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SLCP Verification Protocol Guide

This document provides the verification protocol for the Social and Labor Convergence Program (SLCP) assessment framework version 1.4-1.1. It outlines the requirements that must be followed by Verifier Bodies and Verifiers, including conducting on-site verifications, reviewing self-assessments, addressing facility questions, and finalizing verified assessment reports. The protocol is intended to support converged assessment, collaborative action, and improved working conditions.
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0% found this document useful (0 votes)
103 views131 pages

SLCP Verification Protocol Guide

This document provides the verification protocol for the Social and Labor Convergence Program (SLCP) assessment framework version 1.4-1.1. It outlines the requirements that must be followed by Verifier Bodies and Verifiers, including conducting on-site verifications, reviewing self-assessments, addressing facility questions, and finalizing verified assessment reports. The protocol is intended to support converged assessment, collaborative action, and improved working conditions.
Copyright
© © All Rights Reserved
We take content rights seriously. If you suspect this is your content, claim it here.
Available Formats
Download as PDF, TXT or read online on Scribd
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Converged Assessment.

Collaborative Action.
Improved Working Conditions.

Social and Labor Convergence Program (SLCP)


Verification Protocol
Version 1.4-1.1

5 April 2021

This Verification Protocol applies to Version 1.4 of the Converged Assessment Framework.
This is a comprehensive document and it is important that it is read thoroughly.
Section 3 and Section 5 provide a list of mandatory requirements that Verifier Bodies/ Verifiers must follow. The added guidance to the
requirements provides a thorough explanation of each mandatory requirement along with examples, support documents and
recommendations.

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 Guidance (Facility, Verifier), as well as the QA Manual.

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Change Log
This document will be updated on an as-needed basis. Whenever there is an update, VBs are informed through technical bulletins and webinars.

Date Section Change Summary


Updating of hyperlinks and email addresses throughout the document
2020/06/29 Entire document
Edits to make language clearer
2020/06/29 Entire document Additions related to COVID-19, e.g. verification scheduling, onsite verification procedures, etc.
New Annex III: COVID-19 – Enhancement to Verified Annex III gives detailed instructions on how to include COVID-19 information, as applicable, in the self/joint-assessment
2020/06/29
Assessment Report Information 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
Inclusion of short statement about Verification Data for “Accurate” items (more details included in Verifier Guidance)
2020/06/29 Overview of the SLCP Assessment Process
Updated graphic to explain the assessment process
Clearer language about eligibility to conduct a verification
2020/06/29 Eligibility of Verifiers
Reference to Verifier Status Maintenance
Added new statuses of VRE, VRQ and made some additions/ changes to timeframes for edit/review by Verifier and
2020/06/29 Details of the SLCP Assessment Process facility
Updated visual of SLCP assessment process with VRQ, VRE
3.-5. Facility account creation on AH platform, initiating
2020/06/29 Note for newly operation facilities; min. 3 months data required in self-assessment
self/joint-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
9. VB/ Verifier reviews self/joint-assessment to determine
2020/06/29 More clarity on person-day assignments if step 1+2 or step 1+2+3 is selected
correct person-day requirements
11. Verifier reviews self/joint-assessment in detail to prepare
2020/06/29 Background check addition: previous social audit/ SLCP reports
for onsite verification, including facility background check
Additions to:
o clarify potential change to person-days when onsite.
o ensure all types of production employees are considered in verification
14. Verifier conducts onsite verification (opening meeting,
2020/06/29 o clarify language requirements
walk through, interviews, document review, closing meeting)
o remind Verifier to add translator information in Verification Details
o add detail around management interviews
o cover the topic of denied access
15. Verifier focuses on Verification Summary; addresses
2020/06/29 Addition of Verifier guidance around reporting verified assessment data to users other than the facility
facility questions/ concerns during closing meeting
16.-20. Resolving facility concerns, filling in Tool, completing
Explanation of new statuses VRQ and VRE and Verifier responsibilities
2020/06/29 report online to run AH checks, VB quality check, VRQ check
Recommendation for Verifier/ VB downloading of verified assessment report for document retention
with VRE edits, changing assessment status to VRC
21.-24. Facility reviews verified assessment, connects offline
Explanation of new status VRE and Verifier responsibilities
2020/06/29 with Verifier/ VB for concerns and requests edits as
New timeframe for facility report finalization as multiple edit rounds can occur (14 calendar days instead of 10)
necessary, accepts verification or raises Dispute

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Annex IV Verification Communication Template (suggested Revision to make it easier to read/ understand
2020/06/29
communication) Addition of COVID-19 document reference
More details about what types of employees to interview
2020/06/29 Annex VII Additional On-site Verification Information
Management Interview guidance

Introduction of versioning according to CAF Version


2021/03/07 Versioning
Version 1.0 of the Protocol for CAF v1.4, hence Version 1.4-1.0

Reformatted and restructured to ensure verification related requirements are clear and clearly
2021/03/07 Entire document communicated as requirements
See especially chapter: 3. SLCP Verification Requirements

Removal of requirements/ information for facilities due to introduction of new CAF document:
2021/03/07 Entire document
Facility Guidance

Addition of requirements from Verifier Guidance to separate “Guidance” from “Protocol”


2021/03/07 Entire document
requirements

New chapters:
Helpful information for navigating SLCP terminology and definitions used in the Data Collection
2021/03/07 Acronyms
Tool
Definitions of Terms

3.1.4. Requirements for Calculating Number of


Person-days, Interviews and Documents to
Review Person-day requirements have changed, along with minimum requirements for interviews,
2021/03/07
personnel records and wage and hours records review
Table 2: Determining Person Days, Number of
Interviews and Sample Document Review

New chapters:
4. SLCP Virtual Verification Process SLCP is permitting additional aspects of verification to occur virtually (i.e., remotely through
2021/03/07
desktop, phone, web-enabled activities)
5. SLCP Virtual + Onsite Verification
Requirements

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Offsite desktop review for policies and procedures has been in place from the start, but now has
expanded to include activities such as web-based payroll review, remote interviews and virtual
walkthroughs
Offsite review is now incorporated into virtual + onsite activity
An SLCP verification still requires onsite activity with minimum 1 person-day

Annex III COVID-19 – Inclusion of COVID-19


2021/03/07 Updated with new Question numbers and text to reflect CAF v1.4 changes
information in Verified Assessment Report

Annex IV Verification Communication Template Updated to include Facility Guidance and information about virtual/offsite/desktop + onsite
2021/03/07
(suggested communication) verification

2021/04/05 Versioning Version 1.1 of the Protocol for CAF v1.4, hence Version 1.4-1.1

2021/04/05 Correction of mistake under Guidance for Original: If the facility chooses more than Step 1 (i.e. Step 2 or Step 3), person-day requirements
3.1.3.3. must be at least half a person-day more than the indicated Step 1 minimum. For example, if the
facility has 1-100 workers, Step 1 minimum is 1 person-day, Step 2 minimum is 1.5 person-days,
Step 3 minimum is also 2 person-days.
Correction: If the facility chooses more than Step 1 (i.e. Step 2 or Step 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 workers, Step 1 minimum is 1 person-day, Step 2 minimum is
1.5 person-days, Step 3 minimum is also 1.5 person-days.

2021/04/05 Correction of use of “employee” or “employees” Several changes where “employee” was mentioned changed to “worker” instead. E.g. mistake
under 3.2.1.1. where section was still listed as Employee Treatment and Employee Involvement.
Changed to Worker Treatment and Worker Involvement.

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Table of Contents

Terms of Use...................................................................................................................................................................................................................................... 10

Glossary ............................................................................................................................................................................................................................................ 11

Acronyms .......................................................................................................................................................................................................................................... 13

Definition of Terms ............................................................................................................................................................................................................................ 14

1. Introduction ................................................................................................................................................................................................................................... 16
1.1. Overview of the Converged Assessment Framework (CAF) .......................................................................................................................................................................... 16
1.2. Overview of the SLCP Assessment Process ................................................................................................................................................................................................... 18
1.3. Structure of the SLCP Verification Protocol .................................................................................................................................................................................................. 20

2. SLCP Verification Process ................................................................................................................................................................................................................ 21


2.1. Characteristics of an Audit vs. SLCP Verification .......................................................................................................................................................................................... 21
2.2. Details of the SLCP Assessment Process ....................................................................................................................................................................................................... 22
2.2.1. SLCP Statuses ......................................................................................................................................................................................................................................... 22
2.2.2. SLCP Actors ............................................................................................................................................................................................................................................ 22
Table 1: SLCP Statuses ................................................................................................................................................................................................................................ 23
2.3. Pre-Onsite Verification .................................................................................................................................................................................................................................. 29
2.3.1. Account Maintenance on Gateway ....................................................................................................................................................................................................... 29
2.3.2. Planning the Verification ....................................................................................................................................................................................................................... 29
2.3.3. Assigning a Verifier ................................................................................................................................................................................................................................ 30
2.3.4. Assigning Person-days ........................................................................................................................................................................................................................... 30
2.3.5. Calculating Number of Person-days, Interviews and Documents to Review ....................................................................................................................................... 31
2.3.6. Review of Self/Joint-Assessment .......................................................................................................................................................................................................... 31
2.3.7. Pre-verification Communication to Facility........................................................................................................................................................................................... 31
2.3.8. Download Back-up of Data Collection Tool from AH platform ............................................................................................................................................................. 32
2.4. Onsite Verification ........................................................................................................................................................................................................................................ 32

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2.4.1. Opening Meeting Onsite Verification Requirements ............................................................................................................................................................................ 32


2.4.2. Walkthrough Onsite Verification Requirements ................................................................................................................................................................................... 33
2.4.3. Worker and Management Interviews Onsite Verification Requirements ............................................................................................................................................ 33
2.4.4. Document Review Onsite Verification Requirements .......................................................................................................................................................................... 33
2.4.5. Document and Photo Attachment Onsite Verification Requirements ................................................................................................................................................. 33
2.4.6. Pre-closing Meeting Onsite Verification Requirements ........................................................................................................................................................................ 34
2.4.7. Closing Meeting Onsite Verification Requirements .............................................................................................................................................................................. 34
2.5. Post-onsite Verification................................................................................................................................................................................................................................. 34
2.5.1. Resolving Facility Concerns ................................................................................................................................................................................................................... 34
2.5.2. Report Writing ....................................................................................................................................................................................................................................... 34
Focus on “Verification Data” Narrative ...................................................................................................................................................................................................... 35
2.5.3. VB Quality Check ................................................................................................................................................................................................................................... 36
2.5.4. VB Document Retention ........................................................................................................................................................................................................................ 36
2.5.5. Facility Reviews Verified Assessment Report........................................................................................................................................................................................ 37
2.5.6. Facility Responds After Review of the Verified Assessment Report ..................................................................................................................................................... 37
2.5.7. Raising a Dispute ................................................................................................................................................................................................................................... 38
2.5.8. Facility Shares Verified Assessment via the Gateway and/or the Accredited Host .............................................................................................................................. 38
2.6. In line with legal requirements ..................................................................................................................................................................................................................... 38
2.6.1. Identifying and citing when facility is not in line with legal requirements ........................................................................................................................................... 38
2.6.2. Tool meaning of “Consult applicable legal requirements” ................................................................................................................................................................... 38
2.7. Law Guidance and Law Overlay .................................................................................................................................................................................................................... 40
2.7.1. Data Collection Tool “Law Guidance” and Automated Entry of Non-Compliance and Legal Reference ............................................................................................. 40
2.8. Quality Assurance ......................................................................................................................................................................................................................................... 41
2.8.1. VOO Quality Assurance Procedures for Accepted Verified Assessments ............................................................................................................................................. 41
2.8.2. Verifier Feedback .................................................................................................................................................................................................................................. 41

3. SLCP Verification Requirements ...................................................................................................................................................................................................... 44


3.0. General Requirement .................................................................................................................................................................................................................................... 44
3.1. Pre-onsite Verification .................................................................................................................................................................................................................................. 44
3.1.1. Requirements for Planning the Verification.......................................................................................................................................................................................... 44
3.1.2. Requirements for Assigning a Verifier .................................................................................................................................................................................................. 46
3.1.3. Requirements for Assigning Person-days.............................................................................................................................................................................................. 47

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3.1.4. Requirements for Calculating Number of Person-days, Interviews and Documents to Review .......................................................................................................... 47
Table 2: Determining minimum person-days, number of interviews and sample of document review ................................................................................................... 48
3.1.5. Requirements for Review of Self/Joint Assessment ............................................................................................................................................................................. 51
3.1.6. Requirements for Pre-verification Communication to Facility ............................................................................................................................................................. 53
3.2. Onsite Verification ........................................................................................................................................................................................................................................ 55
3.2.1. General Onsite Verification Requirements ........................................................................................................................................................................................... 55
3.2.2. Opening Meeting Onsite Verification Requirements ............................................................................................................................................................................ 58
3.2.3. Walkthrough Onsite Verification Requirements ................................................................................................................................................................................... 59
3.2.4. Worker and Management Interview Onsite Verification Requirements .............................................................................................................................................. 60
3.2.5. Document Review Onsite Verification Requirements .......................................................................................................................................................................... 62
3.2.6. Document and Photo Attachment Onsite Verification Requirements ................................................................................................................................................. 64
3.2.7. Pre-closing Meeting Onsite Verification Requirements ........................................................................................................................................................................ 67
3.2.8. Closing Meeting Onsite Verification Requirements .............................................................................................................................................................................. 67
3.3. Post-onsite Verification................................................................................................................................................................................................................................. 69
3.3.1. Requirements for Resolving Facility Concerns ...................................................................................................................................................................................... 69
3.3.2. Verified Assessment Report Revision Requirements ............................................................................................................................................................................ 70
3.3.3. Requirements for Report Writing ......................................................................................................................................................................................................... 71
Table 3: Requirements for Completion of Verification Fields .................................................................................................................................................................... 74
3.4. VB Quality Check and Document Retention.................................................................................................................................................................................................. 82
3.4.1. Requirements for VB Quality Check ...................................................................................................................................................................................................... 82
3.4.2. Requirements for VB Document Retention .......................................................................................................................................................................................... 83
3.5. Ethics ............................................................................................................................................................................................................................................................. 84
3.5.1. Anti-bribery Requirements.................................................................................................................................................................................................................... 84

4. SLCP Virtual + Onsite Verification Process........................................................................................................................................................................................ 86


4.1. Introduction .................................................................................................................................................................................................................................................. 86
4.2. Some Onsite Verification Requirements Apply to Virtual Verification ......................................................................................................................................................... 86

5. SLCP Virtual + Onsite Verification Requirements .............................................................................................................................................................................. 88


5.1. Pre-virtual verification .................................................................................................................................................................................................................................. 88
5.1.1. Requirements for Planning Different Types of Virtual Verification Activity ......................................................................................................................................... 88

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5.1.2. Requirements for Assigning a Verifier .................................................................................................................................................................................................. 91


5.1.3. Requirements for Assigning Virtual Verification Activity Time ............................................................................................................................................................. 91
5.1.4. Requirements for Calculating Number of Person-days, Interviews and Documents to Review .......................................................................................................... 93
5.1.5. Requirements for Review of Self/Joint Assessment ............................................................................................................................................................................. 95
5.1.6. Requirements for Pre-verification Communication to Facility ............................................................................................................................................................. 95
5.2. Virtual Verification ........................................................................................................................................................................................................................................ 97
5.2.1. Verification Protocol Onsite Activities that can be Replaced by Virtual Activity .................................................................................................................................. 97
5.3. Post-virtual Verification .............................................................................................................................................................................................................................. 103
5.3.1. VOO Quality Assurance and Report Writing Procedures for Virtual Verification Activities ............................................................................................................... 103

Annex I Professional Conduct ........................................................................................................................................................................................................... 106


Prohibition on Sales ........................................................................................................................................................................................................................................... 106
Confidentiality .................................................................................................................................................................................................................................................... 106
Impartiality ........................................................................................................................................................................................................................................................ 106
Respectfulness and Professionalism .................................................................................................................................................................................................................. 106
Personal Safety .................................................................................................................................................................................................................................................. 106
Facility Safety ..................................................................................................................................................................................................................................................... 107

Annex II Filtering of Verifier Body and Verifier................................................................................................................................................................................... 108

Annex III COVID-19 – Inclusion of COVID-19 Information in Verified Assessment Report ..................................................................................................................... 110

Annex IV Verification Communication Template (suggested communication) ..................................................................................................................................... 119

Annex V Document List .................................................................................................................................................................................................................... 121


Factory Profile ............................................................................................................................................................................................................................................... 121
Recruitment / Hiring & Termination ............................................................................................................................................................................................................. 121
Working Hours............................................................................................................................................................................................................................................... 121
Wages & Benefits .......................................................................................................................................................................................................................................... 122
Worker Treatment & Involvement ................................................................................................................................................................................................................ 122

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Health & Safety.............................................................................................................................................................................................................................................. 122


Management Systems ................................................................................................................................................................................................................................... 124

Annex VI SLCP Code of Conduct ........................................................................................................................................................................................................ 126


Conflicts of interest and impartiality ................................................................................................................................................................................................................. 126
Corruption .......................................................................................................................................................................................................................................................... 126
Integrity.............................................................................................................................................................................................................................................................. 126
Confidentiality .................................................................................................................................................................................................................................................... 126
Competence ....................................................................................................................................................................................................................................................... 126
Personnel....................................................................................................................................................................................................................................................... 126
Supervision .................................................................................................................................................................................................................................................... 126
Verified Assessment Data and Records ............................................................................................................................................................................................................. 126
Report Generation and Submission .............................................................................................................................................................................................................. 126
Supporting Documents .................................................................................................................................................................................................................................. 126
Handling of Sensitive Information................................................................................................................................................................................................................. 127
Record Management ..................................................................................................................................................................................................................................... 127
Obligations to SLCP and VOO ............................................................................................................................................................................................................................ 127
Transparency with SLCP and the Verification Oversight Organization (VOO) .............................................................................................................................................. 127
Accountability ................................................................................................................................................................................................................................................ 127
Verifiers ......................................................................................................................................................................................................................................................... 127
Obligations of SLCP and VOO............................................................................................................................................................................................................................. 127
Privacy and Data Protection .......................................................................................................................................................................................................................... 127
Openness ....................................................................................................................................................................................................................................................... 127

Annex VII Additional On-site Verification Information ....................................................................................................................................................................... 128


Walkthrough/ Onsite Observation ..................................................................................................................................................................................................................... 128
Worker Interviews.............................................................................................................................................................................................................................................. 129
Management Interviews .................................................................................................................................................................................................................................... 130

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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. Guidance (Facility, Verifier).
“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.
“Facility Guidance” Element 3 of the Converged Assessment Framework. The document that helps facilities understand the SLCP process and complete the
self/joint-assessment by giving guidance on how to enter facility responses into in the Data Collection Tool.
“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, VBs and Verifiers

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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.
“Verification Oversight Organization (VOO)” Entity responsible for the day-to-day management of SLCP verifications. It manages the selection of VBs 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, 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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Acronyms
AH Accredited Host
ASC Assessment Completed
ASI Assessment Initiated
CAF Converged Assessment Framework
FFC Fair Factories Clearinghouse
GW Gateway
ITC International Trade Centre
QA Quality Assurance
SLCP Social and Labor Convergence Program
VB Verifier Body
VBs Verifier Bodies
VOO Verification Oversight Organization
VRC Verification Completed
VRD Verification Disputed
VRE Verification being Edited
VRF Verification Finalized
VRI Verification Invalidated
VRP Verification in Progress
VRQ Verification Quality Check

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Definition of Terms
Casual workers Persons who work occasionally and intermittently, and are employed for a specific number of hours, days or weeks. They
are not normally entitled to the same terms and conditions of employment as ordinary workers (e.g. they would not
usually get sick or holiday leave).
Contract workers Persons working on/with the facility’s product or directly involved in the operations of the facility and who are
contracted by agencies, i.e. not under employment contract with the facility. Examples include workers who are at the
facility and employed by a third party to do line work or maintenance on machinery. They are not cleaning, security,
canteen staff or other staff not working on facility product or activities related to production. Those workers are non-
production workers.
Domestic migrant workers Persons who moved from their hometown for work in another town located in the same country, i.e., persons whose
hometown is not the town where the facility is located. A worker is a domestic migrant if they live in place X for work but
their permanent home where their family resides is in place Y. However, if the location of the facility is considered
‘home’ then the worker would not be considered a domestic migrant.
Foreign migrant workers Persons who moved from their home country for work in another country, i.e., persons whose home country is not the
country in which the facility is located.
Law Overlay The Tool (offline and online) has information in the section introductions that address international labor
standards that are applicable to that specific section/ sub-section topic. This is Law Guidance specific to
international labor standards only.
The Law Overlay is both the Law Guidance by country and the automatic entry of Non-Compliance and Legal
Reference according to the final verified response.
The final verified response is the facility response if Accurate, or the Corrected Response or Verification Data
by the Verifier.
On the AH platform, the users (facilities and Verifiers) will see a Law Guidance link (similar to More Info). When
they go to that info box, they will see Law Guidance information about country specific legal requirements
specific to that question. And if Law Guidance at question level is implemented also the automatic entry of
Non-Compliance and Legal Reference is implemented. The Law Overlay is both the Law Guidance field (country
and question-specific) and automatic entry of Non-Compliance and Legal Reference together as a package.

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See more information here.


Non-production workers Persons not involved in the production of goods and in operations related to the product, e.g. distribution.
Non-production workers include security guards, canteen workers and cleaners.
Permanent workers Persons hired on an open-ended/ indefinite/ permanent basis.
Production Applies to all operations in a facility, since many facilities are not directly involved in “production” per se, (i.e. distribution
centers, warehouses, etc.).
Supervisors Persons who lead or supervise others and who work on the production floor (not in the office, e.g., line leaders, group
leaders, and department heads, but not managers.
Workers Persons working on/with the facility's product, ensuring machinery is working to produce product, or directly involved in
the operations of the facility. They are non-supervisory, which means no one report to them (if a person is in a
supervisory role, e.g. sewing line group leader, they would not be counted as “worker”). Facilities include those involved
in production of goods, and also those involved in operations related to the product, e.g. distribution. Examples of
"workers" are cutters, sewers, QC, packers, etc. (all workers who contribute to producing the product), boiler workers,
mechanics (machine repair persons), electricians and workers who load product onto trucks.

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1. Introduction

1.1. Overview of the Converged Assessment Framework (CAF)


The Converged Assessment Framework (CAF) consists of three elements:

Data Collection Tool

• Used by facilities and Verifiers


• Records facility data and verification data on social and labor conditions in facilities
• Executed through AH online platform (recommended) or through downloadable Excel from AH

Verification Protocol

• Verification procedures and requirements for SLCP approved Verifier Bodies and Verifiers
• Verifier Bodies and Verifiers receive and maintain SLCP approval by following procedures and requirements outlined in the SLCP
Quality Assurance Manual

Guidance

• Facility Guidance: to understand assessment process and complete the self/joint-assessment


• Verifier Guidance: to understand how to write the verified assessment report

You can access the other CAF files on our Helpdesk.

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The CAF is standard neutral. That means:

The CAF DOES The CAF DOES NOT

• collect self-reported demographic, compliance related • set minimum requirements


and performance information from facilities
• act as a scoring/ranking system, certification program or Code
• employ a robust verification process of Conduct

• facilitate operation (data hosting & sharing) • provide corrective action plans or engage in other follow-up
actions

There is no judgment made on the data collected through the SLCP process. It provides objective data on 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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1.2. Overview of the SLCP Assessment Process

Data Collection Data Verification


Collection can be done by either: The Verifier will check the correctness and completeness of the data gathered through the
• Self-assessment (facility only) or joint Data Collection Tool. They will confirm or provide corrections to the original self/joint-
assessment (facility + external assistance) assessment data online on the AH platform or offline via an Excel document downloaded
from the AH. If there is a stable internet connection, it is recommended to use the online AH
• Online or offline by using the Data platform to complete the verification.
Collection Tool.
The Verifier is required to verify each question in the Tool even if the facility did not provide
Self/joint-assessment can be carried out via an Excel an answer. See the Verifier Guidance for details on when to indicate “Accurate”/
document downloaded from the Accredited Host (AH) or “Inaccurate”/ “Updated during Verification” and other Verification Selection options in the
online via an AH platform. If the facility has a stable internet Data Collection Tool. The Verifier must provide Verification Data to support corrected
connection, it is recommended to use the online AH platform responses and is encouraged to provide Verification Data for “Accurate” responses where
to complete the self/joint-assessment. there is a legal non-compliance or a concern relating to general social compliance norms.
The objective of the self-joint assessment is for the facility to The Verification Oversight Organization (VOO) oversees the integrity of SLCP verification and
enter complete and accurate data into the Data Collection ensures the quality of verified assessment data.
Tool.
The objective of Data Verification is to ensure end-users’ acceptance of SLCP data and the
SLCP believes in facility ownership; therefore, it is the facility replacement of their own audit methodologies with the SLCP process.
that starts the SLCP process and they maintain ownership of
all data throughout the process.

Data Hosting and Sharing


With facility permission, the verified assessment report will be shared through a semi-decentralized model with a Gateway and AHs.
The objective Data Hosting and Sharing 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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The SLCP assessment process:

Note:
• The SLCP process begins with registration of all active parties on the Gateway.
• The Active Accredited Host is used to facilitate the data collection for self/joint-assessment and verification and sharing of verified data.
• The Passive Accredited Host only receives verified data from the Gateway, after completion of the full assessment process on an Active AH, and
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1.3. Structure of the SLCP Verification Protocol


The SLCP Verification Protocol is divided into five sections:
1. Introduction: This section provides the reader with an overview of the SLCP Converged Assessment Framework and the assessment process.
2. SLCP Verification Process: This section provides the reader with an overview of the different stages involved in the SLCP verification process. Within
each stage there are links to the specific requirements in Section 3: SLCP Verification Requirements necessary for the VB/Verifier to meet in order
to accurately complete the verification.
3. SLCP Verification Requirements: This section provides the reader with a set of mandatory requirements for the VB/Verifier to meet to complete
the verification process. These requirements are accompanied by guidance and some recommendations to provide support to the VB/Verifier
through the verification process.
4. SLCP Virtual Verification Process: This section explains the SLCP verification if virtual verification activities are included, and how the requirements
for virtual verification will work in conjunction with requirements for onsite verification.
5. SLCP Virtual Verification Requirements: This section provides the reader with a set of mandatory requirements for the VB/Verifier to meet to
complete the verification process if virtual activities are included. Links are also provided to the requirements in Section 3 that must be met
together with the virtual verification requirements in order to successfully complete an SLCP verification with virtual activities. These requirements
are also accompanied by guidance and some recommendations to provide support to the VB/Verifier through the virtual verification process.
The SLCP Verification Protocol is an interactive document. Links at the bottom of each section will bring the user back to the Table of Contents if the user
wishes to go directly to another section of the document. Intra-sectional links are provided so the user can easily navigate between different sections and
sets of requirements within the document.

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2. SLCP Verification Process


The SLCP Verification Protocol specifies procedures, rules and process requirements needed to complete the verification.
The SLCP process does not intend to determine to what extent working conditions in a facility comply with a certification or social compliance standard.
Rather, the SLCP CAF is an agnostic data collection tool (not dependent on a particular standard) and
reporting differs from traditional compliance auditing. Audit: A systematic review or
Therefore, we use specific terminology to underline this distinction. The SLCP program specifies: assessment of something

• Verification rather than Audit or Assessment Verification: The process of establishing


the truth, accuracy, or validity of
• Verifier rather than Auditor something
Source: Oxford University Press

2.1. Characteristics of an Audit vs. SLCP Verification

Audit SLCP Verification


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

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2.2. Details of the SLCP Assessment Process


In the Overview of the SLCP Assessment Process, we present the three main parts to the SLCP assessment 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 in Table 1 below.
2.2.1. SLCP Statuses

ASI- ASC-
Assessment Initiated Assessment Completed

VRP- VRQ- VRE- VRC- VRF-


Verification in Progress Verification Quality Check Verification being Edited Verification Completed Verification Finalized

VRD- VRI-
Verification Disputed Verification Invalidated

2.2.2. SLCP Actors

F-Facility V- VB- GW-Gateway AH- VOO-


Verifier VB Accredited Host Verification Oversight Organization

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Table 1: SLCP Statuses

ACTORS
SLCP
NO. ACTION ESTIMATED TIMELINE1
STATUS
F V VB GW AH VOO

1. Facility creates an account on Gateway ✓ ✓ ✓ ✓

2. Facility discusses verification cost/timeline offline with VBs ✓ ✓


Note: verification can be semi-announced with a 10-day window
and cost/timeline will likely be estimates as self/joint-assessment
information is needed to determine exact person-day
requirements for verification
Week 0
3. Facility creates account on Accredited Host platform using Facility ✓ ✓ All steps before Week 0 are prior to the start
ID from Gateway of the verification process. Note it takes facility on
average 2 weeks to complete
self/joint-assessment as Tool is complex
4. Facility accesses Data Collection Tool through AH and initiates ✓ ✓ and multiple individuals may be required
ASI
self/joint-assessment to provide input/ documentation

5. Facility completes self/joint-assessment; recommend online ✓ ✓


completion but download into Excel from AH is available with ASC
final step of upload to AH required

6. Facility selects VB to conduct verification on Accredited Host ASI or ✓ ✓


platform ASC

7. VB assigns Verifier on Gateway VRP ✓ ✓ Week 1

1
There 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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ACTORS
SLCP
NO. ACTION ESTIMATED TIMELINE1
STATUS
F V VB GW AH VOO

8. VB/Verifier obtain access to non-editable/ locked self/joint- ✓ ✓ ✓


assessment data on AH platform along with documents the VRP
facility uploaded

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


VRP
person-day requirements

10. Verifier reviews self/joint-assessment in detail to prepare for ✓ ✓


VRP
verification, which includes facility background check
Typically, no earlier than week 3

11. Verifier or VB provides pre-verification communication to facility, ✓ ✓ ✓ Typically, no later than week 7
including document list and verification planning information Note self/joint-assessment must be delivered to
VRP
according to Verification Protocol requirements (note any virtual Verifier at least 10 working days prior to
verification activity also requires a verification plan) scheduled virtual and/or onsite visit. Some VBs
may need up to 4 weeks advanced notice to
12. Verifier conducts virtual verification activities, if applicable ✓ ✓ schedule verification, as Verifier schedules are
booked well in advance.
(activities such as offsite documents review, virtual interviews, VRP
virtual walk-through)

13. Verifier downloads Data Collection Tool from AH platform with ✓ ✓


non-editable/ locked self/joint-assessment data for back-up Typically, no earlier than week 4
VRP
during onsite verification in case AH platform connectivity issues
occur Typically, no later than week 8
Note Verifier availability may require up to 4
14. Verifier conducts onsite verification following Verification ✓ ✓ weeks advanced notice and verification can be
Protocol requirements, including opening meeting, document VRP semi-announced with 10-day window
review, interviews, facility walk through, and closing meeting

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ACTORS
SLCP
NO. ACTION ESTIMATED TIMELINE1
STATUS
F V VB GW AH VOO

15. Verifier focuses on entering “Updated during Verification”, ✓ ✓


“Inaccurate” and “Non-Compliance” data to inform Verification
Summary and prepare for closing meeting; verification is VRP
completed online or in downloaded Excel offline; Verifier
addresses any facility questions/ concerns during closing meeting

16. Verifier or VB resolves any further facility concerns/questions ✓ ✓ ✓ ✓


about verification within a maximum of 48 hours after onsite
VRP
verification is completed, 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 automated VRP Typically, no earlier than week 6
checks/flags for proper completion
Typically, no later than week 10
18. VB conducts quality check of Verifier's work and either Verifier or ✓ ✓ ✓
VB changes the assessment status to “Verification Completed” on VRC
AH platform

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
makes necessary edits and -again- changes status to “Verification to Verifier after Verifier completes verification
Completed” on AH platform (VRC); Verifier can choose to immediately review
VRE and 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

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ACTORS
SLCP
NO. ACTION ESTIMATED TIMELINE1
STATUS
F V VB GW AH VOO

21. Facility reviews the verified assessment online or offline in Excel ✓ ✓


by downloading from AH. The facility has 14 calendar days to
review and request edits from the Verifier before facility’s VRC
manual finalization by changing status to VRF or AH’s automated
finalization on calendar day 15.

22. Facility reaches out to VB/Verifier directly (offline/email) with any ✓ ✓ ✓ ✓


concerns/questions about the verification data. Once edits are VRC and
agreed between VB/Verifier and facility, facility changes its status maybe
from VRC to VRE to allow Verifier access to the assessment for VRE
edits.

23. Verifier reviews facility concerns/questions and edits the ✓ ✓ ✓


assessment as agreed. Verifier changes status to VRC so facility
can review the edits and request further changes if necessary.
Status change from VRC to VRE to VRC can occur as often as VRE then
necessary within the 14 calendar days. On calendar day 15 the VRC
process ends and the assessment changes to VRF, unless the
facility manually changes to VRF before 14 calendar days are
complete. Typically, no earlier than week 8
Typically, no later than week 12
24. Facility changes assessment status to “Verification Finalized" by ✓ ✓
accepting the verification. If facility has any complaint about the
Verifier following procedure or about Verifier conduct, facility VRF or
opens a “Dispute”. If facility takes no action, assessment status VRD
automatically changes to VRF after 14 calendar day review and
edit period ends.

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ACTORS
SLCP
NO. ACTION ESTIMATED TIMELINE1
STATUS
F V VB GW AH VOO

25. In VRF, facility can share the accepted verified assessment via the ✓ ✓ ✓
Gateway and/or the Accredited Host with other users and other VRF
AH platforms

26. If Dispute opened, VOO evaluates the validity of the Dispute and ✓ ✓ ✓
accesses the verified assessment data via the Gateway; facility VRD
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 and
4 calendar days later changes to VRI) VRI or Typically, no later than week 15
OR VRE and Note: VOO evaluates validity of Dispute within 2
VRC working days. If substantiated, VOO attempts to
o VOO returns assessment to Verifier for edits and final facility resolve Dispute within 10 days and gives 4
review (Verifier and facility have 5 calendar days to make edits calendar day notice prior to change to VRI
and review)

28. If Dispute not substantiated, VOO finalizes verified assessment ✓ ✓


and changes status to VRF after 4 calendar day notice to facility; VRF
see point 25 for next steps.

29. Note that in VRF, the VOO can choose to conduct quality ✓ ✓
Typically, no earlier than week 16
assurance procedures for any verified assessment.
Typically, no later than week 22
The 14 days noted in Action 23 are back and forth between
VRI Note duplicate verifications
facility and Verifier before VRF. Once in VRF, the VOO will
conduct sample-based QA activity. The VOO will use the VRQ (a more intensive QA procedure)
data to check on VB quality review processes, but the VOO is not can take 8-10 weeks after VRF to complete
involved in the 14 day back and forth between the facility and the

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ACTORS
SLCP
NO. ACTION ESTIMATED TIMELINE1
STATUS
F V VB GW AH VOO

Verifier.
Outcome of this verification oversight activity may result in
invalidation of a verified assessment.

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2.3. Pre-Onsite Verification


Following is an explanation of each stage of the SLCP pre-onsite verification process. Each stage has a set of mandatory requirements that the VB/Verifier
must follow. These requirements are set out in Section 3 of the SLCP Verification Protocol, and each section below provides a link to the accompanying
requirements.
2.3.1. Account Maintenance on Gateway
As an approved VB, you will be assigned a Gateway account. For more information on SLCP VBs go to slconvergence.org/verifierbodies. To start a VB
application go to the VB Application Page.
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2.3.2. Planning the Verification
The list of SLCP approved VBs available for the specific verification becomes visible on an Accredited Host platform once the facility requests a verification.
Eligibility is based on whether the VB is operating in the country in which the verification will take place and which languages the VB can support through its
Verifiers.
Prior to VB selection, the facility should have had offline conversations with VBs regarding quotes and services. If COVID-19 is a concern, the VB should
reference Annex III to educate facilities 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/email) between the facility and the VB, the facility selects that VB on the
Accredited Host platform.
Please refer to Annex II for more information on how VBs are designated eligible for a specific facility.
The facility initiates and completes the self/joint-assessment. Modules 3 and 7 of the SLCP e-learning explain these actions in detail.
See 3.1.1. Requirements.
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Changes in workforce, processes, operations 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/joint-assessment as a result of COVID-19 or for any
other reason, the VB must advise the facility to review and update the self-assessment.
Closer to the verification, VBs should ensure that the processes on which the facility self-reported will be in operation during the verification (e.g. if certain parts of
what the facility does are not operational, it is recommended that the verification NOT take place; however, it does NOT mean that the verification MUST NOT take
place. Ultimately, it is up to the facility to decide if they want the verification to take place. SLCP recommends that all operations be active to show a full picture, but if
the facility wants the verification with only part of production active, then the Verifier can complete the verification as such. The Verifier must make note of this in the
report in the Verification Details section, at a minimum.
If all parts are in operation, just at decreased capacity, then the verification can take place. The VB/ Verifier can guide the facility to make the best choice by asking
them if they have considered the users of the verified data and if all users would accept the limited operations of the facility.

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2.3.3. Assigning a Verifier
To ensure data integrity and prevent bias, the facility cannot choose the SLCP approved Verifier. Rather, the VB 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.
See 3.1.2. Requirements.
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2.3.4. Assigning Person-days
SLCP has specific requirements for the VB/Verifier when determining the number of person-days needed for an onsite verification, such as the maximum
number of calendar days allowed, involvement of virtual verification activities, defining a person-day, and Verifier selection. Note: Person days are only
related to verification (either onsite or virtual) not scheduling, research, report writing, edits during the 14 day review period, and other activities required
of the Verifier.
See 3.1.3. Requirements.
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2.3.5. Calculating Number of Person-days, Interviews and Documents to Review


When the VB/Verifier determines the number of person-days, interviews and documents necessary to conduct the verification, they must follow the
specific methodology laid out in Table 2. This table clearly explains how many person days, interviews and documents will be needed based on:
• Absence of any virtual verification activity (i.e., no offsite or virtual documents review, interviews, and walkthrough),
• Number of workers in the facility, and
• Specific Step (Step 1, Step 2 or Step 3) the facility completes in the self/joint-assessment. Step to verify must match the self/joint-assessment Step
selected.
For calculation of person-days, interviews and documents to review with virtual verification activity, refer to 5.1.4. Requirements.
See 3.1.4. Requirements.
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2.3.6. Review of Self/Joint-Assessment
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.
At this point, it is likely that the VB has already provided the facility with a cost and person-day estimate for the verification. However, the VB can only
accurately determine how many person-days are needed and if virtual verification activity requested by the facility is actually possible once they have
access to the self/joint-assessment and, with it, any documents the facility attached to the self/joint-assessment.
Depending on how much data there is to verify, the VB/Verifier may change the person-day estimates. For example, a facility that chose Step 2 and
answered Management System questions may only have very few policies in place and will therefore require less time than a facility with more policies to
review. Note: the person-day estimate does not include review of the self/joint-assessment.
See 3.1.5. Requirements.
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2.3.7. Pre-verification Communication to Facility
SCLP provides details on what is required of the Verifier in communicating the verification plan to the facility. Requirements related to this process include
timelines and specifics to be included in the verification plan. Note: the person-day estimate does not include development of the verification plan.

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See 3.1.6. Requirements.


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2.3.8. Download Back-up of Data Collection Tool from AH platform
SLCP recommends downloading the offline Excel Tool in verification mode with the facility self/joint-assessment completed from the Accredited Host
platform. This provides the Verifier with an offline back-up to complete verification data and the Verification Summary in case the Verifier experiences
Internet connectivity issues during the onsite verification and cannot access the AH platform.
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2.4. Onsite Verification


The Verifier verifies all the responses that are applicable to the facility according to the Step chosen in the self/joint-assessment. The Step scope to be
verified must match the self/joint-assessment Step selected. It is therefore important to review the self/joint-assessment Step selection prior to the onsite
verification to ensure the facility and the Verifier have agreed on verification of the correct Step selection. It is also the Verifier’s responsibility to ensure
that all questions have the correct answer, which means that if the facility did not provide a correct answer, or did not provide an answer at all, the Verifier
provides the correct information.
The onsite verification consists of an opening meeting, a workplace walkthrough, worker and management interviews, documentation review, a pre-closing
and a closing meeting. The purpose of the walkthrough and interviews is to observe workplace health and safety practices and verify the implementation of
policies and procedures. The opening and pre-/closing meetings facilitate communication, clarification and transparency between the Verifier and facility.
Refer to Annex VII for tips concerning the onsite walkthrough, and worker and management interviews. Examples of instances for document/photo
attachments are noted in the Verifier Guidance. See Section 3.2. for the SLCP requirements and guidance for the onsite verification process. For general
onsite verification requirements, see 3.2.1. Requirements.
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2.4.1. Opening Meeting Onsite Verification Requirements
An SLCP onsite verification begins with an opening meeting. Whenever possible, the opening meeting should include all parties involved in the SLCP
assessment process: facility management, workers’ representatives and those individuals responsible for managing recruitment, contracts, wages, and
health and safety. The opening meeting involves discussions around verification objectives, scope and methodology. SLCP requirements for the opening

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meeting also include agenda recommendations. See 3.2.2. Requirements.


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2.4.2. Walkthrough Onsite Verification Requirements
The Verifier performs a walkthrough of the entire facility/workplace to observe facility practices. Throughout the verification, the Verifier informs facility
management about any inaccuracies, notable verification data entries and any legal non-compliances.
See 3.2.3. Requirements.
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2.4.3. Worker and Management Interviews Onsite Verification Requirements
The Verifier interviews a sample of workers and all management staff responsible for social and labor activities/ policies/procedures at the facility. See
3.1.4. Requirements for calculating number of worker interviews.
See 3.2.4. Requirements.
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2.4.4. Document Review Onsite Verification Requirements
The Verifier conducts document review of policies and procedures as well as records such as wages and working hours, employment records, formal
complaints, etc. See 3.1.4. Requirements for calculating number of wage, hours and personnel records to review.
See 3.2.5. Requirements.
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2.4.5. Document and Photo Attachment Onsite Verification Requirements
When there is documentation or photographs that can be attached as evidence/ information alongside the applicable question, the Verifier will attach the
files via the Accredited Host platform.
See 3.2.6. Requirements.
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2.4.6. Pre-closing Meeting Onsite Verification Requirements


This provides the Verifier time to complete the Verification Summary. Depending on the scope/breadth of inaccuracies and non-compliances, the Verifier
may not have had time to complete all “Inaccurate”, “Non-Compliance” (for Verification Summary) and “Updated during Verification” items needed to
prepare for the closing meeting. The Verifier takes this time to complete as many of the entries that will allow the Verifier to have a productive closing
meeting with the help of the Verification Summary.
See 3.2.7. Requirements.
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2.4.7. Closing Meeting Onsite Verification Requirements
The closing meeting should include the same individuals who were present during the opening meeting. During this 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 the facility can
understand how to better complete the Data Collection Tool the next time. SLCP requirements for the closing meeting also include agenda
recommendations.
See 3.2.8. Requirements.
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2.5. Post-onsite Verification


2.5.1. Resolving Facility Concerns
The VB/Verifier may have to address facility concerns about the verified data. SLCP has specific processes and requirements for the VB/Verifier when
following up with the facility on any issues raised.
See 3.3.1. Requirements.
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2.5.2. Report Writing
The Verifier/VB 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

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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 VB when it runs mandatory quality checks. Note: report writing time is not included in the number of person-days
required for verification of the facility. Person days are only related to verification (either onsite or virtual) not scheduling, research, report writing, edits
during the 14 day review period, or any other activities required of Verifier
More information about how to complete the Tool and tips on quality review are in the Verifier Guidance.
Focus on “Verification Data” Narrative
SLCP data has to be clear, applicable to the question at hand, and factual, so that multiple users can easily adopt the data and apply their own standards.
Even though SLCP verified data is standard agnostic, we still need to provide the necessary data for standard holders and brands with codes of conduct to
assess compliance and inform remediation activity/corrective action plans.
This means, it is the responsibility of the Verifier to produce a detailed explanation in “Verification Data” so that the user of the verified assessment report
has the necessary information to make an informed decision, including, e.g., grading/ ranking/ passing/ failing/ certifying a facility and/or providing the
facility with a Corrective Action Plan.
Based on the Verifier’s experience in social auditing, the Verifier may identify a response that, whether “inaccurate” or “accurate”, is in violation of an
industry standard or code of conduct. For the user of the report to properly inform remediation efforts, “Verification Data” needs to include explicit details
of the facility’s circumstance; details that are clear, applicable to the question at hand, and factual.
The “Verification Data” narrative is an extremely important element of the verification process and Verifiers need to understand what is expected from
them when completing this information. The requirements for “Verification Data” Narrative are outlined in 3.3.3. Requirements. Make sure to read the
Guidance which explains how to approach each verification selection.
See 3.3.3. Requirements.

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“More info” is a valuable resource, and we recommend referencing this information anytime anything seems unclear.
Examples of the types of explanatory information provided in “More info” include:
• Calculation methods for measurement or distance questions
• Legal compliance questions
• Distinctions for clarity across similar questions
• Details on types of programs (e.g. financing programs)
• Appropriate answers based on specific scenario (e.g. if the facility provides a weekly rest day, but not for 20 consecutive hours, answer “No”)
• Definition/explanation of terms
• The overall intent of the question.

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2.5.3. VB Quality Check
The VB is responsible for conducting an internal quality check and ensuring the Verifier’s quality of work is in accordance with the Verification Protocol
Requirements and provided Verifier Guidance.
Failures in the VB Quality Check process may be discovered when the Verifier changes the status from VRP to VRC, which triggers the status of VRQ. If
quality failures are present the status of the assessment goes to VRE. It is the responsibility of the Verifier to ensure all quality issues are resolved prior to
(re-)submitting to status VRC.
See 3.4.1. Requirements.
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2.5.4. VB Document Retention
VBs must follow local legal requirements relating to the minimum retention of notes, documents, photographs and/or client files. SLCP requires at
least 12 months of retention to facilitate any Dispute or quality assurance procedures.
Note: as the Verifier and VB do not have access to the finalized verified assessment report (status VRF), Verifiers should save a copy of the report

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(likely the offline Excel version) for their records prior to changing the status to “Verification Completed”. VBs 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.
See 3.4.2. Requirements.
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2.5.5. Facility Reviews Verified Assessment Report
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.
The facility can review the verified assessment report by accessing it online or downloading it as an offline Excel from the Accredited Host platform. The
facility then has 14 calendar days to review the report and request edits from the Verifier/VB, as necessary.
See 3.3.2. Requirements.
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2.5.6. Facility Responds After Review of the Verified Assessment Report
The facility has 14 calendar days to review the verified assessment report and ensure the report is correct and of high quality. During this time, the facility
can:
• Accept the verified assessment report on the Accredited Host platform, which changes the assessment status from “Verification Completed” to
“Verification Finalized”
• 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
• Reach out to the Verifier/ VB for clarifications, concerns (e.g. quality of report), questions about the verified assessment report, especially with
regards to verification data issues (Verification Selection, Corrected Response, Verification Data, Non-Compliance, Legal Reference) that do not
relate to Verifier following the Protocol or Verifier conduct
• Change the status from “Verification Completed” to “Verification being Edited” if the facility and Verifier/ VB 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”.
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2.5.7. Raising a Dispute


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. The only information available is that the facility has an invalidated report and the reason the report was invalidated.
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2.5.8. Facility Shares Verified Assessment via the Gateway and/or the Accredited Host
Once the facility has accepted the verified assessment report, it can then share the report via the Accredited Host site and/or Gateway.
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2.6. In line with legal requirements


2.6.1. Identifying and citing when facility is not in line with legal requirements
SLCP does not come to any conclusions on compliance with any brand’s code of conduct or any certification standard. However, this does not mean that the
Tool is completely void of reference to any type of standard. SLCP actually requires the facility and Verifier to reference applicable legal requirements when
answering questions. For the Verifier this applies to all questions outside of the Facility Profile section.
Any incidence of Non-Compliance (no matter the Verification Selection or Corrected Response) will be reflected in the Verification Summary for easy
reference.

2.6.2. Tool meaning of “Consult applicable legal requirements”


This Tool is aligned with international labor standards and national laws.
Any time a question references the law (e.g. "in line with legal requirements", "legally required"), the facility (and Verifier) must consult applicable legal
requirements to assess the answer (verified answer) to the question. “More Info” provides instructions on what to do if there are no applicable legal
requirements.

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Applicable legal requirements include:


• The ILO Core Conventions in force in the country in question
o The ILO Core Conventions provide the baseline for determining compliance with the fundamental rights at work:
▪ Child Labour (C138 Minimum Age Convention, 1973 and C182 Worst Forms of Child Labour Convention, 1999)
▪ Discrimination (C100 Equal Remuneration Convention, 1951 and C111 Discrimination (Employment and Occupation) Convention,
1958)
▪ Forced Labour (C29 Forced Labour Convention, 1930 (and Protocol) and C105 Abolition of Forced Labour Convention, 1957)
▪ Freedom of Association and Collective Bargaining (C87 Freedom of Association and Protection of the Right to Organize Convention,
1948 and C98 Right to Organize and Collective Bargaining Convention 1949
• Other conventions in force in the country in question
• Laws and regulations that apply in the jurisdiction in question
• Collective Bargaining Agreements
o Where the provision in question is at least as favorable for workers as relevant legal requirements
Applicable legal requirements are set out in the “Law Overlay” for select countries.
If applicable legislation does not cover or sufficiently address an issue regarding compensation, contracts, occupational safety and health or working time,
other benchmarks based on international standards and good practices may be used, where these are derived from international instruments, or materials
developed within the ILO and in consultation with tripartite constituents.
NOTE: If not required by law but the facility still addresses a specific issue (e.g. time off for breastfeeding), the Verifier selects “No applicable requirements”
and notes down in Verification Data that the facility addresses the issue regardless of the absence of legal requirements.
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2.7. Law Guidance and Law Overlay


2.7.1. Data Collection Tool “Law Guidance” and Automated Entry of Non-Compliance and Legal Reference
Law Guidance will be provided by ILO-Better Work for select countries and only for Step 1 scope. Information on country-specific laws will be attached to
each applicable question in Step 1 on the Accredited Host platform. Similar to More Info, the facility and Verifier will have access to country-specific Law
Guidance on the Accredited Host platform.
For offline use, facilities and Verifiers will have access to an Excel document that contains, in a flat file, all applicable law guidance by country and by Tool
question.
Note, there is Law Guidance in the offline Excel Tool, but it is only contained in the Section Instructions and Sub-Section Instructions and only references
international labor standards, i.e. it is not country specific.
Law Guidance informs the SLCP Law Overlay. If the Final Verified Response determined by the Verifier results in a Non-Compliance, and ILO-Better Work has
provided Law Guidance to SLCP for that specific country in which the verification is taking place, then the automatic Law Overlay will be implemented on
the Accredited Host platform.
• Final Verified Response means the facility response if the Verification Selection is “Accurate” or it is the Verifier’s Corrected Response or Verification
Data entry.
• Automatic Law Overlay means upon determination of the Final Verified Response, the Accredited Host will automatically complete the Non-
Compliance “X” and the Legal Reference narrative as per ILO-Better Work provided Law Guidance information. For Step 1 questions with Law
Guidance, the Verifier no longer has to determine whether a specific facility circumstance is not in compliance with applicable legal requirements.
The system will automatically do it for them. This feature increases report quality through standard application of non-compliances and legal
references.
Remember, Law Guidance is not included for all countries and all questions. There may also be non-compliances to applicable laws in Step 1 that are not
included in the Law Overlay. It is still the Verifier’s responsibility to ensure all non-compliances with applicable legal requirements are identified in the
verified assessment report.
The Verifier can override the automatic completion on Non-Compliance and Legal Reference, though it is highly unlikely that the Verifier will need to do so.
If the Verifier overrides the automatic completion, this special circumstance (that would usually result in a non-compliance but in this special facility case
does not) must be explained in Verification Data.
See also our Helpdesk for more information.

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2.8. Quality Assurance


2.8.1. 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.
Timelines:
• Reports for Desktop Review are selected within 10 working days of an assessment changing to VRF.
• The VOO completes Desktop Review within another 10 working days.
• Sites for Counter and Duplicate 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 only information that will be available is that the facility has an invalidated
report along with the reason the report was invalidated.
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2.8.2. Verifier Feedback
The VOO provides VBs with feedback in any instances where a QA activity shows a Verifier has "less than average" performance. While there is no report
detailing the specifics, the feedback should be enough for the VB to address any gaps and improve the Verifier's performance.
– Example: Recent reports received a low-quality score because the Verifier(s) did not properly address questions that were not answered by the
facility. If a facility does not respond to a question, it is the Verifier's responsibility to answer the question by choosing a "Corrected Response". The
Verification Data entered must support the Verifier's Corrected Response by describing the types of evidence they reviewed.

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The scope of the VOO


The purpose of the VOO is to ensure quality of the SLCP verification process and the verified data resulting from that process. Quality means the
verification process is consistent and verification data is reliable. The VOO uses a variety of QA methods to detect issues with the verification process
and identify data reliability issues. QA outcomes are used to determine how to improve the SLCP system. QA is a dynamic process – activities vary based
on actual operations and QA learnings inform the ongoing QA approach.
It is not the VOO’s role to ensure each and every verified assessment report is free of errors. As the owner of the report, the facility has the opportunity
and responsibility to review the verified assessment report and inform the Verifier/ VB and/or VOO of any quality deficiencies. Rather, through targeted
QA activities, the VOO can detect overall quality issues with the verification process or report outcomes and address these deficiencies with targeted
interventions and system improvements.
If a user of the verified assessment report would like to better understand how a Verifier approached a specific topic, or to inquire about further
verification details (on top of already sufficient and good quality data), the user needs to reach out to the facility, or ask the facility to facilitate contact
with the applicable VB for further information. The facility owns the data and thus provides the permission to access that data, especially if the data
goes beyond what is already contained in the verified assessment report.
If a user wants to share information about the quality of a specific verified assessment report, they can provide their feedback through the feedback
form or if they have questions about the report which cannot be answered by the facility or the VB (with permission by the facility) they can contact the
support desk.

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SLCP Verification Requirements

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3. SLCP Verification Requirements


These requirements are mandatory for Verifier Bodies and Verifiers. Guidance is provided for each requirement along with examples of potential scenarios
and how to handle them. The guidance is a critical component of the requirements and therefore should be read. Some requirements are also accompanied
with recommendations and/or references to provide further support throughout the verification process.

3.0. General Requirement


If the Verifier/ Verifier Body cannot adhere to the requirements listed in this Protocol (all requirements including Section 3. and Section 5.) the Verifier/
Verifier Body must submit an Exception Request to the Verification Oversight Organization.

3.1. Pre-onsite Verification

3.1.1. Requirements for Planning the Verification

Requirements Guidance Recommendations

3.1.1.1. Verification must happen within • The date the Verifier must reference to determine completion of the SLCP recommends scheduling the
2 months of completion of the self/joint- self/joint-assessment is in the Data Collection Tool, Facility Profile question verification at a time where at least 80% of
assessment FP-BAS-26 Date of self/ or joint-assessment submission (YYYY-MM-DD). the workforce is active, i.e. to avoid
Should the facility/VB miss this timeframe for verification, the facility must scheduling the verification during very low
contact SLCP through the Helpdesk to change the status of the assessment volume or holiday seasons.
back to ASI-Assessment Initiated so the facility can update the self/joint-
assessment and question FP-BAS-26.

3.1.1.2. VB must confirm if any major If changes in workforce are temporary, then furloughed workers must also be
changes to the workforce are permanent considered when determining the amount of onsite time.
(e.g. terminations) or temporary (e.g.
• Onsite time is based on the facility’s current workforce (workforce at the
furloughs) so as to determine onsite-
time of onsite verification). Changes to the workforce due to COVID-19 may
time needed for verification
impact the amount of time VBs spend on site.
• The Verifier confirms major changes to the workforce during scheduling and
also when onsite if prior information was not available.

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3.1.1.3. The facility must determine the • Verification must be announced or semi-announced within a 10-day
type of announcement. window.
– If the facility wants to speed the process up and start verification
earlier than 10 days, this is at the discretion of the Verifier/ VB, and
the Verifier/ VB can shorten the timeframe for self/joint-assessment
review. But the Verifier must still adhere to Protocol requirements,
i.e., review self/joint-assessment, submit verification plan, etc. Since
some mandatory timeframe requirements may not be adhered to
(e.g. verification plan submission no less than 5 working days prior to
verification) the VB/ Verifier must file an Exception Request
whenever a Protocol requirement is not adhered to.
• 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 VB must consider local/national holidays as well as any
specific dates or date ranges that the facility will be unavailable for
verification.

3.1.1.4. The facility and the VB must • The onsite verification must take place over consecutive days. The Verifier
agree on and have a documented cannot start the onsite verification and then stop for a day or two before
agreement outlining the specified date continuing. Once the verification begins, it must continue each following
or date range for onsite verification day until complete.
• The documented agreement between facility and VB must be agreed and
signed prior to verification taking place.

3.1.1.5. If the VB is asked by another • To facilitate communications and expectations around verification Please refer to the Verification Observation
organization to shadow or observe the observations/ shadowing by parties other than the VOO, SLCP has created a Requirements on our Helpdesk.
upcoming verification, the VB and process that must be followed.
Verifier must follow the Verification
Observation Requirements

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3.1.2. Requirements for Assigning a Verifier

Requirements Guidance Recommendations / References

3.1.2.1. The VB must ensure all rules for The Gateway provides some filtering to ensure some rules are enforced for
Verifier selection are enforced Verifier selection but ultimately the responsibility lies with the VB.
VBs can also access the Helpdesk FAQs to obtain more instructions on how to
use the Gateway.

3.1.2.2. The VB must follow verification See Table 2 for person-day minimum requirements for onsite verification
person-day minimum requirements and without any virtual/ desktop verification activity.
must assign more than one Verifier
accordingly

3.1.2.3. The VB must comply with the • Verifiers are only eligible for a specific verification if: SLCP recommends that:
rules of eligibility
– The Verifier did not verify the facility’s previous assessment (this rule • Verifier gender is appropriate for the
applies even if a facility has moved locations) facility circumstances
– The VB is not involved in the self/joint-assessment that is now • Verifier gender is different from
undergoing verification previous assessment, if such switch in
gender will facilitate gathering of
• Verifiers must meet these requirements:
different perspectives during the
– Must not have verified the facility’s last self/joint-assessment present verification
– Must not have had any involvement with current self/joint-assessment • Additional Verifiers are eligible to
verify in the country of verification
– One Verifier (if team) must be eligible to verify in the country where
according to VOO qualification
the facility is located
• Any additional Verifiers speak at least
– One Verifier (if team) must speak at least one of the worker languages
one of the worker languages.
• Refer to Annex II for more information on how VBs and Verifiers are
designated eligible for a specific facility.

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3.1.3. Requirements for Assigning Person-days

Requirements Guidance

3.1.3.1. The number of calendar days for onsite • The 4 consecutive working day maximum allowance for onsite verification can only be exceeded if the
verification must not exceed 4 consecutive working facility provides written permission.
days
• If the number of calendar days exceeds 4 consecutive working days, the VB must send more than one
Verifier.

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

3.1.3.3. Person-day requirements may only be • For information on possible reduction in person-days see 5.1.4. Requirements
decreased if virtual verification activity takes place and
• Step 1 person-day listing in Table 2 is a minimum requirement for onsite verification and must be
in accordance with virtual verification requirements
followed.
• If the facility chooses more than Step 1 (i.e. Step 2 or Step 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 workers,
Step 1 minimum is 1 person-day, Step 2 minimum is 1.5 person-days, Step 3 minimum is also 1.5 person-
days.

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3.1.4. Requirements for Calculating Number of Person-days, Interviews and Documents to Review

Requirements Guidance Recommendations / References

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3.1.4.1. VB and Verifiers must follow Table Table 2: • Step 2 and Step 3 person-day listings in Table 2 are
2 (below) in calculating on-site person suggested timeframes as the scope of verification
• Workers in this context means the workers who are within
days, number of interviews and the can drastically differ from one facility to another in
scope of the SLCP assessment. These are workers (individuals
sample of documents to review for onsite the sections of Management Systems and Above
working on/with the facility's product or directly involved in
verification and Beyond
the operations of the facility). They are non-supervisory.
Which means, no one reports to them. • SLCP recommends that the VB adds additional
onsite time if any of the following conditions apply:
• Time estimate for interviews: 15 minutes per individual
interview, 30 minutes per group of 4-6. Group interviews – Facilities have migrant workers and/ or languages
are in addition to individual interviews. E.g. 1-100 workers need to be supported to conduct interviews
total 12-14 workers must be interviewed.
– Facilities have specialized operations with
• Exceptions to the person day-requirements or other additional health and safety hazards, such as
requirements in the Verification Protocol may be made by vehicle fleets, water reservoirs or large quantities
the VOO. Exceptions can be requested by completing an of hazardous material
Exception Request form.
– Facilities have large compounds, or more than one
location associated with the business license.

3.1.4.2. If more than one Verifier is • Not all Verifiers need to be present every day of the onsite
present and Verifiers were not present verification, however details about who was present on
each day, Verifier must note in which day needs to be entered in the Verification Details
Verification Details the name of Verifier section of the report
present on which day

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Table 2: Determining minimum person-days, number of interviews and sample of document review
Any step in addition to step 1 requires a minimum
Minimum 0.5 person-day more time than the “Minimum
requirement requirement”. Below are suggested total person
days.

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Individual Number of Person-Days Person-Days Person-Days


Number of
Worker Group Worker Personnel Files Wage & Hours Records
Workers (Step 1) (Step 2) (Step 3)
Interviews Interviews

1 - 100 8 1 12-14^ 10 x set of 3 = 30 1 1.5 2

101-200 12 2 20-24^ 20 x set of 3 = 60 1.5 2 2.5

201 - 500 15 3 27-33^ 27 x set of 3 = 81 2 2.5 3

501 - 1000 20 4 36-44^ 40 x set of 3 = 120 3 3.5 4

1001+ 28 6 52-64^ 55 x set of 3 = 165 4 4.5** 5**

^ Range applicable, as group interviews are one group of 4-6 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 and
the Verifier receives approval from the VOO via the Exception Request Form).
Note: Person days can be reduced in increments of 0.5 person-days if virtual activity is conducted, see Table 4
Report writing time and other activities around the actual verification event are not included in the person-days (e.g., self/joint-assessment review, verification plan
completion, background research, etc.).
Important: If going above Step 1, the minimum for Step 2 AND 3 is 0.5 day more. That means Step 2 suggested person-days are the minimum for both Step 2 and 3.
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Increasing the number of person-days needed for verification


SLCP does not prevent the Verifier from increasing the number of person-days from the minimum requirement shown in Table 2. If the VB knows that the minimum
requirement is not enough to be able to complete all Protocol required tasks, then the VB should add more days. This can be done from the beginning (at scheduling) or also
if the Verifier is encountering difficulties during the onsite.
If the VB/ Verifier needs more time for verification, it should be discussed with the facility. The Verifier should explain to the facility that it is in the facility's best interest for
the Verifier to have ALL the facts to ensure accuracy of the verified assessment report. Moreover, the verified assessment report can always include the facility's perspective
and response to a specific situation. Consequently, gathering all this additional info may take more time.
Note: The maximum number of calendar days permitted for onsite verification is 4 days. If the VB finds that more time is needed, then more Verifiers can be added to the
verification to ensure verification remains within the 4-day limit or the VB/ Verifier can file an Exception Request.

Worker interviews
Verifiers can always interview more personnel and other personnel other than "workers"; however, this is not part of the minimum requirement for
interviews. For example, persons in a supervisory function or in a service role (e.g. canteen, cleaner) are not considered "workers" and do not count toward
the number of required "worker" interviews.
Example: If the Verifier is conducting interviews in a facility of 50 workers, Table 2 indicates that there must be 8 individual worker interviews. If the
Verifier decides to interview a team leader, the Verifier may do so, but then the Verifier would be conducting 9 interviews in total (8 worker interviews
and one supervisor interview).

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3.1.5. Requirements for Review of Self/Joint Assessment

Requirements Guidance

3.1.5.1. The Verifier must study • Preparation will also help with creation of the facility-specific verification plan, see Requirement 3.1.6.2
the self/joint-assessment
• The Verifier will gain an understanding of the facility’s management systems (e.g. management personnel onsite, scope of
completed by the facility to
documentation, physical premises of the facility), as well as potential risk areas (e.g. migrant labor, dormitories and hazardous
prepare for the onsite verification
operations).

3.1.5.2. Verifier must ensure the • Based on the preliminary offline conversations between the facility and the VB regarding quotes and services, the VB needs to
Steps (1, 2 or 3) the facility has ensure that the scope agreed upon (Step 1, 2 or 3) is what has been completed in the self/joint-assessment.
included in the self/joint-
• If there is any discrepancy, the Verifier must reach out to the facility to discuss any adjustments needed either to the
assessment match the verification
self/joint-assessment or to cost/timeline of verification.
scope negotiated between the VB
and the facility

3.1.5.3. Verifier must ensure the • Verification can only take place if the facility has provided at a minimum 3 months of operation/3 months of self-assessed
self/joint-assessment contains at data.
minimum 3 months of operation/3
• This must be verified prior to the verification process beginning.
months of self-assessed data

3.1.5.4. Verifier must review • It is in the VB’s/Verifier’s interest to ensure all facility responses are in English, because if the facility’s responses are not in
self/joint-assessment answers to English, the Verifier will have to provide the English response in Verification Data for users to understand the final verified
ensure only English was used for response. This means the Verifier is spending time translating the facility responses.
facility responses (unless the
• Accredited Host checks are required to detect non-English language and direct the facility to update the response to English.
question explicitly asks for local
However, technical failures can occur. If the self/joint-assessment contains non-English responses, the Verifier should direct
language)
the facility to reopen the assessment (change back to ASI – Assessment Initiated by contacting the SLCP Helpdesk) and update
the responses.
• There are only two questions that ask for local language responses, if applicable.

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3.1.5.5. VB and Verifier must obtain • Employment laws include minimum wage, working hours and social benefits that pertain to the facility location
relevant social and labor
• International Labour Organization (ILO) conventions pertaining specifically to the eight ILO Fundamental Conventions:
information related to specific
conditions within the country and – Freedom of Association and Protection of the Right to Organise Convention, 1948 (No. 87)
region of SLCP verifications
– Right to Organise and Collective Bargaining Convention, 1949 (No. 98)
– Forced Labour Convention, 1930 (No. 29) (and its 2014 Protocol )
– Abolition of Forced Labour Convention, 1957 (No. 105)
– Minimum Age Convention, 1973 (No. 138)
– Worst Forms of Child Labour Convention, 1999 (No. 182)
– Equal Remuneration Convention, 1951 (No. 100)
– Discrimination (Employment and Occupation) Convention, 1958 (No. 111)
• Further resources provided by the ILO for labor law are: Industrial Relations Database and Working Conditions Laws Database.

3.1.5.6. The VB must conduct a • The background check must include at a minimum:
background check of the facility
– 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)
– Worker demographics (e.g. migrant workers, young workers as well as any possible language challenges)
– The type of laws that apply to the particular facility
• The Verifier may also request previous social audit reports or the previous SLCP verified assessment report to obtain facility-
specific information; however, the facility is not obligated to share this information with Verifiers
• The Verifier should be aware of potential bias that can develop with review of previous reports.

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3.1.6. Requirements for Pre-verification Communication to Facility

Requirements Guidance Recommendations / References

3.1.6.1 Verifier/VB must • Verification information must include: SLCP has created a template (see Annex IV) that can
communicate specific be used to communicate the verification
– The number of person-days and calendar days required to complete the
verification information to the information
verification
facility no later than 10 working
More information about SLCP
days prior to the date of start of – Reminder of how the facility must include information on COVID-19 in
and its process: https://slconvergence.org/helpdesk
verification activity (onsite or the self/joint-assessment (use Annex III)
virtual activity) The SLCP Code of Conduct (see Annex VI)
– Document list – customized based on country of verification (a non-
customized, basic document list is provided in Annex V to help initiate SLCP QA Manual, which explains the Dispute Process
the process) and how reports may be invalidated:
https://slcp.zendesk.com/hc/en-
– The expectation that onsite verification requires access to all areas of
us/articles/360014823394-Quality-Assurance-Manual
the facility and its grounds, photographs (respecting and avoiding
proprietary information) and confidential interviews between the
Verifier and workers and management
– A statement on the need for senior management and workers’
representatives to be present at the opening and closing meeting
– Contact details for Verifiers/VB in case facility needs a local contact
(telephone number and email)
– 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 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.

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Additional fees may apply depending on the scope of work to be


completed post verification.
• Prior to VB selection, the VB does not have access to the self/joint-
assessment data. When providing quotes to the facility at that time, the
VB will request facility data, such as, location, number of workers and
languages spoken to estimate the onsite verification duration. The
verification duration can only be estimated until the VB has access to the
self/joint-assessment data. Once the self/joint-assessment is shared, the
VB can properly assess verification requirements and include them in the
verification information required 10 working days before verification
starts.

3.1.6.2 The Verifier/VB must The verification plan must outline the daily verification details including, at a See the Verifier Guidance for a verification plan
send a verification plan no less minimum: sample.
than five working days prior to
– The specific calendar days onsite (or number of days if verification is
the scheduled verification
semi-announced)
– The hours of verification (start and finish for each day)
– 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)
– The minimum number of interviews that have to be conducted
– The minimum number of wage/hour/personnel records that have to be
reviewed
– The document request list (even if virtual/desktop review of documents
occurred and/ or if the facility attached the documents to the self/joint-
assessment).

3.1.6.3 During the scheduling • If the facility has experienced a change of 50% or more of their workforce • Closer to the verification, VBs should ensure that
process, the VB must discuss since the date of completion of their self/joint-assessment, the VB must the processes the facility self-reported on will be
with the facility any changes in advise the facility to review and update the self-assessment. in operation during the verification (e.g. if certain

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their workforce due to COVID- Note: that if the workforce has changed considerably, there may be parts of what the facility does are not operational,
19 or other exceptional multiple questions that need to be updated by the facility, not just worker the verification should not take place)
circumstances demographic information
• Prior to travelling to the verification site, VB
should check for any health and safety or travel
restrictions put in place by local governments.
Additionally, VB 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)

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3.2. Onsite Verification

3.2.1. General Onsite Verification Requirements

Requirements Guidance Recommendations / References

3.2.1.1. Verifier must verify all “All data” means all questions that are applicable to the facility according to the Step See Verifier Guidance for more
data chosen in the self/joint-assessment: details
– Recruitment and Hiring (Step 1)
– Working Hours (Step 1)
– Wages and Benefits (Step 1)
– Worker Treatment (Step 1)
– Worker Involvement (Step 1)
– Health and Safety (Step 1)

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– Termination (Step 1)
– Management Systems (Step 2)
– Above and Beyond (Step 3)
• 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 verification information to these unanswered questions.

3.2.1.2. The timeframe of the • This timeframe is referred to as the assessment period.
verification data must be based
• The only exception to this is when filling in the Facility Profile. When the Verifier
on the same previous 12 months
arrives onsite the Facility Profile circumstances may be different from what they
from the date that the self/joint-
were during the self/joint-assessment. For Facility Profile information, the Verifier
assessment is completed by the
must include the most up-to-date/current information as of the date of the onsite
facility
verification, 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.
• For all other questions, the assessment period includes the 12 months prior to the
submission date of the self/joint-assessment (FP-BAS-26 Date of self/ or joint-
assessment submission (YYYY-MM-DD)).
• 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.

3.2.1.3. Each verification must • The physical scope reported is tied to the facility’s business license and Please reference a detailed table on
cover the area as defined by the operations permitted therein. Should the actual physical scope greatly differ our Helpdesk for facilities, Verifier/
facility in the Facility Profile of from the self-assessed/ facility-reported physical scope and the Verifier VB and users of the verified
the self/joint-assessment and all decides the scheduled verification timeframe is not enough to complete a assessment to understand the
operations included therein verification of the actual physical scope, the Verifier may extend the

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verification person-days or reschedule the verification. relationship between Facility Profile,


assessment and verification.
• If the facility has multiple business licenses but only one address, the Verifier
need only conduct one verification as it is still considered to be only one
facility as per the facility profile created on the Gateway.

3.2.1.4. Any verification activity • This applies to all data including:


must be in compliance with any
– Employee files and data for review and retention of such data/information
applicable data privacy laws and
regulations – Narrative and attached photos/documents (photos must not contain
employee names or any personally identifiable information for reasons of
confidentiality and privacy).

3.2.1.5. Verifiers must include all • New hire, under probation, under age 18, union/ worker representative, pregnant, In the event that Verifiers suspect
applicable types of “workers” in returning from maternity leave, foreign migrants, domestic migrants, other potential issues among workers in the
the verification vulnerable groups or minorities facility, Verifiers should also check
third-party service providers not
• Part-time, fixed term, short-term (a person with a labor contract of limited or directly working on the product and
unspecified duration with no guarantee of continuation), temporary (e.g. labor therefore not included in the worker
supplied by a third-party employment agency). scope for the purposes of SLCP. These
workers are non-production workers.
They may shed more light on the
situation. Examples of such workers
are those working in food service,
security, childcare, and custodial.

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

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workers are affected by various


situations
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3.2.2. Opening Meeting Onsite Verification Requirements

Requirements Guidance Agenda recommendations

3.2.2.1 The onsite verification • To the extent possible, the opening meeting includes facility management, • Introduction of the verification team and
must start with an opening workers’ representatives and those individuals responsible for managing facility management personnel
meeting recruitment, contracts, wages, and health and safety to discuss verification
• Reviewing the scope and activities of
objectives, scope, and methodology.
verification
• Verifiers must encourage the facility to be open and transparent during the
• Reviewing a facility floor plan to ensure that all
SLCP process.
appropriate areas are part of the walk-through
activity. Facility should advise whether
3.2.2.2 Authorization to take • Data integrity is key to the success of SLCP. Data collection and verification
Verifiers need PPE or a safety orientation to
pictures must be requested should reflect actual labor conditions.
mitigate any health and safety risks
• The Verifier will observe facility restrictions and not photograph sensitive
• Clarifying that the verification goal is to check
(i.e., proprietary) products, materials or processes. If photo authorization is
that the assessment was completed correctly,
completely denied, the Verifier will note the denial in the verified
to validate the accuracy of the data provided
assessment report. Should the facility refuse the Verifier’s request to take
and to highlight any inaccurate data or
photos and yet agree to take photos themselves on behalf of the Verifier,
circumstances of not following legal
this must be noted in the report along with any incidences where the Verifier
requirements
did not receive pictures they requested.
• Data, including potentially confidential data,
3.2.2.3 Verifier must inform • The Verifier communicates to management that all worker interviews are will be gathered during the verification. Data
management that the Verifier confidential, and that the employer is prohibited from taking retaliatory that can be linked back to a specific individual/
selects the workers to interview action against those who are interviewed. worker will be kept confidential and none will
be shared outside the verification team with
3.2.2.4 If applicable, Verifiers • The Verifier requests that each union put forward a group of worker level one exception: data can be made available to
must inform management that union members/ representatives. the SLCP VOO for quality review or
they wish to interview the head

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of the union(s) and worker • If the facility management does not agree to the participation of workers investigation into the work of the Verifiers
representative(s) and/or their representatives in interviews, the Verifier must cancel the
• Description of the report methodology and
verification as information cannot be verified.
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.

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3.2.3. Walkthrough Onsite Verification Requirements

Requirements Guidance

3.2.3.1. Verifier must take time Refer to Annex VII for tips on the onsite walkthrough.
to first look at the ‘big picture’
Recommended items to look out for to understand the ‘big picture’:
before focusing in on the detail
• People being ushered out of the workplace (e.g. children, or those without contracts) 

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

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

• PPE being hastily put on
• 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).

3.2.3.2 Verifier must inform the Throughout the verification, the Verifier informs facility management about any inaccuracies, notable verification data entries and
facility about any inaccuracies any non-compliances to applicable legal requirements. This will help the Verifier in conducting the closing meeting at the end of
during the verification 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.

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3.2.3.3 Verifier must follow any • Facility should advise whether Verifiers need PPE or a safety orientation to mitigate any health and safety risks
applicable facility H&S protocols
• Verifiers are expected to practice good hygiene and to respect any special facility H&S rules, e.g. social distancing when
conducting verifications.

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3.2.4. Worker and Management Interview Onsite Verification Requirements

Worker Interview Requirements Guidance

3.2.4.1. Verifier must meet or • Sample size for onsite verifications without virtual verification activity is based on Table 2
exceed the minimum number of
• Verifier decides, based on real-time information at the facility, how to compose or expand the sample to achieve the best
interviews
quality possible
• The Verifier and not the facility selects the workers 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.

3.2.4.2. Verifier must interview a The Verifier must consider both the types of contracts and types of people in the workforce. See Annex VII for more
representative sample of workers information.

3.2.4.3. Verifier must interview • This helps the Verifier explore their view of working conditions, management attitude as well as any specific issues.
the trade union and/or worker
• If there are union/worker representatives serving in committees, they must also be included in the interviews.
representative (if applicable to
the facility) • 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.

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3.2.4.4. Worker interviews are • Verifiers must ensure that problems raised by workers are discussed with management in a way so as to not identify the
strictly confidential and worker who raised the problem.
subsequent reports will not
• Verifiers must never provide specific names, identification numbers or other obvious indicators of workers to facility
identify the names of
management or within the assessment report (e.g., if there is only one worker in a specific section and that section is cited in
interviewees nor their individual
the report).
responses
• Verifiers may keep a confidential record of those with whom they have had interviews if VB policy requires.
• Interviews must take place away from management and supervisors in a room or space where interviewees feel comfortable
sharing sensitive information.

3.2.4.5. Interviews must take • This may involve the use of interpreters. SLCP is committed to the principle of being able to communicate with any person at
place in a language understood the facility. This can be challenging at sites with multiple languages.
by workers either with additional
• Information about languages is in the Facility Profile, but for scheduling purposes, the VB will have to inquire about the
Verifiers or onsite interpreters
languages prior to receiving the self/joint-assessment.
• The Tool asks for primary, secondary and third most prevalent language spoken by workers, as well as the primary language
spoken by facility management.

3.2.4.6. The verification team • The Tool asks for primary, secondary and third most prevalent language spoken by workers, as well as the primary language
must be able to support at least spoken by facility management.
the top two languages spoken by
• If 100% of the facility (workers and management) speaks one language/ can comfortably communicate and answer interview
workers and the primary
questions in one language then Verifier need only to speak this language.
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
VB 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.

3.2.4.7. Interpreters must be • It is recommended that Verifiers can support language requirements and interpreters should only be used in exceptional cases.
independent of the facility and Verifier eligibility is based, in part, on country presence so, in essence, interpreters should not be necessary.
trained to understand social
compliance topics

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• If the Verifier(s) cannot support the language requirements, the VB may use professional translation/ interpreter services.
Interpreters must be present on site. It is required to use interpreters who are trained to understand social compliance topics
to allow for a thorough, accurate and trusted communication.
• The Verifier/ VB should make clear in the verification plan the reason for using an interpreter
• Finding and contracting an interpreter is the responsibility of the VB. 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.

Management Interview Guidance


Requirements

3.2.4.8. Verifiers must conduct • Refer to Annex VII for tips on management interviews.
management interviews
• 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.
• Questions in Step 2 related to “Management Systems” and in Step 3 related to “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 worker well-being and community projects.

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3.2.5. Document Review Onsite Verification Requirements

General Document Review Guidance


Requirements

3.2.5.1. Verifiers must review • The data collected during interviews must be checked against documentation to ensure that all information matches. The
documents to understand the individuals interviewed will form part, but not necessarily all, of the sample of persons whose personnel files and payroll are
facility’s procedures and to verify verified.
specific claims about how the

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workforce is managed • However, SLCP recommends that if virtual wage/ hours records review took place, the subsequent onsite wage/ hours records
review corresponds 100% to workers interviewed onsite.
• The Verifier may decide onsite to concentrate a review of personnel files or payroll on a set of specific workers or on those
persons with the highest/ lowest hours or wages per pay period. That decision is at the discretion of the Verifier.
• Personnel files will be reviewed to verify facts about contracts, age and identity proof, training, job performance, disciplinary
action and resignation/ termination.
• Note if virtual + onsite verification takes place: See Requirement 5.2.1.4. During onsite verification, Verifiers must ensure that
policy documents shared virtually are physically available onsite

Wage & Hours Records Guidance


Requirements

3.2.5.2. When reviewing wages • The three pay periods required for the sample are:
and hours, Verifiers must select 1. The most recent pay period
three pay periods (recent, high,
2. A peak pay period
low production period) from the
12-month assessment period to 3. A low pay period
verify the self/joint-assessment
If there is no peak pay period (2.) or low pay period (3.) then the Verifier must select two other pay periods at random, but
data. If closure of production
always include the most recent pay period.
happened, the pay period during/
after closure must also be • The Verifier may extend the sample within the 12-month assessment period if s/he deems it necessary to substantiate the
included. verification.
– Example: If a response is “Inaccurate” for working hours, the Verification Data will be based on the documents the
Verifier sampled that showed the inaccuracy. There is no need to look for additional examples if the minimum scope of
document review was completed. However, the Verifier can choose to sample more to better understand the extent of
the problem.
• 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).

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3.2.6. Document and Photo Attachment Onsite Verification Requirements

Requirement Guidance

3.2.6.1. Verifiers must include • At minimum, Verifiers must include photographic evidence and/or documentation in the following instances:
specific photographic evidence
– Outside general overview of the building and area surrounding the facility
and/or documentation attached
to questions of the Tool, selecting – Inside general overview – main section(s) of the interior, the “shop floor”
the question that best fits
– Attendance recording system
– Work in progress: e.g. assembly, cutting, packing
– Canteen, kitchen and/or dormitory (if present)
– Waste handling and storage areas
– Hazardous substance storage areas
– Personal protective equipment
– Firefighting equipment
– Emergency exits and marked non-exits
– Bulk storage tanks and secondary containment
– Supporting facilities such as wastewater treatment and boiler
– Abatement equipment (items used to reduce intensity of pollution)
– Good practices
– Issues identified as "Inaccurate" or “Non-Compliance” (when physical evidence and observable issues permit)
– Issues where more information would help the reader understand the facility circumstances, no matter the outcome of
the “Verification Selection”
• 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

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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.
• Examples of instances for document/photo attachments are noted in the Verifier Guidance.

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Situations of Denied Access


Should the Verifier experience any issues with viewing/accessing information required to verify the self-assessed data:
• 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
• 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
• 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 in Verification Details.

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3.2.7. Pre-closing Meeting Onsite Verification Requirements

Requirements Guidance

3.2.7.1. Prior to the closing meeting, the • If the Verifier has not already completed all “Inaccurate”, “Non-Compliance” and “Updated during Verification”
Verifier must take the time to complete all items to create the Verification Summary in the Tool and prepare for the closing meeting, the Verifier must now
“Inaccurate”, “Non-Compliance” (for take the time to complete as much as possible, and ideally all fields that will allow the Verifier to have a
Verification Summary) and “Updated during productive closing meeting with the help of the Verification Summary.
Verification” items to prepare for the closing
• The “Updated during Verification” items do not appear in the Verification Summary, only in the Facility Profile
meeting
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 non-compliances, 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 Verification Summary is in the Verifier Guidance.

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

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3.2.8. Closing Meeting Onsite Verification Requirements

Requirements Guidance Agenda recommendations

3.2.8.1. The onsite verification • The closing meeting should ideally include the same individuals who were • Thanking facility management for their time
must end with a closing meeting present during the opening meeting, but at minimum facility management

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and union/ worker representatives, if applicable • Explanation of SLCP to the facility once
more
• During the meeting, the Verifier reviews the scope of the work performed
and highlights any discrepancies (gaps) between the self/joint-assessment • Explanation of where there were
and the verification outcomes so that a facility can understand how to discrepancies between the self-assessed
better complete the Data Collection Tool the next time. information and the Verifier data. This will
be based on the Verification Summary (if
3.2.8.2. Verifier must not provide • It is out of scope and not the Verifier’s role to train management, nor to Verifier had time to fully complete).
training or help the facility to help the facility identify the root causes of issues found. Otherwise, conversation will focus on
identify root causes of the issues “Inaccurate” and “Non-Compliance” items
• The Verifier only explains the factual gaps between the assessment data
found
and the verified data and reviews any instances (not already noted in the • Cooperation of staff and availability of
self/joint-assessment) where the facility is not following local legal information
requirements.
• Confidentiality of the results
3.2.8.3. If applicable, Verifier must • The information on data sharing by the VB can be shared with the • Informing facility that the verified
inform facility of any plans the facility during the scheduling process but must also be shared with assessment data will be delivered within ten
VB/Verifier has to share the the facility during the closing meeting. working days of the verification, calculated
verified data with parties other from the final day
• If the VB has an agreement with a user of the facility’s verified
than the Accredited Host and on site
assessment report – other than the facility itself – and this
SLCP/ the VOO
agreement involves reporting of verified assessment data, the • Informing facility that there will be no
facility must be made aware of such reporting. For example, SLCP Corrective Action Plans or improvement
does not prohibit the VB from sending zero tolerance/ critical issue plans provided by the Verifier, as this is out
reports immediately after the onsite verification; but since these of the scope of SLCP
reports (which are outside of the SLCP system) include facility data
• Mentioning two-day grace period (if
obtained through the SLCP assessment process and the facility owns
applicable and exceptional circumstance is
their data, the Verifier or VB must inform the facility of this special
met see 3.3.1.); facility can still provide
data sharing process.
more information to the Verifier to
substantiate assessment information or
3.2.8.4. Should the facility have • If not able to address the issues during the closing meeting, the VB/Verifier
clear up any issues with the Verifier that
any queries and/or concerns and facility must attempt to solve the issues within the two working days
resulted from the onsite verification
about the verified data at after closing of onsite verification (see Requirement 3.3.1.)
question level, the Verifier and • Dispute process
• If the issues still cannot be resolved, the facility still has time to connect
facility must discuss and attempt
with the VB/Verifier during the facility review process of the report (14 • If applicable, VB/Verifier sharing of facility
to address the issues during the

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closing meeting calendar days from receipt of verified assessment report), see Requirement verified assessment data with users other
3.3.2. If concerns relate to Verifier following Verification Protocol and/or than the facility.
Verifier conduct, then the facility can raise a Dispute, see 2.5.7.

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3.3. Post-onsite Verification

3.3.1. Requirements for Resolving Facility Concerns

Requirement Guidance

3.3.1.1 Verifier must address facility concerns • If concerns relate to question level issues like disagreement about a Non-Compliance, then the Verifier/VB must
within two days (48 hours) from end of onsite handle this offline with the facility.
verification
• If concerns relate to Verification Protocol or Verifier conduct, then the Verifier/VB must refer the facility to the
Dispute process, see 2.5.7.
• The Verifier may have to review further documentation or conduct remote interviews due to exceptional
circumstances during onsite verification. Exceptional circumstances include management personnel being absent on
day(s) of verification and Verifier requiring an interview with them or their presence is required to obtain access to
specific policies/ procedures or explain policies/ procedures.
• Example: If a facility explains to the Verifier during onsite assessment that they are unsure if they can share a
document due to confidentiality, then the Verifier can use the 48 hours period after the onsite assessment to allow
the facility to share more information with the Verifier. During the onsite, it should be evaluated that this document
really exists and is something that is being implemented.
The 48 hours is not for the facility to change the verification outcome by writing-up a document after onsite, nor is
the 48 hours for the facility to make corrections to proven/ confirmed verification outcomes.
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3.3.2. Verified Assessment Report Revision Requirements

Requirements Guidance

3.3.2.1. Any changes the Verifier makes to Should the facility and Verifier/VB agree to changes to the verified assessment report at this stage of review (VRC-
the report after completion/ during the Verification Completed status), the facility must change the status from “Verification Completed” to “Verification
facility review phase must be agreed upon by being Edited” and give the Verifier access to the report again through the Accredited Host platform so the Verifier can
the facility make the agreed changes.

3.3.2.2. After edits are finalized, the Verifier • This back and forth between facility review in status “Verification Completed” and Verifier changing the report in
must change the status to “Verification status “Verification being Edited” can occur as often as necessary within the 14 calendar days provided for review
Completed” so the facility can access the and editing.
report again and review the changes
• 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”.
• Emails will also be sent to the Verifier and facility to remind each party of the impending deadline.

3.3.2.3. If in status “Verification being Edited” Should the Verifier need to make edits to the report, as requested by the facility (from VRC to VRE) or by SLCP (after
(VRE), Verifier must work as quickly as VRQ and before submitted to VRC), SLCP recommends that the Verifier again saves a copy of the report in Excel from
possible to finalize the edits and change the the Accredited Host platform for their records prior to changing the status to “Verification Completed”.
status back to “Verification Completed” so
the facility has enough time to review the
report one last time before completion

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3.3.3. Requirements for Report Writing


Note: In addition to the correct Verification Selection and Corrected Response, Verification Data is essential for users to understand facility circumstances and make
decisions on compliance levels, corrective action and remediation. Users use Verification Data to inform compliance, grading, certification and/or remediation.
Refer to the below information and the Verifier Guidance for more details about report writing.

Requirement For Verification Guidance


Selection

3.3.3.1. Verification Selection must be The rules on what Verification Selection to choose are as follows:
completed correctly following the
Accurate: Information provided by the facility is 100% correct and supported by data.
specific rules explained in the column
“Guidance” Updated during Verification: This can only be found in the Facility Profile. When the Verifier arrives on-site the Facility Profile
circumstances may be different from what they were during the self/joint-assessment. For all other questions, the assessment
period only 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 information which may require an update. These changes are not
considered “Inaccuracies” but rather updates to the provided facility data.
Inaccurate: Information provided by the facility has one or more errors; at least one data point shows that the answer is
incomplete or incorrect (i.e. the facility answer is not 100% accurate); or information cannot be verified (i.e. the Verifier cannot
prove that the facility answer is accurate).
For example, if there is a lack of documentation that does not permit accurate verification of specific questions the Verifier
must select “Inaccurate”. Example: A facility was using manual time keeping records, which were not consistent or complete.
The facility switched to an electronic time keeping system 2 months before the verification. The facility was only able to provide
2 complete months of records to the Verifier. Questions that require review of time records must be marked as “Inaccurate”
Facility did not reply during SA/JA: The facility did not provide a response at all. Note, in the offline Tool this will be visible
through the dark grey color, indicating that the facility has not provided a response. When the facility provides a response, the
color changes to light grey.
Not visible to facility during SA/JA: The Verifier’s Corrected Response has opened up conditional questions that were not there
before for the facility to answer during self/joint-assessment, and therefore the facility response is blank. The Verifier needs to
select “Not visible to facility during SA/JA” and enter the Corrected Response.
Example: In the Facility Profile answers will unhide questions in other Sections (Recruitment & Hiring, Wages &

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Benefits, etc.). If the Verifier finds that the facility was inaccurate by NOT selecting "X", "Yes" or entering a number >0
in worker demographics, and changes the Corrected Response to "X", "Yes" or a number above 0 then the conditional
questions that were hidden for the facility become visible for the Verifier (further down in various sections of the Tool).
In this case, the Verifier needs to select "Not visible to facility during SA/JA" and enter Verification Data to support the
Corrected Response. If the Verifier finds that the facility answered accurately, the conditional questions remain hidden
(if the facility did not select "X" or "Yes" or entered “0”).
Not applicable due to special facility circumstances: This is likely to be rarely used. It offers Verifiers the option of noting if
something is ‘not applicable’ if the question has no “Not Applicable” option. Facility circumstances that SLCP has not considered
can come up and it is the responsibility of the Verifier to decide if these special circumstances mean that all answer options
SLCP provides are not suitable. If this Verification Selection is chosen by the Verifier, then the Corrected Response column
remains blank and must not be completed because the question is not applicable.
No longer applicable due to verification: The Verifier’s Corrected Response makes the conditional questions that were
answered (or not answered) by the facility in the self/joint-assessment no longer applicable. The Verifier can just select this and
then not need to explain the Verification Selection choice in Verification Data. If this Verification Selection is chosen by the
Verifier, then the Corrected Response column remains blank because the question is not applicable. For the user of the verified
data the Verification Selection alone is clear that this data can now be ignored due to verification.
Verification not required: Applicable to a few questions where verification is not necessary. It is the only drop down selection
option in the Verification Selection. No Corrected Response can be completed/is needed. If the Verifier chooses to add
comments under Verification Data they can do so, but it is not required.

Requirements For Completion of Guidance


Verification Fields Including
Attachments

3.3.3.2. Depending on the Verification See Table 3 below for what cannot be blank (white cell), what could be blank depending on the circumstances (light grey cell)
Selection, other verification fields and what is not applicable and does not need to be filled in (dark grey cell).
must be completed/cannot be left
blank

3.3.3.3. Verification Data must be • See last column “Photo/ File upload to AH” in Table 3 for when attachments are required
supported by photos/ attachments
• See also Requirement 3.2.6.
where feasible

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• Support material is required (if feasible) where the Verification Selection is “Inaccurate” and if there is a “Non-Compliance”

3.3.3.4. Verifier must adhere to • This applies especially to narrative and attached photos/ documents
applicable data privacy regulations
• Photos must not contain worker names or any personally identifiable information for reasons of confidentiality and privacy
• If facility does not permit photographs due to confidentiality, then please note in report under the Verification Details
section that the facility did not permit a photo of the work in progress/ production line (or other) due to confidentiality/
visibility of brand logos, etc.

3.3.3.5. All fields in the Verification • If the Verifier does not have any information to enter, the Verifier still has to complete the field with N/A.
Details section must be completed
• Verifier should pay attention to the More Info links/fields to understand what to respond in the Verification Details section.
• The question in Verification Details about Verification Duration must be filled in with the total number of person days used
for verification (which may also include virtual verification). E.g. 1) 2 Verifiers for 2 calendar days is 4 person days. 2) 1
Verifier 1 calendar day virtual and 2 Verifiers 1 calendar day onsite is total 3 person days.

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Table 3: Requirements for Completion of Verification Fields

Verification Selection Corrected Verification Data Non-Compliance Legal Reference Photo/ File upload to AH
Response

NEVER BLANK
For every question
that appears in Tool
(even if no response
provided)

NEVER BLANK if Non-Compliance selected IF NON- NEVER BLANK if MUST UPLOAD if Non-Compliance
COMPLIANCE OF Non-Compliance selected and if proof/ documentation
Must fill in narrative to explain the non-
APPLICABLE selected available
compliance so users of the verified data
LEGAL
can make corrective action plans. Must fill in legal
REQUIREMENTS
reference
Non-Compliance information
2
selected with “X”

Updated during NEVER NEVER BLANK If proof/ documentation available to


Verification selected BLANK emphasize a point shared in
Must fill in narrative to explain why
Verification Data then must upload
Must select update is necessary.
or fill in

Inaccurate selected NEVER NEVER BLANK As applicable If Non-Compliance MUST UPLOAD if proof/
BLANK selected, must fill documentation available
Must fill in narrative to explain why the
in narrative
facility’s response was inaccurate and
share facility details so users of the

2
Note that there is automation for Non-Compliance selection and Legal Reference narrative completion on the Accredited Host platform for select countries. Please see more information under the chapter
Identifying and citing when facility is not in line with legal requirements.

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Must select verified data can make corrective action


or fill in plans as necessary.

Facility did not reply NEVER NEVER BLANK As applicable If Non-Compliance If Non-Compliance selected OR if
during SA/JA selected BLANK selected, must fill there is an issue that as per Verifier
Must fill in narrative to explain why the
in narrative social audit experience would result in
Must select facility did not respond, what Verifier
a Code of Conduct finding
or fill in reviewed to support answer and share
facility details, as necessary, so users of AND if proof/ documentation
the verified data can make corrective available
action plans, as necessary.
THEN must upload

Not visible to facility NEVER NEVER BLANK As applicable If Non-Compliance If Non-Compliance selected OR if
during SA/JA selected BLANK selected, must fill there is an issue that as per Verifier
Must fill in narrative to briefly explain why
in narrative social audit experience would result in
Must select this question is now applicable.
a Code of Conduct finding
or fill in
If there is a Non-Compliance must fill in
AND if proof/ documentation
narrative.
available
If there is an issue that as per Verifier
THEN must upload
social audit experience would result in a
Code of Conduct finding, the Verifier must
share facility details so users of the
verified data can make corrective action
plans, as necessary.

Accurate selected As applicable As applicable If Non-Compliance If Non-Compliance selected OR if


selected, must fill there is an issue that as per Verifier
Must fill in narrative if
in narrative social audit experience would result in
• Verifier wants to provide additional a Code of Conduct finding
information about facility
AND if proof/ documentation
circumstances
available
• If there is a Non-Compliance
THEN must upload

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• If there is an issue that as per Verifier


social audit experience would result in
a Code of Conduct finding, the Verifier
must share facility details so users of
the verified data can make corrective
action plans as necessary

Not applicable due to NEVER BLANK If proof/ documentation available to


special facility emphasize a point shared in
Must fill in narrative to explain why there
circumstances selected Verification Data then must upload
is a special facility circumstance that
results in the Corrected Response not
being applicable

No longer applicable Verifier can choose to leave comments


due to verification
selected

Verification not Verifier can choose to leave comments


Required

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Requirements For Verification Guidance


Data

3.3.3.6. Verifiers must provide • If Verification Selection is “Accurate”: there may be circumstances which make the situation unique or irregular. In these
details in “Verification Data” that cases, the Verifier must provide additional information in Verification Data.
explain clearly the reason for the
– Example: The local law permits extra working hours daily due to the availability of less manpower. As this is in line
specific Verification Selection and
with legal requirements, the Verifier would not enter a Non-Compliance. However, the Verifier would need to
provide users of SLCP data with
make note (even if the Verification Selection is “Accurate”) in Verification Data that there was an increase, how
necessary information to inform
much and why and how many workers were affected by increase, etc., and that this is permitted by law.
post SLCP steps (including grading,
certification and corrective action – Example: Months reviewed, etc.
plans)
• If Verification Selection is “Inaccurate”: the user of the data needs to understand what the accurate situation is
(Corrected Response) and why the situation was not captured accurately by the facility in the self/joint-assessment
(Verification Data).
– Specifically, the Verification Data must state what types of evidence were reviewed AND details about the current
circumstances at the facility. If applicable, Verification Data must address:
▪ number of persons affected
▪ name of the policy or procedure in question
▪ dates of the relevant records
▪ place of incidence or activity
▪ any other information that the user of the data should know to assist them with future follow-up or
corrective actions, which are outside of the SLCP assessment process
• If Verification Selection is “Updated during Verification”: If Facility Profile responses need to be updated, the Verifier
must indicate the reason for the update in Verification Data. Reasons provided by the Verifier can be a simple explanation
like something changed between the date of self-assessment and verification.
– Example: An additional production building was found during verification that was not mentioned in the facility’s
self-assessment. In this case, the Verifier must select "Updated during Verification" in the Facility Profile and enter
the correct number of production buildings. Under "Verification Data". The Verifier should note why this
information was not included in the self-assessment. If the Verifier suspects that the facility was deliberately

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providing inaccurate information, this should be noted under “Verification Data” and also repeated in Verification
Details.
• If a facility addresses a specific issue that is not required by law in the country where the facility operates (e.g. time off
for breastfeeding), the Verifier selects “No applicable requirements” and Verification Data must explain that the
facility addresses the issue regardless of the absence of legal requirements.
• If the final verified response shows a result that according to Verifier’s social auditing experience would normally result
in a code of conduct or standard non-compliance (no matter if the Verification Selection is Accurate or Inaccurate),
Verification Data must include details so that the user of the report can better inform remediation efforts.
– Example: A facility answers “Yes” to “Did any workers work more than 60 hours in total (regular + overtime)
within any given week?” The data point is not a legal non-compliance according to the country’s law, and the
Verification Selection is “Accurate”. However, the response presents a circumstance, that is likely to be a violation
of most brand codes of conduct so Verification Data should describe further details.
– Example: If the facility uses prison labor, follow up details on type and number of prison workers would help
inform code of conduct or standard compliance requirements. Likewise, details should be provided in Facility
Profile to provide clarity where appropriate.
– Example: Building is shared with other facilities/enterprises; if applicable, the Verifier should provide information
on the type and number of facilities / enterprises.
• If facility response includes more than one selection due to different processes occurring in the facility, the Verifier must
provide users of the report with enough detail to explain the reason/processes behind the selections.
– Example: The facility has different processes for clocking in and out for different types of workers (e.g. line
workers clock in themselves but those who work in packing/shipping are clocked in by security guards). Therefore,
there is more than one selection for the question “Who performs the clock-in/clock out function for workers?”–
the individual worker and management. In this situation, verification data should explain that for some
categories/types of workers the clocking in and out process is different.
• If facility response is “Facility did not reply during SA/JA”, the Verification Data must be a short statement of what
information was reviewed to support the Corrected Response.
• Verifiers must provide an updated or more detailed description if the facility’s free text responses (e.g. “Please describe
xxx”) do not provide a sufficient or clear description. This is applicable to questions with answer type “Response Here:”.
– Example: A factory has several multi-floor buildings, and each building has a different number of floors. The

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facility must provide the number of floors for the main building and the Verifier must provide details on the other
buildings at the site and how many floors they each have under “Verification Data”. The Verifier may upload a
facility plan to the question to explain the facility layout better through an image

3.3.3.7. If the facility • The only standard that applies to SLCP and must be addressed for every question outside of the Facility Profile is national
circumstances are not in labor law and international labor standards
compliance with applicable legal
• If verified response results in a Non-Compliance determination (no matter if the facility response is Accurate or
requirements, then the Verifier
Inaccurate), the user of the verified assessment report must understand the details of the Non-Compliance to better
must select “Non-Compliance”,
inform remediation efforts
provide Legal Reference and
details for the non-compliance in • If the question does not refer to “in line with legal requirements”, but the Verifier identifies a situation during
Verification Data verification where the facility is not in line with applicable legal requirements, the Verifier must select “Non-Compliance”
AND provide the “Legal Reference”
• Facility Profile: The only Tool section where questions are included but no Non-Compliance option is provided for the
Verifier is the Facility Profile section. If the Verifier identifies a Non-Compliance in this section, they must address the Non-
Compliance in the Verification Details section, where the Verifier is provided an opportunity to provide free text narrative.
• Legal Reference, at minimum, must consist of the specific location of the applicable law in the law text:
– Name of law or regulation
– Year or version no. or other identifying number of the law or regulation
– Location of the applicable text in the published law or regulation, e.g. paragraph, article
– The Legal Reference may also contain excerpts of the law or a summary of the information, as long as the
information is in English.
• Verifiers must enter legal issues correctly. This includes:
– Raising a Non-Compliance when an “Inaccurate” Verification Selection relates to a legal requirement
– Raising a Non-Compliance when an “Accurate” Verification Selection relates to a legal requirement.
See also information about the Law Overlay.

3.3.3.8. Temporary regulatory If during COVID-19, for example, certain laws were temporarily suspended or relaxed by local government, these laws must be
circumstances must also be considered only if applicable during the 12 months of self/joint-assessment data. And no matter the Verification Selection and

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explained in Verification Data, as final verified response, if there was a temporary regulatory circumstance this must be mentioned, as applicable, in the
applicable, and in the Verification Verification Data and the Verification Details section of the report.
Details section of the report

3.3.3.9. If the response to be • The regularity needs to be defined by the Verifier because there is no consensus on regularity unless legally required.
verified is in reference to an
– Example: “Are toilets clean, and sanitized on a regular basis?” If the response to this question is “Yes” then the
activity occurring repeatedly, the
Verifier must ensure that the user of the verified assessment report understands clearly what “regular” means
Verifier must define the
within the context of this facility.
regularity applied by the facility

3.3.3.10. If the facility This Verifier requirement helps facilitate analysis of questions to either improve the question or provide more info or training
misunderstood the question, the around the question.
Verifier must enter the exact
word “Misunderstanding” at the
beginning of the Verification Data
field

3.3.3.11. The Verifier must • Isolated: Systems are in place but a temporary lapse in management of the system resulted in the current circumstance.
provide enough details for the
– Example: Facility with a hiring system that has robust age verification procedures experiences child labor because
reader to identify if the situation
they did not train the new human resources associate sufficiently on procedures.
is “isolated” or “systemic”
• Systemic: Issues that are purposeful, intentional, and methodical in nature that occur regularly and/or impact a significant
number of workers.
– Example: It was noted that the facility employs 10 juvenile workers whose hours are not monitored at all and 8 of
them have worked over 30 hours a week for at least 2 weeks in a row, maximum 4 weeks in a row. This also is not in
compliance with applicable legal requirements. Thus, Verifier applies a Non-Compliance and provides the Legal
Reference.

3.3.3.12. Verification Data clearly • The type and suitability of the evidence/data presented must be clear, and the statement should precisely support the
links to the question/ data point accuracy determination of the Verifier by providing context and the source of evidence.
• The statement must not be general, but specifically linked to the question being evaluated. Therefore, cutting and pasting
of statements into multiple Verification Data fields is poor form.

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3.3.3.13. Verification Data is Verification Data must be limited to factual statements: Details provided (to provide users with enough information to take
factual and without judgment next steps) must not make a judgment on good/bad, compliance to a code/non-compliance to a code, except specifically
related to compliance with applicable legal requirements. The Verifier is not telling the user how to remediate the situation in
Verification Data, but rather sharing all the information necessary (isolated, systemic, who, what, why, where, when, how,
how often, etc.) for the user to define remediation activities.

3.3.3.14. Verifier must enter all • The SLCP final verified assessment report is a report in English. All users require data in English. This means that both the
Verification Data in English facility and Verifier are required to make entries in English only.
• This also means that if the facility provided non-English data, the Verifier is responsible to ensure the final verified
response is in English.
– Example: If a facility free text response in Chinese is “Accurate”, the final verified response will appear as the Chinese
response. Since the user needs English data, the Verifier must translate the facility’s Chinese free text answer and
enter the translated English text into Verification Data. The user will still see the “Accurate” Chinese text but can refer
to the Verification Data to understand the data in English.
• Refer to 3.1.5.4. under 3.1.5. Requirements for additional information.

3.3.3.15. Verification Data uses It is very important that the information is entered using correct spelling and grammar so the user can easily understand the
correct spelling and grammar verified assessment report.

3.3.3.16. Verification Data • The assessment period for SLCP only includes the 12 months prior to the submission date of the self/joint-assessment.
statements must be based on the Verification Data statements are to be based on this assessment period
12-month assessment period*
– Example: Inconsistencies are found in the month of the verification; however, these records are out of the 12-month
scope. Verifier can inform facility of inconsistency and ask the facility if they can include this information in the report.
It is up to the facility to determine if the information can be included. Verifier is, however, permitted to look at all 12
months of the assessment period. If there is a current instance of inconsistency in the month outside of the 12-month
assessment period, there may be another inconsistency elsewhere during the 12-month assessment period. The
Verifier can see if they can find an inconsistency within the 12-month period.
*The only exception is in the Facility Profile section, where the Verifier must include the most up-to-date information which
may require the Verification Selection “Updated during Verification”

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3.4. VB Quality Check and Document Retention

3.4.1. Requirements for VB Quality Check

Requirement Guidance Recommendations

3.4.1.1. VB must conduct an • The VB is responsible for conducting an internal quality check on the report • SLCP takes report quality very seriously. It is
internal quality check on the before it is completed for facility review. the responsibility of the VB to conduct
report (based on quality checks (informed by the Verification
• Once the VB has completed the quality check and the AH checks have been
requirements and guidance Protocol, Verifier Guidance and QA
executed and, if applicable, resolved by the Verifier, the Verifier must
listed in the Verification Manual).
“complete” the verification, this will result in the assessment status change
Protocol, Verifier Guidance
from “Verification in Progress” to “Verification Completed”. • The VRQ check is checking the work of the
and QA Manual) before it is
VB quality check. So if the automated
submitted to the facility for • Before the status changes to “Verification Completed”, an automated SLCP
system identifies a valid failure, then the VB
review data quality check is conducted behind the scenes in a hidden status called
quality check is not rigorous enough. The
“Verification Quality Check” (VRQ). This search for data quality failures takes a
VOO regularly evaluates VB performance,
few seconds. If the data quality check fails, the assessment status automatically
and report quality review is an important VB
changes to “Verification being Edited” (VRE) and an email is sent from
performance aspect.
info@slconvergence.org to all assigned Verifiers of the verified assessment
report. • Although not a requirement, SLCP highly
recommends the Verifier review the VRQ
• The Verifier should then:
check failure email and make revisions to
– Review the email which outlines all the failures the report as applicable.
– Make changes to the verified assessment report, as necessary • Note that the VOO receives the VRQ failures
and also receives a final quality check report
– Finalize the report – again – by changing the status from “Verification being
after the report is finalized by the facility. As
Edited” to “Verification Completed”
part of QA activity, the VOO can compare
– Strive to complete the revisions and finalize the report within 4 calendar quality of the report prior to and after
days. finalization. Any failures/ mistakes still in
place will negatively affect the Verifier and
On calendar day 5 after the assessment status changes from “Verification in
VB score.
Progress” (via VRQ) to “Verification being Edited”, the assessment status

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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”. SLCP regularly reviews and updates the automated data quality checks.

• Go to our Helpdesk to see which data quality checks SLCP is currently running.

3.4.2. Requirements for VB Document Retention

Requirement Guidance

3.4.2.1. VBs must follow local legal As the Verifier and VB do not have access to the finalized verified assessment report (status VRF), Verifiers should save a
requirements relating to the copy of the report (likely the offline Excel version) for their records prior to changing the status to “Verification Completed”.
minimum retention of notes, VBs can always ask the facility to share the finalized verified assessment report with them, but SLCP recommends downloading
documents, photographs and/or a copy at this point in the SLCP assessment process.
client files. SLCP requires at least 12
months of retention to facilitate any
Dispute or quality assurance
procedures.

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3.5. Ethics

3.5.1. Anti-bribery Requirements

Requirements Guidance

3.5.1.1. Accepting gifts of any • Exceptions to the rule may include accepting offers for water, soft drinks, tea, coffee and snack food similar to the kind and
value from facility managers, value consumed regularly by those who are offering it.
workers or others related to the
• SLCP adheres to a strict policy against bribery. In the event that a Verifier is offered money, gifts or other unsolicited items,
verification is inappropriate and
the following procedure must be followed:
not permitted
– Refuse the offer immediately, and explain that such a practice is strictly prohibited
– Take a photo of the item, if possible
– 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).

3.5.1.2. Verifiers must never allow • If the facility orders lunch, Verifiers must pay them back for the lunch and explain that this is SLCP policy.
management to take them out for
• Rides may be accepted to and from the facility only when there is no other option. When the Verifier(s) arrive at the facility,
lunch during a verification nor
their behavior should reflect that of an independent third party. If workers see a Verifier coming out of a facility owned
accept payment for lunch
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.

3.5.1.3. Verifiers/VBs must adhere • See Annex I Professional Conduct and Annex VI SLCP Code of Conduct
to Annex I and Annex VI

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Virtual + Onsite3 Verification

3
Virtual verification alone without an onsite verification is not permitted. “+ Onsite” is a reminder that virtual verification alone does not exist
within SLCP.

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4. SLCP Virtual + Onsite Verification Process

4.1. Introduction
SLCP has permitted only offsite documentation review, thus far. However, with improvements in web connectivity at facility sites and requests to reduce
travel and onsite verification time and costs, SLCP now permits reduction in onsite verification time with execution of virtual verification activity. It is always
the facility’s decision to permit the Verifier to engage in any virtual/ offsite verification activity.
Onsite verification is still required, but due to inclusion of virtual verification aspects, the onsite time can be reduced. A reduced onsite verification still
reflects a robust social and labor assessment because it continues to include the following onsite verification activity:
• Observations of conditions in the facility, which include the work area and facility surroundings,
• Review of working hours, wage and personnel records,
• Review of presence of policies and procedures onsite,
• Management interviews,
• Worker interviews, and
• Triangulation of all information.
For most facilities, full onsite verification will still be the best choice, as virtual activities may come with challenges such as technology failures and delay in
transmission of data during virtual meetings. VBs who have executed virtual audits for certification schemes or brands have noted that virtual activities take
on average 20% more time than the equivalent onsite activities.
SLCP strongly recommends that only facilities who cannot hire local Verifiers, are exceptionally large sites, have a large workforce, have extensive
management systems (numerous policies and procedures) or need to limit onsite time due to health and safety issues like COVID-19 should consider virtual
verification activity. The below SLCP Virtual + Onsite Verification Requirements go into specific technology requirements a facility must meet to consider
virtual verification activity.

4.2. Some Onsite Verification Requirements Apply to Virtual Verification


Section 5 below presents the SLCP Virtual Verification Requirements that must be met to complete any virtual verification activity. At times these virtual
verification requirements work in addition to or replace the SLCP Verification Requirements in Section 3. If onsite and virtual requirements are the same,
reference to the applicable requirements in Section 3 is made. These requirements apply to the verification no matter if the Verifier conducts virtual or
onsite activities. Any reference to Section 3: SLCP Verification Requirements in the below SLCP Virtual Verification Requirements is indicated in red with
links provided to that specific requirement. Return to the top.

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SLCP Virtual + Onsite Verification Requirements

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5. SLCP Virtual + Onsite Verification Requirements


These requirements are mandatory for Verifier Bodies and Verifiers. Guidance is provided for each requirement and is a critical component of the
requirement that should be read together with the requirement. Some requirements are also accompanied with recommendations and/or references to
provide further support throughout the virtual verification process.
Some virtual verification requirements must be met in addition to onsite requirements in Section 3. Links are provided to sections that need to be
addressed alongside the virtual verification requirements. Other virtual verification requirements replace onsite verification requirements, and these will
be indicated in red where relevant.

5.1. Pre-virtual verification

5.1.1. Requirements for Planning Different Types of Virtual Verification Activity


Requirements in addition to 3.1.1. Requirements for Planning the Verification

Requirement Guidance Recommendations

5.1.1.1. The Verifier must confirm • Facility decides whether to include virtual verification activity.
the facility’s eligibility for virtual
• Facility must request virtual verification activity before the VB determines general
verification
feasibility and also which specific virtual verification activity is feasible.

5.1.1.2. Facilities choosing Step 1 • As onsite verification is still required, virtual verification activity is only permitted for
with 100 or less workers are not facilities requiring more than 1 person-day for verification.
permitted to engage in virtual
verification activity

5.1.1.3. Execution of virtual • THIS REQUIREMENT REPLACES REQUIREMENT 3.1.1.3 IN SECTION 3.1.1
verification activity must always be
• Virtual verification activities must be announced to allow for timely meetings.
announced
• In planning, the VB must consider local/ national holidays as well as any specific dates or
date ranges that the facility will be unavailable for verification.

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5.1.1.4. Verifier and the facility • The Verifier must confirm that the facility has a stable Internet connection with sufficient
must discuss the IT systems and speed and bandwidth. This can be checked using free software
other requirements needed to (https://www.speedtest.net/). Testing should occur with actual systems in use. Stability is
support the virtual verification considered OK if (the below are general guidelines):
activity • Ping<100 ms
• Jitter<30 ms
• Speed should be at least 10Mpbs

5.1.1.5. VB must discuss with the • The VB must explain to the facility their rights under the General Data Protection
facility any information security Regulation (GDPR) and/or other applicable data protection laws and regulations.
and confidentiality issues that may
• The facility may be hesitant to share documents due to intellectual property (IP)
arise from remote sharing of
restrictions and may require non-disclosure agreements to be signed prior to sharing
documents, records, and private
confidential/IP restricted documents.
information pertaining to workers

5.1.1.6. Virtual verification for • The facility must be able to share documents remotely to permit virtual/ remote SLCP recommends that larger
documentation review must use documentation review. This includes: documents (e.g. workplace
one of the approved remote policies and procedures) are
– Sharing screens during the virtual verification activity so Verifiers can review
sharing mechanisms shared as softcopies via email or
documents
a secure website like the
– Emailing documents to a Verifier so they can be reviewed
Accredited Host platform.
– Sharing documents through a file sharing platform (e.g. Dropbox, Baidu, etc.)
– Uploading all documents to the Accredited Host platform with the self/joint-
assessment
– Using a video camera to display documents.
• The facility decides what format to use for remote/ virtual document sharing and the VB
decides if they can accommodate the facility’s choice.
• File formats accepted: PDF, JPG, Word, Excel

5.1.1.7. Virtual verification activity • The videoconference software used must support: SLCP recommends that the VB
for document review, walkthrough use videoconferencing software
– Screensharing (for documentation review)
or interviews must be conducted they are familiar with and have
using videoconference software – 2 way live video (for interviews, walkthrough and documentation review) used. If the VB is using a

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– Screenshot capability (to replace photos) software of the facility’s choice,


– Ability to take photographs with a cell phone/camera it is the VBs responsibility to
ensure Verifiers understand how
• Recommended videoconference software feature
to use the software PRIOR to the
– Chat (so users can type questions; especially useful in loud areas for virtual virtual verification activity.
walkthrough or when there are connectivity issues)
• The type of videoconferencing software to be used must be agreed upon by the VB and
the facility

5.1.1.8. Verifier must confirm • The facility staff chosen for virtual verification activity need to have the ability to share
relevant facility staff have the their screens for the record review
ability to share screens if record • This must be determined before the virtual verification activity begins
review should take place via screen
sharing

5.1.1.9. For virtual walkthrough • Since noise on the production floor may make it difficult for the Verifier and the facility to
activity, the Verifier and facility communicate, the chat feature on the videoconference software may be used to
must discuss areas of the facility communicate and/or the designated cameraman should use headphones with an
where noise levels may disrupt integrated microphone.
communication. Where complex
• In areas where hearing protection is required, all communication should be done through
communication cannot be
the chat feature, or the walkthrough of this area should be postponed to the onsite
facilitated through technology, an
verification.
onsite walkthrough is required.
• Where complex communication is not possible or feasible using the chat feature of the
video conferencing software, these facility areas must be visited during the onsite
verification.

5.1.1.10. Verifier must obtain a • As with an onsite walkthrough, all relevant parts of the facility must be included in the
map of the facility to enable any virtual walkthrough. It is therefore essential that the Verifier obtain and study a map of the
virtual walkthrough activity and facility and its premises in order to ensure that the entire facility (including areas such as
ensure all applicable facility areas dormitories and childcare facilities) is covered during the virtual walkthrough.
are visited virtually or with onsite
walkthrough

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5.1.1.11. Verifier must conduct the • To facilitate smooth virtual communication with management (opening meeting,
virtual verification without an management interviews, documentation review), the Verifier must be able to fully
interpreter understand and speak the language used by management.
• Worker interviews are not included in virtual verification activity.

Return to the top.

5.1.2. Requirements for Assigning a Verifier


Requirements in addition to 3.1.2. Requirements for Assigning a Verifier

Requirement Guidance

5.1.2.1. The Verifier(s) conducting the • Onsite activity after virtual activity must be seen as a continuation of the verification event. There must therefore be
virtual activity must also be involved in continuity in the Verifier(s) conducting the onsite verification after virtual verification.
the onsite activity
• Additional Verifiers (in addition to the original Verifier(s) conducting the virtual activity) are permitted for onsite
verification.

Return to the top.

5.1.3. Requirements for Assigning Virtual Verification Activity Time


Requirements in addition to 3.1.3. Requirements for Assigning Person-days

Requirement Guidance

5.1.3.1. Virtual and onsite verification • Virtual verification activity should aim to be consecutive, but there can be some flexibility in planning. If not consecutive,
activity must take place within an 8 the virtual verification activity and onsite verification activity combined must take place within an 8 calendar day period.
calendar day period. If the combined
• Depending on the scope of verification, virtual and onsite verification should ideally be consecutive and occur within the
virtual and onsite verification activity

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cannot take place within an 8 calendar same working week to make sure data are consistent.
day period, the VB must file an
• For onsite activities after virtual activity, the same requirement applies as for verification using no virtual activities: Person
Exception Request.
days should not exceed 4-calendar days; onsite activities that require more than 4 calendar days must involve 2 Verifiers.

5.1.3.2. All virtual verification activity • Full onsite verification activity time can be 15-20% less than when verification is conducted in an onsite + virtual
must be completed before the onsite combination. This is due to scheduling virtual meetings, possible technology/ WIFI/ internet issues, relying on a facility
verification activity member to execute the activities virtually with Verifier instructions, facility staff being new to virtual meetings, etc.
• The exact time required to conduct any or all permitted virtual verification activities will be up to the professional judgment
of the VB/Verifier. This is because the scope of selected activities and the scope of work within each type of virtual
verification activity will depend on facility circumstances and their self/joint-assessment data.
• The completion of combined virtual and onsite verification activity must take place within an 8 calendar day period.
• The Verifier(s) conducting the virtual activity must also be involved in the onsite activity, although additional Verifiers are
permitted for onsite verification.

5.1.3.3. VB and facility must maintain • Although every effort should be made in the planning stage (5.1.1 Requirements) to avoid any unexpected issues, virtual
flexibility in the verification plan to verification activities may not go as planned and cannot be completed. In this case, the Verifier must still meet the
allow for a possible extension of onsite verification requirements and fulfill all required verification activities through onsite verification. This likely means the
verification time if virtual verification onsite verification time will increase due to inability to complete planned virtual verification activities.
activity fails due to unexpected
If the onsite verification timeframe has to be increased and the combined virtual and onsite verification time exceeds 8
circumstances
calendar days, the VB must complete an Exception Request.

5.1.3.4. Person-days must be reduced • The increment is 0.5 person-days because:


in 0.5 person-day increments – Minimum increases in person-days (for Step selection and workforce size) are set at 0.5-1 person-day increments, and
– Adherence to requirements are spot-checked by the VOO, and the increment allows them to more easily check the
accuracy of person-day calculations.
• Reductions in onsite time can therefore be 0.5 or 1 or 1.5 person days, etc., depending on the scope of virtual verification
activity.
• The required virtual verification activities to combine and execute in order to achieve a minimum 0.5 person-day reduction
in onsite time is up to the professional judgment of the VB/Verifier.

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Return to the top.

5.1.4. Requirements for Calculating Number of Person-days, Interviews and Documents to Review
Requirements in addition to 3.1.4 Requirements with use of Table 4 in addition to Table 2 which enforces overall sampling numbers that apply to
the virtual + onsite verification activities as a whole

Requirement Guidance

5.1.4.1. Verifier must follow Table 4 • Onsite verification activities must not exceed 4-calendar days; if more person days are required, more Verifiers must be
below if conducting virtual wages/ added.
hours records review
• There is a maximum threshold for wage/ hours records virtual review for each level of number of workers.
• Personnel records must be reviewed onsite corresponding to the workers interviewed onsite.
• Verifier is permitted to review personnel records virtually if needed (see Requirement 5.2.1.4.) but those personnel records
reviewed virtually do not count toward the required minimum.

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Table 4 below provides calculations for sampling wage and hours records permitted for virtual verification. Table 4 is to be applied along with calculations in
Table 2 in Section 3.1 when conducting virtual + onsite verification.
Table 4: Sample of wage and hours records permitted for virtual verification
Note: For minimum number of worker interviews and personnel records review (to be only done onsite) see Table 2

Consequences for onsite verification activity if


Wage & Hours Records Total (virtual Maximum Number of Wage & Hours
Number of Workers maximum number for wage & hours records review
and onsite) Records permitted for virtual review
is applied

0 – no virtual verification activity 12-14 onsite # workers interview


1 - 100 10 x set of 3 = 30 permitted. See Requirement 5.1.1.2. under 12-14 onsite # personnel records review
5.1.1. Requirements 10 x 3 (30) onsite wage & hours records

20-24 onsite # workers interview


101-200 20 x set of 3 = 60 6 x set of 3 = 18 20-24 onsite # personnel records review
14 x 3 (42) onsite wage & hours records

27-33 onsite # workers interview


201 - 500 27 x set of 3 = 81 8 x set of 3 = 24 27-33 onsite # personnel records review
19 x 3 (57) onsite wage & hours records

36-44 onsite # workers interview


501 - 1000 40 x set of 3 = 120 12 x set of 3 = 36 36-44 onsite # personnel records review
28 x 3 (84) onsite wage & hours records

52-64 onsite # workers interview


1001+ 55 x set of 3 = 165 17 x set of 3 = 51 52-64 onsite # personnel records review
38 x 3 (114) onsite wage & hours records

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5.1.5. Requirements for Review of Self/Joint Assessment


See 3.1.5. Requirements.
Return to the top.

5.1.6. Requirements for Pre-verification Communication to Facility


Requirements in addition to 3.1.6. Requirements

Requirement Guidance

5.1.6.1. Verifier/VB must send a • The virtual + onsite combination verification plan will require more detail than the plan for just an onsite verification.
verification plan no less than five working It must adhere to the 8 calendar day timeframe and outline all times, dates and personnel required for virtual and
days prior to the scheduled verification onsite verification activity. See Verifier Guidance for sample of a verification plan. Also see the Helpdesk for A Guide to
and virtual verification activity must have Virtual + Onsite Verification for Facilities which provides Verification Protocol information about virtual + onsite
set dates and times and personnel activities in a more digestible format to facilities.
included in the verification plan
• All virtual activity has to be completed before the onsite activity.
• As part of the pre-verification planning the VB/Verifier must determine if there are management staff that must be onsite
at the facility during the virtual verification to share/review documents or explain procedures through onsite
demonstration.

5.1.6.2. Verifiers must have facility • Verifiers may not record the virtual verification sessions unless the facility has given written permission.
permission if Verifiers want to record the
• Note specific requirements prohibiting recording of sessions are in place under 5.2.1. Requirements (5.2.1.6.).
virtual verification sessions
• SLCP recommends the use of screenshot functionality.
• Similar to onsite verifications, the Verifier must ask the facility for permission to take pictures during the opening
meeting/ pre-verification meeting prior to starting the virtual activity.

5.1.6.3. Verifiers are not permitted to • Interviews must not be recorded, even if facility provides express permission to do so.
record interviews
• Communication to the facility in advance of the virtual verification activity will include explaining that virtual interview

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activity will not be recorded.

5.1.6.4. Verifier and the facility must • Scheduling key IT requirements would have already been discussed to ensure virtual verification activity is feasible. See
discuss the IT systems and other 5.1.1. Requirements for Planning Virtual Verification Activity
requirements needed to support the
• The Verifier must confirm which areas of the facility have WIFI connections. If there are areas of the facility with no
virtual verification no less than 10
WIFI connection, then the Verifier must determine if those areas of the facility can be inspected virtually using a 4G
working days prior to verification
data connection on a mobile phone or similar device, or if those areas shall be part of the onsite walkthrough.

5.1.6.5. Verifier must ensure the facility • Ideally the facility will designate a single staff person to be the “cameraperson” (the individual in charge of operating
has a staff person available throughout the camera during the virtual verification, especially during the virtual walkthrough).
the verification who is responsible for
using mobile phone or similar device to
provide video access

5.1.6.6. Verifier must conduct a pre- During this meeting the Verifier must:
verification meeting using the
• Explain the virtual verification methodology to facility management
videoconferencing software that will be
used during the virtual verification activity • Test the video conferencing software, including using it in production areas

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5.2. Virtual Verification

5.2.1. Verification Protocol Onsite Activities that can be Replaced by Virtual Activity
Requirements in addition to 3.2.1 to 3.2.6. Requirements under 3.2. Requirements. If onsite Requirements are adapted for virtual verification it is
explicitly noted in the guidance.

General Requirement Guidance

5.2.1.1. Should all permitted virtual • Any one of the virtual activities detailed in this table can be selected by the facility and confirmed by the VB/Verifier.
verification activities take place, the Inclusion of activities will depend on Step selection, technology requirements, document sharing permissions, etc. as per
Verifier must follow the required the Requirements.
sequence of virtual verification
• The Verifier must follow this sequence of virtual verification activities prior to going onsite if all permitted virtual
activities prior to going onsite (see
verification activities are to take place:
guidance for specifics)
1. Pre-verification meeting
2. Opening meeting (which can fully replace the onsite opening meeting if all required attendees are present)
3. Documentation review of soft copies of all policies and procedures
(taken from SLCP document list and documents listed in self/joint-assessment)
4. Management interviews to further understand policies and procedures and review further documents that could not
be shared as soft copies
5. Second round of documentation review, as applicable, to ensure data from interviews match documentation provided
6. Virtual walkthrough/onsite observation
7. Wage and hours records review
8. Scheduling of further virtual verification activity as per 2.-5. if Verifier has follow-up questions or open items

5.2.1.2. Verifiers must thoroughly • Same Requirement applies to 3.2.1.6. Verifiers must cross-check information gained from observation and documentation
document virtual information review with information gathered from the interview process with both management and workers to understand how
gathering to facilitate the cross- workers are affected by various situations
checking of information with (further)

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onsite management interviews, • Verifier still needs to follow the general principle of “triangulation”.
(further) onsite documentation
• However, when verification is split into virtual and onsite and the goal is to reduce onsite verification time, the Verifier must
review, (further) onsite walkthrough
diligently take notes (including permitted screenshots) and ensure the required onsite follow-up activity related to the
and workers interviews which are
already executed virtual activity is clear.
only permitted onsite
• Virtual verification findings will need to be incorporated into the Verification Data narrative of the Tool.

Opening Meeting Requirements Guidance

5.2.1.3. Verifiers are permitted to • As the virtual and onsite activity must be scheduled consecutively and within an 8 calendar day maximum timeframe, the
conduct the full opening meeting opening meeting can function as the kick-off to the virtual + onsite verification process
virtually in place of the onsite opening
• Once onsite, the Verifier can then immediately commence with walkthrough, interviews and/or documentation review
meeting
• The requirement for video conferencing applies, see Requirement 5.1.1.7.
• Also see 3.2.2. Requirements
• 3.2.2.2 Authorization to take pictures must be requested: for virtual verification pictures are considered screenshots or
use of camera to photograph the computer/ tablet screen
• 3.2.2.4 If applicable, Verifiers must inform management that they wish to interview the head of the union(s) and
worker representative(s): this should already have been scheduled and included in the verification plan under
Requirement 5.1.6.1.

Document Review Requirements Guidance Also see 3.2.5. Requirements

5.2.1.4. Verifiers are permitted to • All types of documentation review can be conducted virtually or remotely if the facility permits and applicable privacy
review documentation virtually or regulations are followed.
remotely as long as it is appropriate,
• Appropriate documentation means the documents provide evidence or further context related to the Tool question.
sufficient and in compliance with
applicable data privacy regulations • 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 may be necessary to
fully verify the answers.
• If the documentation is neither appropriate nor sufficient, virtual/remote review can be declined by the Verifier, as the
Verifier cannot execute proper virtual/remote verification. The Verifier must explain in detail why virtual/remote

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verification is not possible.


• There will still be additional required onsite documentation review for wages and hours records that are associated with
workers interviewed onsite.
• This specific portion of documentation review cannot be replaced virtually, i.e. only some wage/ hours records review
can be conducted virtually. See Requirement 5.2.1.12. below.
• Personnel records will only be reviewed virtually if the virtual review of wages/ hours records leads to questions that
must be answered with the review of the personnel records. The overall number of personnel records to be reviewed as
per Table 2 will not be reduced if this virtual activity occurs. The number of personnel records to be reviewed is for onsite
review only.
• Example: A worker received a reduction in pay or a fine due to a disciplinary issue and this is reflected in payroll. The
Verifier therefore asks to check documentation for the disciplinary incident in the worker’s personnel file.
• Apart from the wage/ hours/ personnel records that must be reviewed onsite, if the facility is able to share most but not all
of the required documents remotely, virtual verification activity may still take place. The remaining documents can be
checked during onsite verification. The Verifier will also verify that documents shared virtually are available onsite during
onsite verification.
• Example: A facility can choose to have a virtual documentation review done for Health and Safety but not for labor
conditions. The Verifier will need to verify labor conditions onsite, while also verifying existence of Health and Safety
documentation provided virtually during onsite verification.
• Note: the Verifier does not need to re-verify documents checked virtually when onsite, however, the Verifier does need to
verify that the documents are kept at the facility and not at head office or somewhere else.
• It is the responsibility of the Verifier to ensure that certain documents best checked onsite should not be checked
virtually. For example: checking machinery licenses should be checked onsite to verify corresponding identification
numbers, while policy/ procedural documents can be checked virtually with implementation of these policies and
procedures checked onsite.

5.2.1.5. During onsite verification, • Policy documents must be located at the facility, so they are accessible to all facility personnel. Policies need to be located
Verifiers must ensure that policy where they are intended to be executed.
documents shared virtually are
• Onsite verification of documents ensures value and credibility to the virtual verification process.
physically available onsite

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5.2.1.6. Verifier is not permitted to • For protection of privacy, information security and confidentiality, virtual documentation review cannot be recorded.
record virtual document review and
• If the document does not breach privacy and confidentiality (or private or confidential information is blacked out), the
must ask for permission to take
Verifier may ask the facility if the Verifier can take a screenshot for attachment purposes (attachment to the verified
screenshots during opening meeting
assessment report).
or pre-verification meeting
• Similar to onsite verifications, the Verifier must ask the facility for permission to take pictures during the opening meeting/
pre-verification meeting prior to starting the virtual activity.
• Also see 3.2.6. Requirements.

Management Interview
Guidance
Requirements

5.2.1.7. Management interviews • Management does not need to be present at the facility for the virtual verification activity to take place. The interviews can
follow the same Requirements as happen at a place that best suits the interviewee, but requirement for video conferencing still applies, see Requirement
onsite management interviews, with 5.1.1.7.
one exception (see guidance for
Also see 3.2.4. Requirements
details)

Virtual Walkthrough with Onsite


Guidance
Observation Requirements

5.2.1.8. Virtual walkthrough is • Virtual walkthrough can be conducted as per the Requirements 5.1.1. and in particular 5.1.1.9.
permitted to reduce onsite
• The sample for onsite walkthrough must focus on re-examining possible high risk factors (dangerous machinery, working
walkthrough activity. Onsite
from heights, uneven walkway/ surfaces, chemical storage, etc.), and examining the sensory environment (noise, fumes,
walkthrough is still required on a
and temperature) to determine use of personal protective equipment or other risk mitigation measures like ventilation,
sampling basis (see 3.2.3
temperature controls, etc.
Requirements)
• During the virtual walkthrough the Verifier uses video conferencing to visually verify the implementation of policies and
procedures and observe workplace health and safety practices, see Requirement 5.1.1.7.

5.2.1.9. During the virtual • The Verifier must instruct the facility cameraperson to use the camera feature on the videoconference software (computer,
walkthrough, the Verifier must use tablet, phone or other device the facility is comfortable with and can support videoconferencing capabilities) to allow them
the facility map to identify the parts to view all parts of the facility. It is important for Verifiers to direct the facility cameraperson on which parts of the facility

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of the facility they must observe and they want to view, rather than allow the facility to direct the virtual walkthrough.
they must direct the walkthrough
• During the virtual walkthrough the Verifier should be sure to ask questions to ensure the entire facility is covered.
Questions like “where does that hallway lead to?” or “what processes take place on this floor” can help confirm that what
the Verifier is viewing is in line with the provided map.
• The Verifier must ask the facility to open doors to help confirm the accuracy of information.
• If displaying using a mobile phone, the facility cameraperson should use horizontal format to display the environment.
• SLCP encourages the Verifier to take pictures/ screenshots during the virtual walkthrough. See Requirement 5.1.1.7. that
required screenshot capability.

Wages and Hours Records Review


Guidance Also see 3.2.5.2 Requirement under 3.2.5. Requirements
Requirements

5.2.1.11. The facility must have an • If the facility has an electronic system that maintains electronic copies of wages and working hours records, they are eligible
electronic system that maintains to conduct this verification activity virtually, but the review must happen using screensharing on the device that houses/has
electronic copies of wages and access to the electronic data (likely a computer or tablet).
working hours records in order to
• The facility is not permitted to email copies of these records, take pictures of these records or share through other means.
conduct wage and hours review
virtually

5.2.1.12. The sample of total number • The guidance under Requirement 3.2.5.1. notes: The data collected during interviews must be checked against
of workers to interview and records documentation to ensure that all information matches. The individuals interviewed will form part, but not necessarily all, of
to review is still as per Table 2 and all the sample of persons whose personnel files and payroll are verified. The Verifier may decide […] to concentrate a review of
worker interviews must occur onsite, personnel files or payroll on a set of specific workers or on those persons with the highest/ lowest hours or wages per pay
but worker records review can occur period. That decision is at the discretion of the Verifier.
beforehand and virtually
• The virtual review need not be correlated with the worker interviews onsite apart from 5.2.1.15. It is recommended to
conduct interviews first and then match the remaining record review with those interviewed; therefore interviewees are
not known beforehand and there can be no influencing or coercion of interviewees.
• This allows the Verifier to review some wage/ hours records without the corresponding interview of the worker. See Table
4.
• Triangulation of information is still key, and thus the majority of wage/ hours records review should be of those workers
who were interviewed onsite. SLCP recommends that if virtual wage/ hours records review took place, the subsequent

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onsite wage/ hours records review corresponds 100% to workers interviewed onsite.
• The Verifier is still permitted to interview workers onsite whose records were reviewed virtually. But to ensure the integrity
of the verification process, the identity of the majority of the interviewees will still be unknown until the Verifier selects the
workers onsite.
• Should the Verifier need to re-review the records from the virtual record review due to new information discovered (e.g.
worker interviews or onsite walkthrough), the Verifier shall proceed with the repeated review, but still has to complete the
minimum onsite record review scope as per Table 2.

5.2.1.13. If Verifier engages in wage/ • See 3.2.5.2 Requirement under 3.2.5. Requirements
hours records review, the full 3 pay
• The Verifier cannot only review some pay periods. The entire 3 pay period set for that worker has to be reviewed. As per
periods of wage and hours records for
Requirement 3.2.5.2, any closure pay periods need to be reviewed in addition to complete the required full set of records
that selected worker must be
to review.
reviewed

5.2.1.14. Verifier must include a “real • A “real time” review of working hours/ wage/ personnel records is done by obtaining a list of workers present at the facility
time” review of working hours/ wage/ at the time of virtual verification and checking the records as per Requirement 3.2.5.2 and selection requirements
personnel records (Requirement 3.2.4.2. Verifier must interview a representative sample of workers).
• If virtual working hours/ wage/ personnel records review is feasible, Table 4 shows how the records review can be
conducted with a maximum number of records to be reviewed virtually. The Verifier can always opt to do more review than
the overall (virtual + onsite) minimum requirement onsite.

5.2.1.15. Verifier always selects half • The workers will be selected at random and the facility will not be notified about workers selected for interview until the
of the workers included in the virtual Verifier is onsite.
record review for onsite interviews
• This approach will facilitate triangulation of information and permit the onsite reduction in records review.
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5.3. Post-virtual Verification

5.3.1. VOO Quality Assurance and Report Writing Procedures for Virtual Verification Activities
Requirements to be met in addition to those in 3.3.3. Requirements for Report Writing

Requirement Guidance

5.3.1.1. VB must maintain all records of • To ensure proper quality assurance activities, which also include review of required person days/ time spent on
virtual verification activity review and verification, the VB is required to maintain all records such as:
maintain an accurate account of the
– All Verifier notes
verification plan
– Electronic session logs, if applicable.
• Accurate account of the verification plan means the plan shared with the facility must be updated to show the real
dates and start and end times of virtual sessions.

5.3.1.2. The Verifier must include all • See example narrative for Verification Details and sample verification plan in Verifier Guidance.
information on virtual verification activity
• Verification plan must not only have accurate account of dates and times of virtual verification activity but also include,
in the “Verification Details” section of the
at minimum:
verified assessment report and attach the
verification plan with details of the – Activities that took place (pre-verification meeting, opening meeting, management interviews, etc.)
activity and the extent of the activity that
– The amount of time spent on desktop/ remote review of documents (documents not shared via virtual conference
was conducted virtually
but attached via AH platform to the self/joint-assessment or sent to/shared with Verifier electronically)
– Documents reviewed (Name, version/ date of document)
– Persons interviewed (Name, title, responsibility)
– Records reviewed (which months that correspond to requirement of recent, high/low/closure season, number of
records reviewed)
– Facility plan attached at end of verification plan
– Areas of facility visited

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– If not all of facility visited, then list of areas visited corresponding to the facility plan or areas visually marked
directly on the facility plan, as applicable
• The question in Verification Details about Verification Duration must be filled in with the total number of person
days used for virtual + onsite verification. E.g. 1 Verifier 1 calendar day virtual and 2 Verifiers 1 calendar day onsite is
total 3 person days.

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Annex

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Annex I Professional Conduct
SLCP considers all Verifiers to be representatives of their VBs when engaging with manufacturers.
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
(3) safeguards the well-being of the Verifier team.
Note: that any sign of bias, favoritism and/or wrongdoing, even if perceived, could compromise the
validity of the verification process.

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

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-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

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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.
VBs 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, act with 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 VB 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 workers (>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 worker languages:
– English (A)
– French (B)
– Finnish (C)

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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. To the
right is the flow chart for filtering of Verifiers associated with a VB. Rather than filter by Prior
Verification and Gender, 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 – Inclusion of COVID-19 Information in Verified Assessment Report
COVID-19 has disrupted supply chains and significantly impacted workplace conditions in facilities. As a result, “Verification Data” for a number of SLCP
questions will need to reflect these impacts in addition to other factors impacting facility operations.
Table below provides Verifiers with guidance on how to address the SLCP questions most relevant to impacts from COVID-19. The table provides a likely
scenario as a heading followed by the sections and data points that are most likely to include a response in reference to COVID-19. The table then provides
guidance for facilities and information for the Verifier to include in “Verification Data”.
There may be additional responses to other questions also affected by COVID-19 which are not included in the table, and these will need to be identified by
the Verifier and also explained in “Verification Data”; however, the table does provide a strong starting point in helping Verifiers understand what is
expected from them when including any impacts from COVID-19 in their “Verification Data” responses.
Note: Inclusion of COVID-19 information in “Verification Data” is not a requirement. The information contained in this Annex is to help Verifiers remember
to also provide COVID-19 details as a contributing factor to changes in facility operations, where relevant. The below table is included in the Facility
Guidance.
If you have any further questions, please contact us via the SLCP Helpdesk.

COVID-19 impact: The facility experiences a change in normal hours of operation / reduction in workforce / terminations / retrenchments / furloughs
Section/subsection of
Data Collection Tool Questions Facility Guidance Verification Data
Tool
FP-BAS-16: Normal Hours of Facility enters information to reflect normal Include information about any changes to normal
Operation per day: hours of operation per day during the 12-month hours of operation from closures, reduced working
Facility Profile \ self-assessment period; if hours changed due to hours or changes to normal operations
Basic Information \ COVID-19, then enter all hours that are
Hours of Operation applicable for the 12-month self-assessment
period, specifying the months/ days and the
normal hours
Facility Profile \ FP-WOR-1 Facility enters worker demographics to reflect Include if there are differences between self-
Worker demographics \ […] normal operations during the 12-month self- assessment completion and verification are due to
assessment period; any further facility COVID-19
Workers FP-WOR-41
comments/ notes about changes/ fluctuations in
demographics shall be included at the end of the

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Facility Profile section under FP-FAC-1


Worker Treatment \ WT-DIS-9: Which of the "Conditions of work" include hours of work, rest If conditions of work, such as, shift selection, access to
Discrimination \ following is a factor in decisions periods, annual holidays with pay, occupational overtime, demotion, etc. are impacted by COVID-19,
on conditions of work? (SELECT safety and occupational health measures, as explain if these conditions were ever dependent on
Conditions of Work
all that apply with a "X"): well as social security measures and welfare factors of: race, skin color, sex (gender), religion,
WT-DIS-9-1: Race / Skin Color facilities and benefits provided in connection political opinion, national extraction, social origin,
with employment. disability, HIV/AIDS status, sexual orientation,
WT-DIS-9-2: Sex / Gender
This question covers any decisions regarding pregnancy/maternity status, marital status, age,
WT-DIS-9-3: Religion nationality/foreign migrant worker status or family
conditions of work, including any decisions due
[…] to COVID-19, such as shift selection, access to responsibilities.
overtime, etc.
Termination \ TER-DIS-2: Which of the Facility selects all factors involved in If workers were terminated due to COVID-19, Describe
Discrimination \ following is a factor in decisions determining which workers were terminated, the factors used to decide which workers were
on termination, forced forced to resign, retrenched or retired. terminated (e.g. race, skin color, sex (gender), religion,
Termination
resignation, retrenchment or This question covers any reasons for political opinion, national extraction, social origin,
retirement? (SELECT all that termination, forced resignation, retrenchment disability, HIV/AIDS status, sexual orientation,
apply with a "X"): or retirement including COVID-19 pregnancy/maternity status, marital status, age or
TER-DIS-2-1: Race / Skin Color nationality/foreign migrant worker status)
TER-DIS-2-2: Sex / Gender
TER-DIS-2-3: Religion
[…]
Termination \ TER-DIS-3: Have decisions of Yes/No Explain if COVID-19 was one illness that played a
Discrimination \ termination, forced resignation, This question covers any illness including factor in determining decisions of worker termination,
retrenchment or retirement COVID-19 forced resignation, retrenchment or retirement.
Absence due to Illness
been dependent upon a
worker's absence due to illness?
Termination \ TER-EMP-2-3: Workers were Yes/No Explain if COVID-19 was a reason for terminating
Employment Practices \ terminated for invalid reasons This question covers any invalid reason workers
Invalid Reasons including COVID-19

Termination \ TER-EMP-3: Does the facility This question considers any legal requirements Describe what legal requirements were addressed if

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Employment Practices \ comply with legal requirements enacted to protect workers suspended or laid the facility suspended workers or reduced the size of
Suspension / Reduction before suspending workers or off as a result of a reduction in workforce due to the workforce due to COVID-19.
Workforce reducing the size of the economic, technological, structural, operational
workforce due to economic, or other similar changes
technological, structural, This question covers any economic,
operational or other similar technological, structural, operational or similar
changes? change including COVID-19

COVID-19 impact: The facility experiences a change in payment of wages, termination benefits and/or paid leave for workers affected by COVID-19

Section/subsection of
Data Collection Tool Questions Facility Guidance Verification Data
Tool
Wages and Benefits \ WB-WAG-44: Are wage This question addresses regular wage payments, Include information on changes to wage payment
payments made regularly and as well as any required payments to workers requirements (including pay due dates) as a result of
Wages and Benefits \
on time and in line with legal due to COVID-19, any required hazard pay / COVID-19
Wage Payment incentive pay, etc.
requirements?
If the facility did not pay any wages or other
required payments on time, answer NO
Termination \ TER-EMP-1: Does the facility not Facilities must consider any legal requirements Describe what termination benefits were not paid in
Employment Practices \ follow legal requirements when not enacted specifically to protect workers line with legal requirements for termination as a result
workers resign or are financially who are terminated. of COVID-19
Unjust Termination
terminated in relation to:
This question covers all legally required
[…]
termination payments, including any legally
• outstanding wages,
required payments to assist workers terminated
• termination payments,
as a result of COVID-19
• termination payments all paid
on time,
• compensation for unused
annual leave, and/or
Termination \ TER-EMP-2: Please specify These questions cover outstanding wages, Describe if workers were not paid correctly for
Unjust Termination which of the items below apply severance payments, timely termination outstanding wages, severance pay and/or unused
(SELECT all that apply with a payments and unused annual leave annual leave, or if termination payments were not
"X"): requirements not enacted specifically to protect paid on time as a result of COVID-19.

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TER-EMP-2-4: Workers were not workers terminated for any reason including
Termination \ paid correctly for outstanding COVID-19
Outstanding Wages wages
Termination \ TER-EMP-2-5: Workers were not
Severance Payment paid correct severance
payments
Termination \
Timely Termination TER-EMP-2-6: Termination
Payment payments were not paid on
time
Termination \
Unused Annual Leave TER-EMP-2-7: Workers were not
compensated correctly for
unused annual leave
Wages and Benefits \ WB-WAG-81: Is the facility not This question refers to any diagnoses / types of If “Other types of required leave” is selected due to
Wages and Benefits \ paying workers correctly for any leave including COVID-19 COVID-19 leave, describe the legally required terms of
of these types of leave as legally payment.
Leave
required:
If “sick leave” is selected, describe any legally required
[…] special provisions for paid sick leave due to COVID-19.
• Sick leave
[…]
• Other types of required leave?

COVID-19 impact: The facility experiences an increase in overtime and changes in how working hours are recorded
Section/subsection of
Data Collection Tool Questions Facility Guidance Verification Data
Tool
Working Hours \ WH-WOR-15: Did any workers These questions are in reference to workers If the answer to any of these questions is yes, and if
Working Hours \ work more than 60 hours in working extended hours for any given reason overtime was worked due to COVID-19 impacts,
total (regular + overtime) within including COVID-19. describe this under “Verification Data”. Include details
Total Working Hours
any given week? such as whether the overtime was due to a reduced
WH-WOR-16: Did any workers workforce or closures that impacted production
work more than 72 hours in planning.
total (regular + overtime) within

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any given week?


WH-WOR-17: Did any workers
work more than 80 hours in
total (regular + overtime) within
any given week?
WH-WOR-1: How are hours of If the facility has changed their method of If the facility has changed their methods of
work recorded for all workers? timekeeping as a result of any reason including timekeeping (e.g. from biometric to manual) to
(SELECT all that apply with a COVID-19 (e.g., switching from biometric to prevent the spread of COVID-19, indicate that more
"X"): manual timekeeping), both methods of than one timekeeping system was used due to COVID-
WH-WOR-1-1: Manually timekeeping should be selected. 19.
(i.e. written record) If the facility uses biometric timekeeping, indicate how
WH-WOR-1-2: Mechanically the biometric timekeeping system is sanitized to
(i.e. punch card) prevent spread of COVID-19.
Working Hours \ WH-WOR-1-3: Electronically
(i.e. swipe card)
Working Hours \
WH-WOR-1-4: Biometrically
Records
(i.e. fingerprint/face scan)

WH-WOR-4-4: Start and finish If workers are required to clock in/out If the facility has adjusted payroll to allow for workers
times in the payroll system before/after the start of their shift and this is to clock in/out before/after the start of their shift due
match exact time in/out in time not reflected in the payroll, answer No. to social distancing rules, describe how much extra
records time is reflected in workers’ pay.
This question is in reference to workers clocking
in/out before/after the start of their shift for
any reason, including social distancing due to
COVID-19.

COVID-19 impact: The facility tests and treats confirmed cases of COVID-19

Section/subsection of
Data Collection Tool Questions Facility Guidance Verification Data
Tool

Worker Treatment \ WT-DIS-20: Does the facility If the facility requires COVID-19 testing for If the facility is requiring COVID-19 testing, describe
require other infection or illness workers, the answer to this question should be the details of the process (when, how often, how,

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Discrimination \ tests (e.g. Hepatitis B) at any YES who, etc.).


Infection or Illness time during employment?
Facilities must consider any legal requirements
WT-DIS-21: If yes, are these for tests administered for COVID-19
infection or illness tests
administered in line with legal This question is in reference to testing for all
requirements? non-HIV/AIDS related infection or illness,
including COVID-19

WT-DIS-24: Has the facility If the facility treats workers for COVID-19, the If the facility is providing treatment for COVID-19,
taken steps to enable workers answer to this question should be YES describe the details of the process (when, how often,
with infections or illness (other how, who, etc.).
Facilities must consider any legal requirements
than HIV/AIDS) to retain their
for individual response to / treatment of COVID-
work if they were medically able
19
to?
WT-DIS-25: Are these steps to This question is in reference to treatment of all
help workers with infections or non-HIV/AIDS related infection or illness,
illnesses (other than HIV / AIDS) including COVID-19
in line with legal requirements?

Health and Safety \ HS-EME-1: Does the facility If the facility’s emergency response plan Indicate if the facility has implemented any new
Emergency have a written Emergency includes dealing with the spread of COVID-19 procedures for dealing specifically with COVID-19. For
Preparedness \ Response Plan? answer YES. example:
Emergency Response Note any local regulations to prevent the spread • Measures taken to reduce large gatherings of
Plan of COVID-19 that apply to the facility and how workers such as group trainings and emergency
the facility is complying with these regulations. evacuation drills.
• Measures taken to prevent the spread of COVID-
This question is in reference to a written
19 as workers enter the facility, such as
Emergency Response Plan for all emergencies
temperature checks.
including COVID-19
• Communications workers receive about COVID-19
and how workers are trained to prevent the
spread of COVID-19.
Health and Safety \ HS-WOR-1: Are workers subject If there are confirmed cases of COVID-19 in the If there are confirmed cases of COVID-19 at the
Worker Protection \ to negative consequences if facility and the facility is not taking proper facility, indicate if the facility allows workers to refuse

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Imminent Danger they remove themselves from precautions to contain the spread (e.g. to work (with or without permission).
work situations that they temperature checks, testing, masks, social
Workers who have refused to work due to confirmed
believe present an imminent distancing, hygiene measures), and workers are
cases of COVID-19 must be considered when
and serious danger to life or not permitted to refuse work due to safety
answering this question.
health? concerns, the answer should be NO.
This question refers to any situation a worker
deems to be an imminent and serious danger to
life or health, including a lack of safety
measures preventing the spread of COVID-19

Health and Safety \ HS-FIR-5: Are on-site medical Yes/No Note the number of workers with confirmed cases of
First Aid and Medical \ facilities / clinic(s) and staff in Facilities must consider any legal requirements COVID-19.
line with legal requirements? for on-site medical facilities / clinic(s) and staff.
Medical Treatment
This question refers to on-site medical facilities /
clinic(s) and staff for all medical requirements
including COVID-19

Health and Safety \ HS-FIR-10: Does the facility Yes/No Note the number of workers with confirmed cases of
First Aid and Medical \ record work-related accidents Facilities must consider any legal requirements COVID-19.
and diseases and report them to for recording and reporting work-related
Work-related Accidents
the competent authority in line accidents and diseases.
and Diseases
with legal requirements?
This question refers to all work-related diseases
including COVID-19

COVID-19 impact: The facility takes additional preventative methods to prevent the spread of COVID-19
Section/subsection of
Data Collection Tool Questions Facility Guidance Verification Data
Tool
Health and Safety \ HS-GEN-10: Are the facility's If the facility undertakes regular Provide details of how the facility’s sanitary practices
General Work sanitation practices in line with cleaning/sanitizing to prevent the spread of prevent the spread of COVID-19.
Environment \ legal requirements? infectious disease such as COVID-19, the answer For example:
to this question should be YES. • Re-arranging workstations to be 6 ft apart
Cleanliness, Sanitation &

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Waste Facilities must consider any legal requirements • Installing barriers between workstations, etc.).
for sanitary practices related to all infectious
diseases.
This question refers to all sanitary practices
including those specific to COVID-19

Health and Safety \ HS-GEN-21: Does the facility This question refers to the provision of hand Indicate If additional hand washing/sanitizing stations
General Work provide hand washing facilities washing and drying facilities for regular have been installed to prevent the spread of COVID-19
Environment \ equipped with clean water and sanitation as well as increased measures for
soap, along with a sanitary way infectious diseases including COVID-19.
Toilet / Restroom
for drying hands after washing
them?

Health and Safety \ HS-WOR-3: Are workers Facilities must consider any legal requirements Indicate if workers are provided PPE (masks,
Worker Protection \ provided with Personal for the provision of PPE in accident prevention respirators, face shields) specifically to prevent the
Protective Equipment (PPE) in as well as in the spread of infectious disease spread of COVID-19. If PPE is provided specifically to
Personal Protective
line with legal requirements? including COVID-19. prevent the spread of COVID-19, indicate if workers
Equipment (PPE)
are trained on how to properly use PPE to prevent the
spread of COVID-19.

Health and Safety \ HS-DOR-2: Does the facility Facilities must consider any health and safety If the facility has dormitories, indicate any measures
Dormitories have any of the following legal requirements for housing/dormitories the facility has implemented to prevent the spread of
measures in place regarding specifically for COVID-19. COVID-19 in dormitories. Note specifically if the
housing/dormitories? (SELECT facility has implemented curfews in dormitories to
This question refers to all health and safety legal
all that apply with a "X"): prevent the spread of COVID-19.
requirements for housing/dormitories including
HS-DOR-2-2: COVID-19.
Housing/dormitories are clean
HS-DOR-3: Are housing /
dormitories in line with all other
health and safety legal
requirements?
Health and Safety \ HS-CAN-2-3: Food preparation, This question refers to all measures taken for If the facility has a canteen, indicate any measures the
Canteens storage, and eating areas are the clean, safe and hygienic preparation of food, facility has implemented to prevent the spread of
kept clean, safe, and hygienic food storage and eating areas, including

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(including temperature, measures taken specifically to prevent the COVID-19 in the canteen.
ventilation, light, noise etc.) spread of COVID-19.

Health and Safety \ HS-HEAL-1: Are facility practices Facilities must consider any other legal health Indicate any additional legally required health and
Health and Safety \ out of compliance with any legal and safety requirements not enacted by the safety measures not enacted by the facility to prevent
requirements not covered facility to protect workers the spread of COVID-19 in the workplace.
Other Legal
elsewhere regarding Health &
Requirements This question covers all legally required health
Safety?
and safety practices including those specific to
COVID-19

COVID-19 impact: Changes in the verification process occurred


Section/subsection of
Data Collection Tool Questions Facility Guidance Verification Data
Tool
Verification Details \ VD-VER-22: Any other comment N/A Indicate if COVID-19 had any impact on the
Verification Details \ verification process, e.g. if certain areas of the facility
were not operational.
Verification
Observations

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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. Please find it in the Annex of the
Facility Guidance.
Completing your assessment on the Accredited Host platform
Please refer to the Facility Guidance for details about the verification process and how to complete your
assessment. If you want to reduce the time of the onsite verification by permitting the Verifier to engage in
virtual or offsite activity, please contact us for more information. If you want us to review policies and
procedures before arriving onsite, you can upload documents to the Accredited Host platform. Note, these
uploaded documents will be visible in the final verified assessment report and visible to those you share the
report with. We ask that you do not upload any sensitive information, such as personally identifiable
information relating to your workers, 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 question FP-BAS-26 Date of self/ or joint-assessment
submission (YYYY-MM-DD). 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 you choose to engage in virtual/offsite verification activities to reduce the onsite verification time and your
facility circumstances fit the virtual/ offsite verification requirements, the number of days listed above may be
decreased in 0.5 person-day increments.
• 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,
interpreters 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 workers 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
workers’ representatives (as applicable) are present.

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• 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.
• For more details about the verification process, please read the Facility Guidance.
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 – Inclusion of COVID-19
information in Verified Assessment Report document which also contains information for facilities on how to
complete the self/joint-assessment. Please find it in the Annex of the Facility Guidance.
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. Worker 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. Worker resignation records

Working Hours
1. Time in/out records (Working hours & overtime hours records)

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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
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)

Worker 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

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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
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

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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. EHS policy & procedure
4. Communication and training records for workers, 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.

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
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.

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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 workers 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 workers towards cleanliness and safety
o Attitude of line supervisors and department heads towards workers
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

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Worker Interviews
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 workers to understand the orientation process
o Leadership: connect with worker 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 worker (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 Workers under probation
o Young workers
o Apprentice/ student workers
o Union/ worker representative
o Pregnant workers
o Workers returning from maternity leave
o Workers from any other vulnerable group
o Temporary/ contract workers
o Fixed term/ non fixed term contract workers
o Workers from different departments, different salary levels, different job positions
o Workers of various nationalities (including migrant workers and foreign contract workers)
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 workers from eating or taking
appropriate rest.
o Explain the purpose of the verification and that all interview information will be

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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 worker 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 on 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 workers 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 workers 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. Human resources policies and procedures
7. How workers communicate issues to management
8. 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
o If during the interview you find inaccuracies or non-compliances with applicable legal
requirements, 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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