and write a detailed description for each photo.

SITUATIONS OF DENIED ACCESS: Should the Verifier experience any issues with viewing/ accessing
information required to verify the self-assessed data:
o Remind the facility of the CAF Terms of Use, which they agreed to when they set up their
profile on the Gateway, specifically the clause: Data collection and verification through the
CAF should reflect actual labor conditions. Users of the CAF and the Verified Assessments
(facilities, verifiers, brands and other organizations) commit to reporting accurate information
to the best of their knowledge and to supporting the integrity of the data shared among users.
o Remind the facility of the purpose of SLCP (data collection and data sharing) and that it is in
the facility’s interest to have the most complete set of verified data for sharing.
o Remind them that if the Verifier cannot verify the data, the Verification Selection will be
“Inaccurate”, affecting the Accuracy Index of the report.
If the facility still denies access, the Verifier must make note of denial in the Verification Details section
of the report and in the Verification Data of the applicable question. If the Verifier cannot verify
something, they must mark the answer as “Inaccurate” and state why it is inaccurate in Verification
Data.
If denial of access is due to confidentiality, the Verifier must check the applicable confidentiality clause
in place, include details about confidentiality in the Verification Data and also in the Verification Details
section of the report.
In either circumstance, the Verifier must also include information on the facility’s general behavior
toward the assessment.

15. Verifier focuses on Verification Summary; addresses facility questions/ concerns during
closing meeting

PRE-CLOSING MEETING: If the Verifier has not already completed all “Inaccurate”, “Legal Flag” and
“Updated during Verification” items to create the Verification Summary in the Tool, the Verifier must now take
the time to complete as much as possible, and ideally all fields that will allow the Verifier to have a productive
closing meeting with the help of the Verification Summary. Note, the “Updated during Verification” items do
not appear in the Verification Summary, only in the Facility Profile filled in by the Verifier. But it is important to
review these with the facility to ensure they are aware of the updated information.
Depending on the scope/ breadth of inaccuracies and legal flags, the Verifier may not have enough time to
complete all fields that are shown in the Verification Summary onsite and may have to skip some entries in the
Verification Summary or just provide highlights to the facility. More information about how to complete the

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Verification Summary in the Tool is in the Verifier Guidance.

The Verifier must also have a final conversation with the union representative and/or worker
representative interviewed at the beginning of the interview process, as applicable. This will help the Verifier
gather any further information related to differences between the original self/joint-assessment data and the
verified data.

CLOSING MEETING: The onsite verification must end with a closing meeting, ideally including the same
individuals who were present during the opening meeting, but at minimum facility management and union/
worker representatives, if applicable. During the meeting, the Verifier reviews the scope of the work
performed and highlights any discrepancies (gaps) between the self/joint-assessment and the verification
outcomes so that a facility can understand how to better complete the Data Collection Tool in the following
cycle.

It is out of scope and not the Verifier’s role to train management, nor to help the facility identify
the root causes of issues found. The Verifier is to explain the factual gaps between the assessment data
and the verified data and review any instances (not already noted in the self/joint-assessment) where
the facility is not following local legal requirements.

If the Verifier Body has an agreement with a user of the facility’s verified assessment report -
other than the facility itself – and this agreement involves reporting of verified assessment data, the
facility must be made aware of such reporting. For example, SLCP does not prohibit Verifier Bodies from
sending zero tolerance/ critical issue reports immediately after the onsite verification; but since these
reports (which are outside of the SLCP system) include facility data obtained through the SLCP
assessment process and the facility owns their data, the Verifier or Verifier Body must inform the
facility of this special data sharing process. The information on data sharing by the Verifier Body can be
shared with the facility during the scheduling process, but must be shared with the facility during the
closing meeting.

Closing meeting agenda recommendations:


o Thanking facility management for their time
o Explanation of SLCP to the facility once more
o Explanation of where there were discrepancies between the self-assessed information and the
Verifier data. This will be based on the Verification Summary (if Verifier had time to fully complete).
Otherwise it will focus on “Inaccurate” and “Legal Flag” items.
o Cooperation of staff and availability of information
o Confidentiality of the results
o Informing facility that the verified assessment data will be delivered within ten working days of the
verification, calculated from the final day on site
o Informing facility that there will be no Corrective Action Plans or improvement plans provided by the
Verifier, as this is out of the scope of SLCP
o Mentioning two-day grace period (if applicable and exceptional circumstance is met as per Action No.
12.); facility can still provide more information to the Verifier to substantiate assessment information
or clear up any issues with the Verifier that resulted from the onsite verification
o Dispute process
o If applicable, Verifier Body/ Verifier sharing of facility verified assessment data with users other than
the facility

Should the facility have any queries and/or concerns about the verified data at a question level, the
Verifier and facility must discuss and attempt to address the issues during the closing meeting.

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If not able to address the issues during the closing meeting, the Verifier Body/ Verifier and facility must
attempt to solve the issues within the two working days after closing of onsite verification. If the issues still
cannot be resolved, the facility still has time to connect with the Verifier Body/ Verifier during the facility
review process of the report (14 calendar days from receipt of verified assessment report). If concerns relate
to Verifier following Verification Protocol and/or Verifier conduct, then the facility can raise a Dispute. See
further information under Action No. 24.

16.-20. Resolving facility concerns, filling in Tool, completing report online to run AH
checks, VB quality check, VRQ check with VRE edits, changing assessment status to VRC

Within two days of end of onsite verification:


o Verifier/ Verifier Body may have to address facility concerns about the verified data. If they relate to
question level issues like disagreement about a legal flag, then the Verifier/ Verifier Body must handle
this offline between them and the facility. If they relate to Verification Protocol or Verifier conduct,
then the Verifier/ Verifier Body must refer the facility to the Dispute process.
o Verifier may have to review further documentation or conduct remote interviews due to the
exceptional circumstances during onsite verification. See Action No. 12.

REPORT WRITING: The Verifier/ Verifier Body has 10 working days after end of onsite verification to
complete the verified assessment report. Filling in the Tool to complete the report can occur online or offline,
but the process must end online as the Accredited Host runs checks to ensure proper completion of the Tool.
These checks focus on content being entered for mandatory fields or in a specific type of format. These checks
do not include the level of quality of data, which is the responsibility of the Verifier and the Verifier Body when
it runs mandatory quality checks.
More information about how to complete the Tool and tips on quality review are in the Verifier Guidance.

The Verifier Body is responsible for conducting an internal quality check on the report before it is
finalized. Once the Verifier Body has completed the quality check and the Accredited Host checks have been
executed and, if applicable, resolved by the Verifier, the Verifier must complete the verification, this will result
in the assessment status change from “Verification in Progress” to “Verification Completed”.

Before the status changes to “Verification Completed”, an automated SLCP data quality check is
conducted behind the scenes in a hidden status called “Verification Quality Check” (VRQ). This search for data
quality failures takes a few seconds. If the data quality check fails, the assessment status automatically
changes to “Verification being Edited” (VRE) and an email is sent from info@slconvergence.org to all assigned
Verifiers of the verified assessment report. The Verifier must:
o review the email which outlines all the failures,
o make changes to the verified assessment report, as necessary,
o finalize the report – again – by changing the status from “Verification being Edited” to “Verification
Completed”, and ideally
o do this all in less than 4 calendar days.

On calendar day 5 after the assessment status changes from “Verification in Progress” (via VRQ) to
“Verification being Edited”, the assessment status automatically changes from “Verification being Edited” to
“Verification Completed”, whether the Verifier made edits or not. This guarantees that the assessment process
continues and the facility can start reviewing the verified assessment report.

If the automated SLCP data quality check does not result in failures, the completion of the verification goes
through and the assessment is in status “Verification Completed”.2

2The first Accredited Host to support the SLCP automated data quality checks will be FFC, followed by Higg Co.
Contact the Accredited Host to obtain the most up-to-date status on the VRQ roll out.

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SLCP regularly reviews and updates the automated data quality checks. Go to our Helpdesk to see which data
quality checks SLCP is currently running.

DOCUMENT RETENTION: Verifier Bodies must follow local legal requirements relating to the
minimum retention of notes, documents, photographs and/or client files. SLCP requests at least 12
months of retention to facilitate any Dispute or quality assurance procedures.

Note, as the Verifier and Verifier Body do not have access to the finalized verified assessment report
(status VRF), Verifiers should save a copy of the report (likely the offline Excel version) for their records
prior to changing the status to “Verification Completed”. Verifier Bodies can always ask the facility to
share the finalized verified assessment report with them, but SLCP recommends downloading a copy at
this point in the SLCP assessment process.

21.-24. Facility reviews verified assessment, connects offline with Verifier/ VB for concerns
and requests edits as necessary, accepts verification or raises Dispute

Once the Verifier completes the verification report (for the first or second time after VRQ failures), the facility
is notified via the Accredited Host platform, can access the verified assessment report online or offline in excel
through download from the Accredited Host for review, and has 14 calendar days to review the report and
request edits from the Verifier/ Verifier Body, as necessary.

Within these 14 calendar days, the facility can:


o Accept the verified assessment report on the Accredited Host platform, which changes the
assessment status from “Verification Completed” to “Verification Finalized”.
o Dispute the verified assessment report due to Verifier not following Verification Protocol or
complaints about Verifier conduct. This changes the assessment status from “Verification Completed”
to “Verification Disputed”. When raising the Dispute on the Accredited Host platform, the facility will
have to provide more detailed information about the Dispute, so the Verification Oversight
Organization is well informed.
o Reach out to the Verifier/ Verifier Body for clarifications, concerns, questions about the verified
assessment report, especially with regards to question level issues that do not relate to Verifier
following Protocol or Verifier conduct.
o Change the status from “Verification Completed” to “Verification being Edited” if the facility and
Verifier/ Verifier Body have jointly agreed to report edits.

After 14 calendar days, if the facility has not accepted the verification or raised a Dispute, the Accredited Host
automatically changes the status of the assessment to “Verification Finalized”.

Should the facility and Verifier/ Verifier Body agree to changes to the verified assessment report at this
stage of review, the facility must change the status from “Verification Completed” to “Verification being
Edited” and give the Verifier access to the report again through the Accredited Host platform so the Verifier
can make the agreed changes. Any changes the Verifier makes to the report after completion/ during this
facility review phase must be agreed upon by the facility. After edits are finalized, the Verifier must change the
status to “Verification Completed” – again – so the facility can access the report and review the changes. The
Verifier must work as quickly as possible to finalize the edits and change the status back to “Verification
Completed” so the facility has enough time to review the report a final time before finalization.

This back and forth between facility review in status “Verification Completed” and Verifier changing the report
in status “Verification being Edited” can occur as often as necessary within the 14 calendar days. The
Accredited Host has a “countdown clock” feature which will help the facility and Verifier see how much time is
left until the assessment is automatically finalized and the status is changed to “Verification Finalized”. Also,
emails will be sent to the Verifier and facility to remind each party of the impending deadline.

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Should the Verifier need to make edits to the report, per facility request, SLCP recommends that the Verifier
again saves a copy of the report for their records prior to changing the status to “Verification Completed”.

25. If accepted: facility shares verified assessment via the Gateway and/or the Accredited
Host

There are three ways to share the verified assessment report, once the facility has accepted it:
1) When registering on the Accredited Host site, the facility will probably have already indicated which
end users they would like to share the final verified assessment report with. Note, these approved
end users (e.g. brands, retailers, customers, agents) will have access to assessment status information
via the Accredited Host site. They will not have access to the self/joint-assessment data or verification
data until the facility accepts the verified assessment report.
2) Should an end user not be associated with an Accredited Host, the facility may also share the verified
assessment report with another party through the Gateway. The facility will require the email address
for that end user.
3) If the facility wants to have the verified assessment report available on multiple Accredited Host
platforms, they can initiate this linking/ sharing on the Gateway.

26.–28. If Dispute: VOO deems substantiated or not substantiated

Once the facility raises a Dispute, the Verification Oversight Organization is notified about the Dispute and
receives the details of the Dispute via the information the facility filled out on the Accredited Host site.

For more information about the Dispute process, access the SLCP Quality Assurance Manual.

An assessment that is in “Verification Invalidated” status cannot be shared with end users and the full report is
not available on the Accredited Host site or Gateway. Sharing of the report is not possible. The only
information available is that the facility has an invalidated report and the reason the report was invalidated.

29. VOO Quality Assurance Procedures for accepted verified assessments

The VOO can choose to conduct any type of quality assurance procedures for any verified assessment. More
information about these procedures is in the SLCP Quality Assurance Manual.

Reports for Desktop Review are selected within 10 working days of an assessment changing to “Verification
Finalized” and the Desktop Review is completed within another 10 working days. Sites for Counter
Verifications are usually selected within 2-4 weeks of the verification date and the process of scheduling,
conducting the Counter Verification and completing the QA report could take up to 6 weeks.

QA activity by the VOO can result in invalidation of the verified assessment report, which means that the
report can no longer be shared with end users and the full report is no longer available on the Accredited Host
site or Gateway. The sharing will also be revoked. The only information available is that the facility has an
invalidated report and the reason the report was invalidated.

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Annex

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Annex I Verifier Expectations

SLCP considers all Verifiers to be representatives of their Verifier Bodies when engaging with manufacturers.
Note that any sign of bias, favoritism and/or wrongdoing, even if perceived, could compromise the validity of
the verification process. SLCP expects that all Verifiers will behave in a manner that (1) demonstrates the
highest levels of ethics, professionalism, and respect; (2) maintains integrity by ensuring neutrality and
avoiding any conflicts of interest; and (3) safeguards the well-being of the Verifier team. This section outlines
SLCP’s requirements in terms of ethics, Verifier behavior and competencies, and personal and facility safety.

Ethics
Accepting gifts of any value from facility managers, workers or others related to the verification is
inappropriate and is not permitted. Exceptions to the rule may include accepting offers for water, soft drinks,
tea, coffee and snack food similar to the kind and value consumed regularly by those who are offering it.

SLCP adheres to a strict policy against bribery. In the event that a Verifier is offered money, gifts or other
unsolicited items, the following procedure must be followed:
1. Refuse the offer immediately, and explain that such a practice is strictly prohibited;
2. Take a photo of the item, if possible;
3. Contact the VB and/or VOO to report the incident and seek further guidance (based on the advice
given, either abort the assessment or proceed with the verification. If the Verifier feels threatened or
intimidated in any way, the verification should be aborted).

Prohibition on Sales
At no time should Verifiers engage in selling consulting or other services by their organization.

Acceptance of Lunch and Travel


Verifiers must never allow management to take them out for lunch during a verification nor accept payment
for lunch. If the facility orders lunch, Verifiers must pay them back for the lunch and explain that this is SLCP
policy. Rides may be accepted to and from the facility only when there is no other option. When the Verifier(s)
arrives at the facility, their behavior should reflect that of an independent third party. If workers see a Verifier
coming out of a facility owned vehicle, workers may believe that they are working for the management and
are therefore not independent. If there is a security concern with transportation or during any other part of
the verification, the Verifier must contact his or her VB.

Confidentiality
All information shared between the Verifier and a facility worker or manager and all information the Verifier
gathers in the course of his or her verification is the property of the facility and must be kept strictly
confidential. Such confidential information can be shared only within verified assessment reports and to
parties designated by the facility. Verifiers may not e-mail or give hard copies of the verified assessment
template or report to any party other than the applicable Accredited Host and/or SLCP administrator in
instances where technical failure has occurred.

Impartiality
The Verifier must maintain impartiality at all times. They must not take sides or appear to be taking sides in the
event of any dispute at a facility. All complaints by facility workers, managers and/or third parties are to
remain allegations until they have been properly investigated and objective evidence is found to support the
claim(s). The Verifier must also disclose if they have had any personal or professional affiliation or relationship
with the employment site that is subject to the verification.

Respectfulness and Professionalism


The role of a Verifier is to effectively and impartially gather information which requires listening to the
perspectives, opinions, and comments of all stakeholders regardless of their position within the facility.

Verifiers must be respectful of facility owners, managers, production workers, and other persons who may be
involved in the Verification. Verifiers must be sensitive and respectful of gender, racial, cultural, and socio-

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economic issues. Acting in a demeaning, confrontational, or harassing manner to any persons before, during,
or after a verification will not be tolerated. Verifiers must possess effective listening skills and awareness of
non-verbal communication.

Verifiers must always be courteous, conscientious and be generally business-like in demeanor in the
workplace. Verifiers must dress and act in a professional manner at all times. Verbal or physical altercations of
any type will not be tolerated between Verifiers and facility workers or management/ owners

Personal Safety
There may be cases where travelling alone is not considered safe due to local conditions, gender, or other
reasons. In these cases, additional personnel or escorts must be included as part of the verification team.
Verifiers that feel unsafe visiting a facility alone must notify their supervisor.

Facility Safety
SLCP believes that Verifiers, whether internal or external, are ambassadors for the entire program. The
expectation is that they demonstrate the highest level of professionalism and execute the work in the
highest quality manner, taking every measure required to be safe and ensure the safety of others. It is the
responsibility of the Verifier to act in a safe manner when onsite at a facility. Verifiers must exercise best
judgment and must not proceed if they feel unsafe.

Verifier Bodies want to ensure that Verifiers:


• Perform all duties in accordance with applicable federal, state, provincial, regional, and other applicable
health and safety regulations.
• Follow all site-specific (e.g. facility) safety rules and requirements.
• Act in a safe manner at all times including wearing appropriate clothing and personal protective
equipment (PPE) where deemed necessary (hats, suits, gloves, eye protection, etc.). The following PPE is
recommended in the following cases. When in doubt, err on the side of caution:
• Foot protection/ safety footwear (whenever there is risk of crushing or heavy objects dropping onto
feet or whenever there is a risk of slipping (e.g. wet areas));
• Eye protection in areas with potential for flying objects or splashing of chemicals;
• Head protection in areas with the risk of fall hazards;
• Noise PPE to reduce exposure in certain circumstances.
• If available, all Verifiers should locate and review the facility or building safety rules/ plans to understand
site specific safety risks that may apply within the specific location/ building being visited. Be aware of
potential high noise areas.
• Watch for machinery or other electrical devices that are not properly plugged in and be aware of frayed or
exposed electrical wires. Never touch any electrical fixtures or wires that appear unsafe.
• Prior to conducting any inspections that involve heights, or going on rooftops, ensure safety measures are
in place, such as safety harnesses.
• Refrain from touching, smelling, or making contact with chemicals. Be aware of chemicals around the
facility and use judgment when interacting with these chemicals.
• Always be aware of machinery and/or tools with rotating parts.

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Annex II: Filtering of Verifier Body and Verifier

In order to enforce Verification Protocol rules regarding Verifier Body and Verifier selection, we are using
available technology to filter in advance.
Facilities choose the VB on the AH. Below is the flow chart for filtering of VB.

The rule as shown in the flow chart is that the initial Verifier selected must be eligible to verify in the
verification country and speak (be listed in Verifier profile) at least one language listed by the facility as a
language of the employees (>0 Language – Languages A or B or …n). If there is such a Verifier, the VB will show
as a possible selection for the facility on the AH.

For example, the factory has listed the following as employee languages:
English (A)
French (B)
Finnish (C)

The filter will only show Verifiers that have either A, B or C listed in their profile.

Once a VB is selected by the facility on the AH, the VB selects the Verifier on the Gateway. Below is the flow
chart for filtering of Verifiers that are associated to the VB. Rather than filter by Prior Verification and Gender,

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this data will be visible/transparent to the VB so that they may select based on Protocol Rules.

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Annex III: COVID-19 – Enhancement to Verified Assessment Report Information

Verifier Requirements for Completion of Verification Data Fields related to COVID-19

Introduction

As we all know COVID-19 has disrupted supply chains and significantly impacted workplace conditions in facilities. To reflect this impact, we are hereby providing Verifiers
with requirements on how information about the impact of COVID-19 on the facility must be included in the SLCP verified assessment report. This means that if the facility
was affected by COVID-19 as it relates to the SLCP assessment scope, then the Verifier must provide more information. This document also indicates how facilities should
respond to certain questions if they are impacted by COVID-19.

Contact us via the SLCP Helpdesk if you have any more questions.

Reading Guide

• Area Impacted by COVID-19: facility condition or process that is possibly impacted by COVID-19.
• Data Collection Tool Question: Tool question where information on possible impact can be captured.
• Guidance for Facilities: This indicates how facilities should respond to certain questions if they are impacted by COVID-19.
• Verification Data Completion/ Information to Include, depending on facility circumstances: type of information that must be included by the Verifier regardless of
Verification Selection “Accurate” or “Inaccurate”.

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Area Impacted by Data Collection Tool Question Guidance for Facilities Verification Data Completion/ Information to Include
COVID-19
Facility Closures and Changes in Workforce
Facility closures FP-BI-9 N/A If the facility has had any closures or reduction in
Normal Hours of Operation per normal working hours or changes to normal
day: operations due to COVID-19 include this information
under Verification Data

Reduction of FP-ED-2 If the facility has laid off, retrenched or FP-ED-2


workforce Total Number of Production furloughed a significant percentage of workers as If differences between self-assessment completion
Employees a result of COVID-19, the answer to ep-11 should and verification are due to COVID-19, include this in
be YES. Verification Data.
ep-11
In the last 12 months within this ep-11
assessment period, has the facility If the facility has experienced layoffs, retrenchments
experienced any mass layoffs as a or furloughs due to COVID-19 under Verification Data
result of economic, technological, note:
structural or similar changes? • Number of layoffs including gender
breakdown (# of men vs # of women)
• Number of temporary reductions (including
workers who are furloughed or who have had
their hours reduced). Include gender
breakdown of workers who have had their
hours reduced (# of men vs # of women)
• For any temporary reductions note the
duration of the reduction

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Area Impacted by Data Collection Tool Question Guidance for Facilities Verification Data Completion/ Information to Include
COVID-19
Conditions of work disc-7 If conditions of work, such as, shift selection, access to
are non- In the last 12 months within this overtime, demotion, etc. are impacted by COVID-19
discriminatory assessment period, have other check if this ever was dependent on certain factors
conditions of work for employees such as gender.
been dependent upon the
following:
Terminations/ disc-14 N/A If workers were terminated due to COVID-19, under
retrenchments/ When laying off employees does Verification Data, describe the criteria that were used
furloughs were made management follow objective, to decide which workers to terminate. If gender was a
in a non- non-discriminatory criteria when criterion, be sure to note that.
discriminatory selecting individual employees
manner who will be retrenched/laid off?
Wages
Payment of wages WB-14 Facilities must consider any required payments to Under Verification Data include information on
In the last 12 months within this workers during closures due to COVID-19. changes to wage payment requirements (including
assessment period, were wage Facilities must consider any required hazard pay due dates) as a result of COVID-19.
payments made on time and in pay/incentive pay to workers.
line with legal or collective
bargaining agreement If the facility delayed any required payments due
requirements? to COVID-19, the answer is NO.

Payment of wb-27 Facilities must consider any legal requirements If workers were terminated due to COVID-19, under
termination benefits Are termination benefits enacted specifically to protect workers Verification Data, describe what termination benefits
(including severance payments) in terminated as a result of COVID-19. were paid.
line with legal requirements?

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Area Impacted by Data Collection Tool Question Guidance for Facilities Verification Data Completion/ Information to Include
COVID-19
Paid leave WB-23 If the facility was closed due to COVID-19 and the If “other types of required leave” is selected due to
In the last 12 months within this facility was required to pay employees during this paid COVID-19 leave, under Verification Data
assessment period, please confirm closure, “other types of required leave” should describe the required terms of payment.
if employees received time off - be selected.
and were paid - for all forms of If “sick leave” is selected under Verification Data
leave and if payments were in line If workers who are diagnosed with COVID-19 are describe any special provisions for paid sick leave due
with legal or collective bargaining entitled to paid sick leave, “sick leave” should be to COVID-19 .
agreement requirements: selected.
Working Hours
Overtime WH-7; WH-7--1; WH-7--2 N/A If the answer to any of these questions is yes, and if
overtime was worked due to COVID-19 impacts,
In the last 12 months within this describe this under Verification Data. Include details
assessment period, did any such as whether the overtime was due to a reduced
employees work more than workforce or closures that impacted production
60/72/90 hours in total (regular + planning.
overtime) within any given week?
Timekeeping WH-1-4x If the facility has changed their method of If the facility has changed their methods of
How are hours of work recorded timekeeping as a result of COVID-19 (e.g., timekeeping (e.g. from biometric to manually) to
for all employees? switching from biometric to manual prevent the spread of COVID-19, under Verification
timekeeping), both methods of timekeeping Data indicate that more than one timekeeping system
should be selected. was used due to COVID-19.

If the facility uses biometric timekeeping, under


Verification Data indicate how the biometric
timekeeping system is sanitized to prevent spread of
COVID-19.

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Area Impacted by Data Collection Tool Question Guidance for Facilities Verification Data Completion/ Information to Include
COVID-19
Grace period for WH-3--1-4x To allow for social distancing, facilities may If the facility has a grace period for clocking in and out
clocking in and out Start and finish times in the implement a grace period for workers clocking in under Verification Data indicate if this was
payroll system match exact time and out. If workers are required to clock in/out implemented to allow for social distancing and how
in/out in time records before/after the start of their shift and they are long the grace period is.
NOT compensated for this grace period, the
answer to this question should be NO.
Testing and Treating Confirmed Cases
COVID-19 testing disc-10 If the facility requires COVID-19 testing for If the facility is requiring COVID-19 testing, under
Does the facility require infection workers, the answer to this question should be Verification Data, describe the details of the process
or illness tests (i.e. HIV/AIDS or YES (when, how often, how, who, etc.).
Hepatitis B) at any time during
employment?
Policies and HS-18 N/A Under Verification Data, note if the facility’s
procedures for Does the facility have a written emergency response plan includes dealing with
dealing with Emergency Response Plan? widespread contagious illnesses. Note if the facility
contagious illnesses has implemented any new procedures for dealing
specifically with COVID-19. If the facility has
implemented COVID-19 specific procedures, describe
what they address. Note any local regulations to
prevent the spread of COVID-19 that apply to the
facility and how the facility is complying with these
regulations.

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Area Impacted by Data Collection Tool Question Guidance for Facilities Verification Data Completion/ Information to Include
COVID-19
Right to refuse work HS-29 If there are confirmed cases of COVID-19 in the HS 29 If there are confirmed cases of COVID-19 at the
Are employees able to remove facility and workers are not permitted to refuse facility, under Verification Data indicate if the facility
themselves from imminent danger work due to safety concerns, the answer HS-29 allows workers to refuse to work (with or without
in the workplace without seeking should be NO. permission).
permission?
HS 29-1 Workers who have refused to work due to
HS-29--1 confirmed cases of COVID-19 must be considered
Have employees who refused to when answering this question.
work in unsafe conditions ever
faced any negative consequences?
Workers diagnosed HS-52 N/A Under Verification Data note the number of workers
with COVID-19 Does the facility track all types of with confirmed cases of COVID-19.
employee illness?
Medical facilities HS-51--1 N/A If the facility has medical facilities, describe what
Does the facility have on-site measures have been taken to protect medical facility
medical facilities/clinic(s)? staff (e.g. face shields, body suits) and to prevent the
spread of COVID-19 in medical facilities (e.g. isolating
workers with suspected cased of COVID-19, increased
disinfection).
Preventative Measures
Cleaning program HS-4 HS-4 If the facility undertakes regular HS-4
Does the facility have a regular cleaning/sanitizing to prevent the spread of Under Verification Data, provide details of how the
facility cleaning program in place? COVID-19, the answer to this question should be cleaning program prevents the spread of COVID-19.
YES.

Hand washing HS-5-3x HS-5-3x


Hand washing facilities are If additional hand washing/sanitizing stations have
provided been installed to prevent the spread of COVID-19,
indicate this under Verification Data.

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Area Impacted by Data Collection Tool Question Guidance for Facilities Verification Data Completion/ Information to Include
COVID-19
PPE HS-31 HS-31 If workers are provided with PPE HS-31
Are employees provided with specifically to prevent the spread of COVID-19, Under Verification Data, indicate if workers are
Personal Protective Equipment the answer to this question should be YES. provided PPE (masks, respirators, face shields)
(PPE)? specifically to prevent the spread of COVID-19. If PPE
is provided specifically to prevent the spread of
COVID-19, indicate if workers are trained on how to
properly use PPE to prevent the spread of COVID-19.
Dormitories HS-55--2-2x Accommodations are HS-55--2-2x
clean and safe If the facility has dormitories, under Verification Data
indicate any measures the facility has implemented to
prevent the spread of COVID-19 in dormitories. Note
specifically if the facility has implemented curfews in
dormitories to prevent the spread of COVID-19.
Canteens HS-56--2-3x HS-56--2-3x
Food preparation, storage, and If the facility has a canteen, under Verification Data
eating areas are kept clean, safe, indicate any measures the facility has implemented to
and hygienic (including prevent the spread of COVID-19 in the canteen.
temperature, ventilation, light,
noise etc.)
General add-11 add-11: add-11
Does the facility have any • Under Verification Data indicate any • If the facility has not provided information,
additional comments to share preventative measures the facility has select “Accurate” but under Verification Data
regarding their health and safety taken to reduce the spread of COVID-19 indicate any preventative measures the
practices? (e.g. re-arranging workstations to be 6 ft facility has taken to reduce the spread of
apart, installing barriers between COVID-19 (e.g. re-arranging workstations to
workstations, etc.). Include measures be 6 ft apart, installing barriers between
taken for all parts of the facility workstations, etc.).
including the production floor, • If the facility has not provided information,
dormitories and canteens. under Verification Data indicate any
measures the facility has taken to reduce

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Area Impacted by Data Collection Tool Question Guidance for Facilities Verification Data Completion/ Information to Include
COVID-19
• Indicate any measures taken to reduce large gatherings of workers such as group
large gatherings of workers such as trainings and emergency evacuation drills.
group trainings and emergency • If the facility has not provided information,
evacuation drills. under Verification Data indicate any
• Indicate any measures taken to prevent measures the facility has taken to prevent
the spread of COVID-19 as workers the spread of COVID-19 as workers enter the
enter the facility, such as temperature facility, such as temperature checks.
checks. • If the facility has not provided information,
• Indicate what communications workers indicate what communications workers
receive about COVID-19 and how receive about COVID-19 and how workers are
workers are trained to prevent the trained to prevent the spread of COVID-19.
spread of COVID-19.

Impact on Verification Process


Impact on the Verification Details section - N/A Note if COVID-19 had any impact on the verification
verification process Verification observations – any process, e.g. if certain areas of the facility were not
other comments operational.

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Annex IV Verification Communication Template (suggested communication)

Dear Facility Representative,

Thank you for choosing [Verifier Body name] to complete the verification of your [self][joint]-assessment.

Role of the Verifier


SLCP is standard agnostic which means there is no judgment or scoring of the data. The Verifier’s role is to
check the correctness and completeness of your information provided in the Data Collection Tool. Our
Verifiers and [Verifier Body name] will adhere to the SLCP Code of Conduct, see attached.

Completing your assessment on the Accredited Host platform


Facilities can complete the SLCP assessment on an Accredited Host platform or offline in excel. If you choose to
complete the assessment offline, you will need to upload it when finished to your chosen Accredited Host
platform. The platform will check your assessment and will tell you if you need to add more data or edit any
entries. You can also upload documents to the Accredited Host platform if you want us to do some off-site
review. You can upload documentation. We ask that you do not upload any sensitive information, such as
personally identifiable information relating to your employees, or any proprietary information.

Timeline
The Verifier must receive your completed assessment with applicable uploaded documentation no later than
10 working days prior to the scheduled [verification date][verification window].
Verification must happen within two months of completion of the self/joint-assessment. The Verifier will check
the date in the Data Collection Tool, Facility Profile section, Row 30 far right column UVW (offline Excel
location) question FP_BI-22: Date of self/ or joint-assessment submission (DD/MM/YYYY). If this date is more
than two months from the date of verification,, you must contact SLCP through the Helpdesk to change the
status of your assessment back to ASI (Assessment Initiated) so you can update the self/joint-assessment.

Verification details
The scheduled [verification date][verification window] is:
• The number of person-days required to complete the verification are:
• The number of calendar-days we will be onsite are:
If the off-site documents review is deemed appropriate and sufficient information is provided by the facility,
the number of days listed above may be decreased by a maximum of one person-day.
• We will be sending [number of Verifiers] Verifier[s] to conduct the onsite verification. The Verifier[s]
[has][have] the following notable characteristics: [Include information about gender and language
capabilities at a minimum]. [Also include information on any applicable trainees, assistants,
translators or other individuals joining the verification].
• To get in touch with the Verifier[s] you can email [address] or phone [number].

Verification process: What to expect

• During the onsite verification we will conduct a facility tour, check documents and interview both
management and workers.
• The Verifier(s) will require access to all areas of the facility and its grounds, photographs (respecting
and avoiding proprietary information)
• The Verifier will conduct confidential interviews with employees and management. The interviewing
of workers is done as part of their employment and as such, workers should not be financially
penalized or retaliated against, abused or harassed in any form for participating in the interview
process. Furthermore, during the opening and closing meeting it is important that senior
management and employees’ representatives (as applicable) are present.
• To prepare for the onsite documentation review, please find the attached Document List for your
information. We appreciate your cooperation. At the end of the verification, we will conduct a closing
meeting to review the verification summary at a high level.

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• For more details about the verification process, please read the Verification Protocol.

After the verification: What to expect


We will complete the verified assessment report within ten working days. You should have all information
ready for the onsite verification. Only under exceptional circumstances (e.g., non-access to documentation or
information due to absence of key management personnel on the days of the verification assessment), may
you provide additional information up to two days after the onsite verification.

After you have reviewed the verified assessment (14-calendar day window after Verifier completes report) and
accepted it, you can share the verified assessment report with anybody you choose via the Gateway or your
chosen Accredited Host. As this is not a compliance audit, we will not provide information about corrective
action plans.

Concerns or disputes
Should you have concerns or questions about the verified assessment report during your 14-calendar day
review period, you can directly reach out to us for clarification. If applicable, we can make edits to the verified
assessment report. Edits will only be made with your knowledge and approval. Should you have concerns
about the report quality, as it pertains to the Verifier following Protocol or Verifier conduct, you can also raise
a formal Dispute and involve the Verification Oversight Organization. For more information about Verification
Oversight, please see: https://slcp.zendesk.com/hc/en-us/sections/360003592500-Verification-and-Data-
Quality

COVID-19
If your facility is affected or was affected by COVID-19, we will regularly contact you for updates on workforce
and facility operations to ensure there are no substantial changes to your [self][joint]-assessment that could
affect the onsite verification process. Please note that SLCP has issued a COVID-19 – Enhancement to Verified
Assessment Report Information document which also contains information for facilities on how to complete
the self/joint-assessment. Please find it attached.

For further information about SLCP, please go to https://slconvergence.org/helpdesk.

Kind regards,

[Verifier Body name/ Sender name]

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Annex V Document List

List of Documents/Records to be made available to the Verifier(s)

Factory Profile:
1. Company Profile
2. Business Registration License
3. Tax Registration
4. Organization chart
5. Land use/construction permit
6. List of Machineries
7. Company vehicle list
8. Production process flow chart
9. List of subcontractors, if any
10. Dormitory details
11. List of Fire equipment
12. Any certificate by any other independent organization like SA8000, ICTI etc.
13. Building approval plan (architectural & structural) from concern Govt. authority; Approved building
construction lay out from engineering authority, if applicable
14. Building layout approval from fire service & Fire Occupancy Certificate
15. Employee name list

Recruitment / Hiring & Termination


1. Recruitment policies and procedures & Age verification process
2. Child Labor Remediation Procedure
3. Security Service Contract
4. Training Records other than Health & Safety
5. Work permits (internal /external)
6. Employment Contracts
7. Job announcement/description, job application form, if applicable
8. Labor broker contract & dispatching worker personal records/contract
9. Apprenticeship program (if applicable)
10. Immigrant workers (working permit /visa, passport, contract, personal records)
11. Adolescent workers (registration/approval letter from local labor bureau, health checking record)
12. Termination policy and procedure, training records
13. Employee resign records

Working Hours:
1. Time in/out records (Working hour & overtime hour records)
2. Production records (Cutting, stitching, quality etc.)
3. Overtime waiver if any
4. Comprehensive working hours permit if applicable
5. Working hours policy including voluntary overtime policy
6. Overtime approval process/procedure and OT request records, if applicable

Wages & Benefits


1. Minimum wage Notification
2. Payroll (Wage records)
3. Full & Final Settlement
4. Leave records
5. Bonus records
6. EOBI (Employees Old Age Benefit) records
7. Social security records & commercial insurance records
8. Receipts showing tax payments / social security remittances to appropriate public agencies

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9. Evidence of granting maternity/paternity leave and subsequent return to work
10. Piece rate wages sheet, if applicable
11. Annual leave and any paid leave payment record
12. Bank transferring records (for wages if applicable)

Employee Treatment & Involvement:


1. Records from disciplinary procedures
2. Meeting notes from any type of worker/management committee
3. Trade union records
4. Grievance register / Grievance mechanism (procedure, intake channel, investigation/ solution/
feedback records
5. Org Chart of Trade union, worker/management committee
6. Written policies regarding anti-harassment, physical/sexual/emotional abuse and non-discrimination,
no forced labor
7. Freedom of association procedure

Health & Safety:


1. Building plan approval / Permit
2. Fire NOC
3. Genset installation approval
4. Building Stability Certificate
5. Appointment of Labor Welfare / Safety Officer
6. Drinking Water Potability test
7. Boiler License
8. Lift License / Inspection certificate
9. Boiler Operator and Electrician Certificate
10. Noise and Illumination level test Certificate
11. Sanitation Certificate
12. Health Certificate for Workers
13. Doctor / Nurse Appointment Letter
14. First Aid Training Certificate
15. Fire Fighting Training Certificate
16. Fire Mock drill training records
17. Industrial accident records
18. Pollution Control board – Consent order
19. Waste disposal records / Procedures
20. Personal Protective Equipment (PPE) training records
21. Chemical safety training records
22. List of chemicals used (Hazardous / Non-hazardous)
23. Material Safety Data Sheets (MSDS) records
24. Maintenance records of eye wash station
25. Machines maintenance/service records
26. Lock Out/Tag Out survey report, LOTO training records
27. Water Extraction Permit, if applicable
28. Permit for onsite waste disposal
29. License issued by government authority to hazardous waste collector
30. Contract agreement with licensed contractor for hazardous waste collection
31. Hazardous Waste Transfer Contract/ License of Hazardous Waste Handler/License of Hazardous
Waste Transporter/Hazardous Waste Manifest, if applicable
32. Waste inventory and tracking records
33. Wastewater monitoring records
34. Flow Chart (indicating all key processes)
35. Drainage layout
36. Waste treatment equipment’s maintenance records
37. Wastewater Treatment Plant operator certificate, if applicable

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38. Approval of waste treatment system i.e. IEE (Initial Environmental Examination) / EIA (Environmental
Impact Assessment)
39. Environmental Impact Assessment Reports and Approval / Environmental Protection Acceptance
Report / Pollutant Discharge Permit if applicable
40. Air emissions control equipment’s maintenance records
41. Ozone Depleting Substances (ODS) inventory and maintenance records
42. Fuel consumption record for factory’s transportation
43. Green House Gases (GHG) emissions inventory
44. Emergency response plan including relevant training and drills records
45. Risk Assessment (procedure & records)
46. Banned Chemicals List, if any
47. Vehicle operator licenses for any/all types of motorized vehicles
48. Meeting notes from recent health and safety committee
49. Air receiver is fit to operate certificate
50. Steam receiver is fit to operate certificate
51. Food test reports
52. Accident records / accident analysis records
53. Electrical safety test report
54. Thermographic survey report
55. VOC test reports /Air emission monitoring report if applicable
56. Cooling tower water reports / legionella reports
57. Inspection reports (fire hydrant system, sprinkler, detection system, extinguisher, firefighting
equipment, emergency lamps)
58. PPE suitability assessment, PPE selection criteria, PPE list, PPE inspection records
59. Confined space list, confined space entry procedure
60. PCB survey, PCB training records PCB
61. Asbestos survey, training records
62. Food supplier’s medical reports
63. PHI report for the canteen
64. Canteen License
65. Hot Work operation procedure
66. Compressed gas cylinder operation procedure
67. Work permits for special & dangerous operations – forklift driver, lift operator, Electrician and
Welder, boiler operator

Management Systems:
1. Social & Labor Policies and Procedures (including goal/strategy/performance, responsible persons
(roles & responsibility, CSR team org chart)
2. Factory rules and regulations / Employee handbook
3. 3. EHS policy & procedure
4. Communication and training records for employees, suppliers, subcontractors
5. Internal audit records and improvement plan

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Annex VI SLCP Code of Conduct

Document Verifiers agree to during Verifier qualification process:

SLCP expects individuals vetted and approved through the Verification Oversight Organization (VOO) to follow
the principles outlined in the SLCP Code of Conduct.

Integrity

Conflicts of interest and impartiality:

SLCP verifications must be impartial and avoid conflicts of interest that, in fact or in appearance, may create an
incentive to report anything other than the true and accurate facts gathered during the SLCP verification.

Corruption:

Verifier Bodies shall manage risks and ensure compliance with all applicable laws related to corrupt practices.

Integrity:

Members must promote a culture of integrity to address audit integrity and bribery risks that may exist before,
during and after each social compliance audit.

Confidentiality:

Members must maintain confidentiality with respect to information gathered while executing a social
compliance audit, in order to minimize the possibility of inadvertent disclosure, and take reasonable steps to
prevent unauthorized access to information collected during or relating to an audit.

Competence

Personnel:

Verifier Bodies shall only deploy social compliance audit personnel (whether direct employees or independent
contractors) who demonstrate, at a minimum, the relevant knowledge, skills and attributes outlined in the
SLCP Competency Framework, and are going to act in accordance with the Code.

Supervision:

Verifier Bodies shall ensure all their personnel are adequately supervised to ensure all work is performed as
directed and supports the verified assessment data.

Verified Assessment Data and Records

Report Generation and Submission:

Verifier Bodies shall ensure an accurate, concise, and clear verified assessment report, signed off by an SLCP
approved Verifier and Verifier Body, is provided to the facility.

Supporting Documents:

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Verifier Bodies shall ensure each verified assessment report is supported by evidence demonstrating the work
performed in sufficient detail to support the information deemed as accurate or inaccurate in the final dataset.

Handling of Sensitive Information:

Sensitive issues, such as abuse or harassment which may lead to retaliation against workers, or attempts to
bribe, threaten or coerce Verifiers shall be handled with utmost care to protect workers and Verifiers.

Record Management:

Verifier Bodies shall have systems in place to ensure all data is collected, stored and transferred in compliance
with applicable law, is secure and only accessible by authorized persons.

Obligations to SLCP and VOO

Transparency with SLCP and the Verification Oversight Organization (VOO):

Upon request by SLCP and/or the VOO, true and accurate information shall be made available by Verifier
Bodies to verify conformance with SLCP expectations.

Accountability:

Verifier Bodies shall develop and uphold principles which reflect integrity and professional ethical behavior as
outlined in this document. They will comply with all applicable laws and regulations, policies and procedures,
follow professional business practices, and have processes in place for handling complaints and appeals.

Verifiers

In SLCP’s Competency Framework, Verifiers are committed to act in accordance with items in this
document. All Verifiers, shall comply with all relevant legislation, policies and procedures, and maintain the
integrity of the Code

Verifiers are only able to carry out verification as part of an approved Verifier Body.

Obligations of SLCP and VOO

Privacy and Data Protection:

SLCP and VOO shall only collect information from Verifiers and Verifier Bodies that is necessary to determine
their eligibility to participate in SLCP. This information will only be accessed by SLCP and selected VOO
employees as required in the execution of their duties, unless express permission is given by the Verifier or
Verifier Body. SLCP complies with international data collection, privacy and security standards requirements,
and ensures all information is collected and maintained in a way which protects the privacy of the Verifiers and
Verifier Bodies.

Openness:

SLCP and VOO will provide public access to, or disclosure of, appropriate and timely information about the
SLCP process, and status (i.e. the granting, extending, maintaining, renewing, suspending, reducing the scope
of, or withdrawing of permission to act) of any Verifier, in order to gain confidence in the integrity and
credibility of the process. Openness is a principle of access to, or disclosure of, appropriate information.

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Annex VII Additional On-site Verification Information

WALKTHROUGH/ ONSITE OBSERVATION:


SLCP recommends interacting with the employees during the walkthrough by asking them to demonstrate
things, like:
o Where is your nearest fire exit?
o Who is your fire warden?
o How do you transfer this chemical into that pot?
o How do you move this fabric to that shelf? 


Some important areas to consider are:


o Site perimeter: facility external premises and immediate perimeter of the facility, including loading
bays, waste storage, chemical storage, emergency assembly points, sub-facilities, canteens,
dormitories or any other accommodation provided to workers by the facility, even if not in the same
location
o Fire safety plans and equipment, evacuation notification system and route markings, and emergency
exits
o Actions of employees towards cleanliness and safety
o Attitude of line supervisors and department heads towards employees
o Location and capacity of clocking in & out machines and/or attendance records
o Production lines
o Hygiene facilities including toilets, hand washing, hand drying and potable water
o Raw materials storage, finished goods storage, areas and access control procedures
o Boiler room and compressor house
o Power generator (if any)
o Wastewater treatment plant (if any)
o Internal and external transport area (if applicable) and shuttle buses (if provided by company)
o Checking the roof (if possible)
o Any locked rooms that the Verifier was not able to access (if any concerns)
o Additional areas that may or may not be present include confined spaces, elevators, childcare
facilities, medical clinic, canteen or kitchen

WORKER INTERVIEW:
SLCP expects all Verifiers to already be experienced in interviewing techniques before they are approved to
carry out verifications.

Key principles for achieving good quality of information:


o Representation: seek a variety of views across all types of roles within the facility
o Outliers: identify those persons likely to represent the highest/ lowest scale of a given practice such
as working hours or wages
o Seniority: include the newest employees to understand the orientation process
o Leadership: connect with employee representatives such as union officials or committee members or
any type of elected representative
o Efficient approach: be courteous on the amount of time for an interview, recognizing that the time
represents potential earnings to the employee (and his/her work group)

SLCP recommends the selection of interviewees with these qualities in mind (illustrative only – each facility will
vary):
o New hires
o Employees under probation
o Young employees
o Apprentice/ student employees
o Union/ worker representative
o Pregnant employees
o Employees returning from maternity leave

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Converged Assessment.
Collaborative Action.
Improved Working Conditions.
o Employees from any other vulnerable group
o Temporary/ contract employees
o Fixed term/ non fixed term contract employees
o Employees from different departments, different salary levels, different job positions
o Workers of various nationalities (including migrant employees and foreign contract employees)
o Persons performing hazardous work such as chemical storage and disposal
o Relatively gender-balanced, ensuring representation in the case of a small minority

To make the most of the interviews, SLCP recommends the following process:
o Interviews should take place the morning of the first day of verification, with further interviews taking
place in the middle and towards the end of the verification to corroborate information the Verifier
has found.
o Discussions should take place in a quiet, private area away from management offices with no
representatives of management present.
o Informal discussions should also take place during the physical tour of the employment site, at lunch
time or during breaks, with care not to prevent employees from eating or taking appropriate rest.
o Explain the purpose of the verification and that all interview information will be unattributed.
o Begin the interview process with questions that are most likely to elicit routine and uniform data such
as contracts, the orientation process and emergency evacuation practice, to validate that employee
experiences are consistent with documentation. If the early data is consistent, then eliminate those
questions in favor of issues where more variance is expected.
o Focus conversations towards issues that are likely to vary by position and supervisor such as:
enforcement of safety rules, disciplinary process, grievance procedure, harassment, use of
contractors on site and assignment of overtime.

Be aware that the individuals involved may not directly address sensitive issues. Because of that, it can be
useful to ask whether employees in another area potentially experience problems like harassment or
intimidation by supervisors. This second-hand information may indicate an opportunity to expand the
interview sample, and if corroborated or if other employees second-hand repeat the same information must
be added to verification data in the appropriate section.

MANAGEMENT INTERVIEWS:

Management interviews should be used to gain better understanding of:


1. General overview of facility management (who is in charge of what);
2. How the facility is organized (e.g. departments, sections, lines);
3. How workers are managed (e.g. line leaders, supervisors, department managers);
4. What the facility management see as risks to their business;
5. How workers are managed throughout the employment cycle (e.g. recruitment, onboarding,
payment, leave, termination);
6. What human resources policies and procedures are;
7. How workers communicate issues to management;
8. What health and safety policies and procedures are.

Some general guidance around management interviews:


o Try to determine in advance which facility personnel you will need to speak with and when;
o Use the opening meeting to confirm their availability and adjust as necessary;
o Ask open ended questions to gather data;
o Try to keep management interviews conversational rather than a series of yes/no questions;
o If management shares information that requires follow up, ask additional questions and use
triangulation with record review and worker interviews as necessary;
o Manage your time effectively: be respectful of facility management’s schedules and also be aware of
how much time you have allotted to complete the verification;
o Be polite but firm if management tries to influence the outcomes of the verification;

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Converged Assessment.
Collaborative Action.
Improved Working Conditions.
o If during the interview you find inaccuracies or legal flags, share this information immediately and do
not wait till the closing meeting;
o Remain impartial: it is not the role of the Verifier to enforce requirements or a specific compliance
standard).

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