EICC Validated Audit Process (VAP) VAP Operations Manual

1 EICC VAP Operations Manual 1 EICC Validated Audit Process (VAP) VAP Operations Manual Revision January 2016 Information and communication technology companies working through the Electronics Industry Citizenship Coalition (EICC) are working to improve sustainability and social responsibility within the global supply chain. These companies recognize a mutual responsibility to ensure working conditions in the Information and Communication Technology (ICT) industry are safe, workers are treated with respect and dignity, and that manufacturing practices are environmentally responsible.

2 The Validated Audit Process (VAP) is a collaborative approach to auditing to reduce the burden on supply chain companies from multiple requests for social audits. The VAP meets the need for a high quality, consistent and cost-effective standard industry assessment for labor, ethics, health, safety and environmental practices based on the EICC code of conduct, laws, and regulations. For more information about the VAP, please contact: EICC Address: Suite 330, 1737 King Street, Alexandria VA 22314, USA EICC Website: 2016 Electronic Industry Citizenship Coalition.

3 All Rights Reserved. No part of these materials may be reproduced or transmitted in any form or by any means, electronic or mechanical, including but not limited to photocopy, recording or any other information storage or retrieval system known now or in the future, without the express written permission of the Electronic Industry Citizenship Coalition, Incorporated. The unauthorized reproduction or distribution of this copyrighted work is illegal and may result in civil or criminal penalties under the Copyright Act and applicable copyright laws.

4 EICC VAP Operations Manual 2 16. EICC Code Interpretation Guidance This section details the Provisions of the EICC code ( - 2016). The provisions define the EICC requirements to which the auditee needs to conform. The following sections outline requirements for site observation, document review, management knowledge and understanding and worker awareness and understanding for each of the EICC code provisions. Note: All communications from auditee to workers must be done in a language that is easily understood by the workers. If this is not the case, then the relevant aspect is a Major nonconformance.

5 All conformance statements apply to all workers, including temporary, migrant, student and contract, directly and indirectly employed workers that work in the factory/on production/in warehouse and any other type of worker/employee unless the conformance statement specifically states a narrower focus group. Note : If an auditee facility or corporate policy or the Collective Bargaining Agreement are in place, and are stricter than either the EICC Code of Conduct and/or the legal/customer requirements, then if a practice is observed which does not meet the auditee s own policy or Collective Bargaining Agreement, the conclusion is nonconformance (even if it meets EICC and/or legal requirements).

6 EICC VAP Operations Manual 3 A. LABOR A1) Freely Chosen employment Forced, bonded (including debt bondage) or indentured labor; involuntary prison labor; slavery or trafficking of persons shall not to be used. This includes transporting, harboring, recruiting, transferring or receiving persons by means of threat, force, coercion, abduction or fraud for labor or services. There shall be no unreasonable restrictions on workers freedom of movement in the facility in addition to unreasonable restrictions on entering or exiting company-provided facilities.

7 As part of the hiring Process , workers must be provided with a written employment agreement in their native language that contains a description of terms and conditions of employment prior to the worker departing from his or her country of origin. All work must be voluntary and workers shall be free to leave work at any time or terminate their employment . Employers and agents may not hold or otherwise destroy, conceal, confiscate or deny access by employees to employees identity or immigration documents, such as government-issued identification, passports or work permits, unless such holdings are required by law.

8 Workers shall not be required to pay employers or agents recruitment fees or other related fees for their employment . If any such fees are found to have been paid by workers, such fees shall be repaid to the worker. NOTE: for the purposes of this provision (A1), requirements for directly and indirectly employed workers are the same. Any type of forced, involuntary prison, indentured, bonded (including debt bondage), trafficked or slave labor is not used Minimum requirements: Site observation: Not applicable Document review: o All fees and penalties are disclosed to the workers.

9 Documentation on fee disclosure and actual fees for the workers at the Auditee is complete, available and compliant with the provisions of the EICC code and the EICC Trafficked and Forced Labor Definition of Fees August, 2015. Excessive or Prohibited fees, as described in the EICC Trafficked and Forced Labor Definition of Fees August, 2015, are not allowed under any circumstances. Contracts with workers are free of clauses or language which entails components of or could lead to forced, involuntary prison, indentured, bonded, trafficked or slave labor.

10 Hiring practices, and those of any labor agencies/recruiters, must prohibit forced or bonded labor. o Payroll, wage and other records reviewed show no prohibited fees, Excessive Fees, significant debt, and/or significant loans except those acceptable fees listed in the EICC Trafficked and Forced Labor Definition of Fees August, 2015. Records reviewed must show conformance with law, policies, and procedures. o Specific requirements: EICC VAP Operations Manual 4 Recruiting and Hiring practices: Any fees not allowed in the EICC Trafficked and Forced Labor Definition of Fees August, 2015 are required to be returned to the worker within 90 days of discovery.