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CSR Policy & Requirement.pptx

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The document outlines a corporate social responsibility policy and objectives for suppliers. It discusses why CSR is important, customer's code of conduct covering topics like forced labor, working hours and wages, health and safety, and the environment. It provides an overview of customer audits to evaluate supplier compliance, the audit scoring system, and potential consequences for violations. Suppliers are encouraged to join Sedex to complete self-assessments and facilitate customer CSR audits to ensure ethical and compliant operations across the supply chain.

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25th September 2019 Corporate Social Responsibility Policy
Agenda Introduction Objective Why CSRis important? customer Ethical & Environmental Code of Conduct Supplier Approval flow SEDEX Audit Score & Grade Q&A 2
Objective 1.0 Toenhance suppliers understanding about CSR and Code of Conduct (CoC)s requirement 2.0 Toincrease suppliers knowledge on how to preparefor Customer CSR audit 3.0 Toensure suppliers awareness about forced labour practise and laws relevant to the modern slavery and human trafficking 3
customer CSR
Improve Audit Sedex customer Code of Conduct Howcustomerworkwith suppliers?
7
8 customer is about creating machines that 1) perform better, 2) energy efficient, 3) environmentally friendly, 4) manufactured ethically . customer has a responsibility for compliance 1) Shared with its suppliers in its supply chain 2) Create good working conditions 3) Minimal impact on the environment WHY CSR IS IMPORTANT TO CUSTOMER
CSR Policy & Requirement.pptx
Management System Labour Ethics Environment Health & Safety
10
customer Code of Conduct Category 11
1. No ForcedLabour Freely Chosen Employment Zero Recruitment Fees Outsourced Labour Suppliers Full &Direct accessto personal identification documents Workers are free toterminate employmentby giving reasonable notice WITHOUT fear of penalty 12
Offenceto keepworkers passport under Malaysia Passport Act1966 13
customer PassportAccessPolicy: Individual, secured passport locker
Legislations on Forced Labour UK Modern Slavery Act 2015 Federal Acquisition Regulation California Transparency Act Trade Facilitation and Trade Enforcement Act 16
CSR Policy & Requirement.pptx
Requirement RegardingtheFMW Employment Cycle No RecruitmentFees & Deposit On site recruitment (source country) Contract Transport Accommodation Wages Termination & Resignation
CSR Policy & Requirement.pptx
EMPLOYMENT ACT 1955 Law, Practice & Compliance Employees Who are covered by the Act? Coverage What issues are covered by the Act? Questions & Answers What issues interest you? Definitions How significant are words used in the Act?
EMPLOYEES protected by the Employment Act 1955 RM2,000 < WAGES RM5,000/MTH Limited to Sections 69(1)(a), 69B & 69C SEXUAL HARASSMENT All employees irrespective of wages FOREIGN EMPLOYEES Whose wages RM2,000/mth, or whose wages > RM2,000/mth but engaged in manual labour, etc. WAGES RM2,000/MTH Irrespective of occupation WAGES > RM2,000/MTH Engaged in manual labour, operate mechanically propelled vehicles, supervise manual labour, non-officer in a vessel registered in Malaysia & domestic servant. PROBATIONERS Whose wages RM2,000/mth, or whose wages > RM2,000/mth but engaged in manual labour, etc. PART-TIME EMPLOYEES Whose wages RM2,000/mth, or whose wages > RM2,000/mth but engaged in manual labour, etc. MATERNITY PROTECTION All female employees irrespective of wages
Contract of service Termination of contract Administration of wages Protection of female employees Maternity protection Rest day Hours of work Public holidays Annual leave Sick leave Part-time employees Termination & lay-off benefits Foreign employees Registers & returns Sexual harassment COVERAGE OF THE EMPLOYMENT ACT 1955
Child Worker Not completedageof15 Family Business Young Worker 15 years-18years< 7hours/day work Overtime andnight shift not allowed Break every 4hours No hazardous work 20 2. Child Labour
3. Working Hours, Wagesand Benefits Working hours should not be excessive 1 rest day in every 7daysperiod Overtime (Normal) doesnotexceed104 hours/ month Recommendation: Publish workinghours and break time on notice board 22
CSR Policy & Requirement.pptx
3. WorkingHours, Wages&Benefit WagesandBenefits accordingtolegal requirements Minimum Wage Order 2016 Overtime Calculation Annual Leave& Sick Leave benefits Paywages on time & provide payslip Proper Salary Deductions RelatedLaw:EmploymentAct1955, EmploymentRegulations 1957 25
26 AnnualandSick LeaveBenefits Length of Service Annual Leave Sick Leave Less than2years 8 days 14 days 2 years- less than5 years 12 days 18 days 5 yearsor more 16 days 22 days
4. GeneralLabour Practices 1. No Discrimination 2. Fair Disciplinary Practices 3. FreedomofAssociation 27
28
5. Health & Safety HIRARC Comply with relevant laws and regulations Give training PPE/Engineering Control/Management Control Takemeasures toprevent accident. Do due diligence
OSHA 1994 30 Key Requirements: 1) Safety& Health Committeeformation 2) ChemicalHealth Risk Assessment (CHRA) 3) Notifications of Workplace Accidents
FMA 1967 FM(Noise Exposure) Reg. 1989 FM (Safety, Health & Welfare) Reg. 1970 FM(Steam Boiler & Unfired Pressure Vessel) Reg. 1970 31 Key Requirements: 1) PPE usage 2) Toilet &drinking facility 3) First Aid 4) Ventilation, lighting, temperature suitable for workingcondition 5) Safetyprovision in termsfire fighting andemergencyevacuation
Health &Safety Key Requirements 32 Safety&Health Committee Risk Assessment Emergency Preparedness MachineSafety Chemical Management Communication Training
CommonFindings ~ HSE Not wearing PPE Health and Safety Meeting Fire Certificate availability Emergencydoor blocked, pathwayblocked Emergencyexit door lockedwith keyin break glass box Emergency Light Praying room and washingarea must beseparated with gender PPEvisualreminder Canteen operators attire Evacuation map Fire hose without key First Aid box requirements Noise monitoring Scheduled Waste- labelled and segregated accordingly SDS Expired, readiness Forklift Training record,license and checklist and inspection Competent Person for Scheduled Waste &Waste Water Warehouse/Store stacking-Wrap Toilet soap, Tissue and capacity Recycling/ Scrap Workers
Examples of DOs & DONTs when working in manufacturing company
Wear safety goggles Wear safety footwear Wear safety gloves Wear safety mask Wear Ear Protection DOS Wear safety helmet
Electric Hazard! Dont Touch No Smoking Hot Surfaces! Dont Touch Dont Throw Trash into Toilet No Foods Allowed DONTS
Examples of DOs & DONTs when staying in company hostel
CLOSE YOUR TAPS AFTER USE FLUSH TOILET AFTER USE KEEP LOCKED WHEN NOT IN USE DOS THROW RUBBISH INTO DUSTBIN DIRECTION ON USING FIRE EXTINGUISHER PLEASE QUEUE UP
NO PETS ALLOWED NO OVERLOADED PLUGGING NO SPITTING NO ENTRY NO CANDLES ALLOWED NEAR BED DONTS NO ALCOHOL
Food Legislation Food Act 1983 Food Regulations 1985 Food Hygiene Regulations 2009 Key Requirements: 1) Registration of foodpremises 2) Conductandmaintenanceoffood premises 3) Food handler 4) Requirementsandprocedure in handling, preparing, packing, serving, storing andselling of food 40
6. Anti-Bribery & Transparency Free &full AccessFactory,hostel, etc Confidential Interviews No bribery, corruption or unethical practices Whistleblowing channel/program No retaliation policy 41
7. The Environment Supplier must ensure thattheir operation is not negativelyimpactingthe environment. Must beable tomeasure, control, andwhere everpossible, reducetheir environmentalimpact
Environmental Quality Act1974 Environmental Quality (Scheduled Wastes) Regulations 2005 Environmental Quality (Amendment)Act 2012 Environmental Quality (Clean Air) Regulation 2014 43 Key Requirements: 1) Environmental monitoring air, water, noise 2) Scheduled/hazardous wastemanagement 3) Environmental Permits andReporting
44
45
Well maintained Fit for Purpose (CF,H&S, Canteen, Transport) Air & Water (Toilet & Shower, No ext cord, no food in rooms) Comfort (Storage, table & chairs, stove, fridge) Space (3.6 or 4.0, max 8 per room) 8. Workers Accommodation 46
9. Responsible Sourcing of Materials 47 Ensure rare earth minerals is sourced responsibly In line with OECD Due Diligence Conflict Minerals Policy & System Does not finance or benefit armed groups or other criminal organisations that are perpetrators of human rights abuse Tin, Tungsten, Tantalum and Gold Evidence of due diligence available on request Due Diligence in sourcing of minerals
10. CodeofConductImplementation 48 Management Accountability and Responsibility Legal and Customer Requirements Risk Assessment and Risk Management Communication Management Systems
Overview on Sedex Notforprofit CSRcomplianceinformationdatabase Riskassessments&auditmanagement A globaldatasharingplatformtokeeptrackofCSRcompliance incustomersupplychain OnlineEthical&Environmentalquestionnaires www.sedexglobal.com
Suppliers Join Sedexas B member CompleteSelf- Assessment Questionnaires (SAQ) SedexRisk Rating High/Medium/Low CSRAudit CorrectiveAction Plans Follow-up Audit Continuous Improvement
Suppliers: Registrationand next steps Join and Registeron Sedex www.sedexglobal.com Payfor B membership GBP100 per year or GBP300 for 3 years Create Site Details Link to C ustomers Set Access Rights to customers Complete the Self Assessment Questionnaire (SAQ) Risk Assessment
The SAQ Updateatleastevery 6 months (recommendedby Sedex) Completewithin2 weeks IMPORTANT! Incomplete SAQwill automaticaly rateyourcompanyas high risk. (Minimum90%questions shouldbeanswered) Rating result will be the basis of customer CSR Audit plan KEY THINGS YOU NEED TO KNOW ABOUT THE SELF ASSESSMENT QUESTIONNAIRES (SAQ) LabourStandards, Environmental(e.g.1SO 14001), Health&Safety (includingOHSAS 18001) andBusiness Practice TUV DEVELOPMENT SDN. BHD.
customer Policies Codeof Conduct Passport Access Policy CSRAudit Policy Zero RecruitmentFees Accommodation Standard 53
Potential Consequences Maysubjectto immediatesanctions up to andincluding cancellationof any PO or contract,in whole or in part, anrestrictions on future business Actiontobe taken Critical Violations must ceaseimmediately/ resolve immediately Within 48 hours, submit detailedandproactiveCAPaddressing all criticalviolations Critical Violations (Zero Tolerance) 54 1. Child Labour 2. Forced,bonded,indentured, slaveandillegal prison labour andhuman trafficking 3. Severehealth&safetyfindings thatcouldleadtoloss of life
APPROACH Announced Unannounced Audit TYPE Initial Periodical Re-Audit Unannounced CAP verification audits For failure to submit CAP or if CAP cannot be validated 55
49 Audit Scoring Grade Score Action A Acceptable (0-40) CAPclosure + Audit within 2 3 years B Acceptablewith concern (41-75) CAPclosure + Audit within 1 2 years C Needs Improvement (76-90) CAPclosure + Audit within 6 months 1 year D Critical (morethan 90) CAPclosure + Audit within 60 days+ potential business sanction Note: A Critical D score does not necessarily mean that a Critical Violation
Re-audits Three strikes policy For insufficient progress andfail re-audit TWICE (asabove),supplier will beautomaticallydelisted from supplying to customer Unannouncedre-audits For failure tosubmitCAPor if CAPcannotbe validated customersinterpretationoftheCoC,CSRauditpolicy andanyauditors reportis bindingandconclusive. Initial Audit Fail (D) 1st Strike 1st Re-Audit Fail (D) 2nd Strike 2nd Re-Audit Fail (D) 3rd Strike 50
CSR Policy & Requirement.pptx

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CSR Policy & Requirement.pptx

  • 1. 25th September 2019 Corporate Social Responsibility Policy
  • 2. Agenda Introduction Objective Why CSRis important? customer Ethical & Environmental Code of Conduct Supplier Approval flow SEDEX Audit Score & Grade Q&A 2
  • 3. Objective 1.0 Toenhance suppliers understanding about CSR and Code of Conduct (CoC)s requirement 2.0 Toincrease suppliers knowledge on how to preparefor Customer CSR audit 3.0 Toensure suppliers awareness about forced labour practise and laws relevant to the modern slavery and human trafficking 3
  • 6. 7
  • 7. 8 customer is about creating machines that 1) perform better, 2) energy efficient, 3) environmentally friendly, 4) manufactured ethically . customer has a responsibility for compliance 1) Shared with its suppliers in its supply chain 2) Create good working conditions 3) Minimal impact on the environment WHY CSR IS IMPORTANT TO CUSTOMER
  • 10. 10
  • 11. customer Code of Conduct Category 11
  • 12. 1. No ForcedLabour Freely Chosen Employment Zero Recruitment Fees Outsourced Labour Suppliers Full &Direct accessto personal identification documents Workers are free toterminate employmentby giving reasonable notice WITHOUT fear of penalty 12
  • 13. Offenceto keepworkers passport under Malaysia Passport Act1966 13
  • 15. Legislations on Forced Labour UK Modern Slavery Act 2015 Federal Acquisition Regulation California Transparency Act Trade Facilitation and Trade Enforcement Act 16
  • 17. Requirement RegardingtheFMW Employment Cycle No RecruitmentFees & Deposit On site recruitment (source country) Contract Transport Accommodation Wages Termination & Resignation
  • 19. EMPLOYMENT ACT 1955 Law, Practice & Compliance Employees Who are covered by the Act? Coverage What issues are covered by the Act? Questions & Answers What issues interest you? Definitions How significant are words used in the Act?
  • 20. EMPLOYEES protected by the Employment Act 1955 RM2,000 < WAGES RM5,000/MTH Limited to Sections 69(1)(a), 69B & 69C SEXUAL HARASSMENT All employees irrespective of wages FOREIGN EMPLOYEES Whose wages RM2,000/mth, or whose wages > RM2,000/mth but engaged in manual labour, etc. WAGES RM2,000/MTH Irrespective of occupation WAGES > RM2,000/MTH Engaged in manual labour, operate mechanically propelled vehicles, supervise manual labour, non-officer in a vessel registered in Malaysia & domestic servant. PROBATIONERS Whose wages RM2,000/mth, or whose wages > RM2,000/mth but engaged in manual labour, etc. PART-TIME EMPLOYEES Whose wages RM2,000/mth, or whose wages > RM2,000/mth but engaged in manual labour, etc. MATERNITY PROTECTION All female employees irrespective of wages
  • 21. Contract of service Termination of contract Administration of wages Protection of female employees Maternity protection Rest day Hours of work Public holidays Annual leave Sick leave Part-time employees Termination & lay-off benefits Foreign employees Registers & returns Sexual harassment COVERAGE OF THE EMPLOYMENT ACT 1955
  • 22. Child Worker Not completedageof15 Family Business Young Worker 15 years-18years< 7hours/day work Overtime andnight shift not allowed Break every 4hours No hazardous work 20 2. Child Labour
  • 23. 3. Working Hours, Wagesand Benefits Working hours should not be excessive 1 rest day in every 7daysperiod Overtime (Normal) doesnotexceed104 hours/ month Recommendation: Publish workinghours and break time on notice board 22
  • 25. 3. WorkingHours, Wages&Benefit WagesandBenefits accordingtolegal requirements Minimum Wage Order 2016 Overtime Calculation Annual Leave& Sick Leave benefits Paywages on time & provide payslip Proper Salary Deductions RelatedLaw:EmploymentAct1955, EmploymentRegulations 1957 25
  • 26. 26 AnnualandSick LeaveBenefits Length of Service Annual Leave Sick Leave Less than2years 8 days 14 days 2 years- less than5 years 12 days 18 days 5 yearsor more 16 days 22 days
  • 27. 4. GeneralLabour Practices 1. No Discrimination 2. Fair Disciplinary Practices 3. FreedomofAssociation 27
  • 28. 28
  • 29. 5. Health & Safety HIRARC Comply with relevant laws and regulations Give training PPE/Engineering Control/Management Control Takemeasures toprevent accident. Do due diligence
  • 30. OSHA 1994 30 Key Requirements: 1) Safety& Health Committeeformation 2) ChemicalHealth Risk Assessment (CHRA) 3) Notifications of Workplace Accidents
  • 31. FMA 1967 FM(Noise Exposure) Reg. 1989 FM (Safety, Health & Welfare) Reg. 1970 FM(Steam Boiler & Unfired Pressure Vessel) Reg. 1970 31 Key Requirements: 1) PPE usage 2) Toilet &drinking facility 3) First Aid 4) Ventilation, lighting, temperature suitable for workingcondition 5) Safetyprovision in termsfire fighting andemergencyevacuation
  • 33. CommonFindings ~ HSE Not wearing PPE Health and Safety Meeting Fire Certificate availability Emergencydoor blocked, pathwayblocked Emergencyexit door lockedwith keyin break glass box Emergency Light Praying room and washingarea must beseparated with gender PPEvisualreminder Canteen operators attire Evacuation map Fire hose without key First Aid box requirements Noise monitoring Scheduled Waste- labelled and segregated accordingly SDS Expired, readiness Forklift Training record,license and checklist and inspection Competent Person for Scheduled Waste &Waste Water Warehouse/Store stacking-Wrap Toilet soap, Tissue and capacity Recycling/ Scrap Workers
  • 34. Examples of DOs & DONTs when working in manufacturing company
  • 35. Wear safety goggles Wear safety footwear Wear safety gloves Wear safety mask Wear Ear Protection DOS Wear safety helmet
  • 36. Electric Hazard! Dont Touch No Smoking Hot Surfaces! Dont Touch Dont Throw Trash into Toilet No Foods Allowed DONTS
  • 37. Examples of DOs & DONTs when staying in company hostel
  • 38. CLOSE YOUR TAPS AFTER USE FLUSH TOILET AFTER USE KEEP LOCKED WHEN NOT IN USE DOS THROW RUBBISH INTO DUSTBIN DIRECTION ON USING FIRE EXTINGUISHER PLEASE QUEUE UP
  • 39. NO PETS ALLOWED NO OVERLOADED PLUGGING NO SPITTING NO ENTRY NO CANDLES ALLOWED NEAR BED DONTS NO ALCOHOL
  • 40. Food Legislation Food Act 1983 Food Regulations 1985 Food Hygiene Regulations 2009 Key Requirements: 1) Registration of foodpremises 2) Conductandmaintenanceoffood premises 3) Food handler 4) Requirementsandprocedure in handling, preparing, packing, serving, storing andselling of food 40
  • 41. 6. Anti-Bribery & Transparency Free &full AccessFactory,hostel, etc Confidential Interviews No bribery, corruption or unethical practices Whistleblowing channel/program No retaliation policy 41
  • 42. 7. The Environment Supplier must ensure thattheir operation is not negativelyimpactingthe environment. Must beable tomeasure, control, andwhere everpossible, reducetheir environmentalimpact
  • 43. Environmental Quality Act1974 Environmental Quality (Scheduled Wastes) Regulations 2005 Environmental Quality (Amendment)Act 2012 Environmental Quality (Clean Air) Regulation 2014 43 Key Requirements: 1) Environmental monitoring air, water, noise 2) Scheduled/hazardous wastemanagement 3) Environmental Permits andReporting
  • 44. 44
  • 45. 45
  • 46. Well maintained Fit for Purpose (CF,H&S, Canteen, Transport) Air & Water (Toilet & Shower, No ext cord, no food in rooms) Comfort (Storage, table & chairs, stove, fridge) Space (3.6 or 4.0, max 8 per room) 8. Workers Accommodation 46
  • 47. 9. Responsible Sourcing of Materials 47 Ensure rare earth minerals is sourced responsibly In line with OECD Due Diligence Conflict Minerals Policy & System Does not finance or benefit armed groups or other criminal organisations that are perpetrators of human rights abuse Tin, Tungsten, Tantalum and Gold Evidence of due diligence available on request Due Diligence in sourcing of minerals
  • 48. 10. CodeofConductImplementation 48 Management Accountability and Responsibility Legal and Customer Requirements Risk Assessment and Risk Management Communication Management Systems
  • 49. Overview on Sedex Notforprofit CSRcomplianceinformationdatabase Riskassessments&auditmanagement A globaldatasharingplatformtokeeptrackofCSRcompliance incustomersupplychain OnlineEthical&Environmentalquestionnaires www.sedexglobal.com
  • 50. Suppliers Join Sedexas B member CompleteSelf- Assessment Questionnaires (SAQ) SedexRisk Rating High/Medium/Low CSRAudit CorrectiveAction Plans Follow-up Audit Continuous Improvement
  • 51. Suppliers: Registrationand next steps Join and Registeron Sedex www.sedexglobal.com Payfor B membership GBP100 per year or GBP300 for 3 years Create Site Details Link to C ustomers Set Access Rights to customers Complete the Self Assessment Questionnaire (SAQ) Risk Assessment
  • 52. The SAQ Updateatleastevery 6 months (recommendedby Sedex) Completewithin2 weeks IMPORTANT! Incomplete SAQwill automaticaly rateyourcompanyas high risk. (Minimum90%questions shouldbeanswered) Rating result will be the basis of customer CSR Audit plan KEY THINGS YOU NEED TO KNOW ABOUT THE SELF ASSESSMENT QUESTIONNAIRES (SAQ) LabourStandards, Environmental(e.g.1SO 14001), Health&Safety (includingOHSAS 18001) andBusiness Practice TUV DEVELOPMENT SDN. BHD.
  • 53. customer Policies Codeof Conduct Passport Access Policy CSRAudit Policy Zero RecruitmentFees Accommodation Standard 53
  • 54. Potential Consequences Maysubjectto immediatesanctions up to andincluding cancellationof any PO or contract,in whole or in part, anrestrictions on future business Actiontobe taken Critical Violations must ceaseimmediately/ resolve immediately Within 48 hours, submit detailedandproactiveCAPaddressing all criticalviolations Critical Violations (Zero Tolerance) 54 1. Child Labour 2. Forced,bonded,indentured, slaveandillegal prison labour andhuman trafficking 3. Severehealth&safetyfindings thatcouldleadtoloss of life
  • 55. APPROACH Announced Unannounced Audit TYPE Initial Periodical Re-Audit Unannounced CAP verification audits For failure to submit CAP or if CAP cannot be validated 55
  • 56. 49 Audit Scoring Grade Score Action A Acceptable (0-40) CAPclosure + Audit within 2 3 years B Acceptablewith concern (41-75) CAPclosure + Audit within 1 2 years C Needs Improvement (76-90) CAPclosure + Audit within 6 months 1 year D Critical (morethan 90) CAPclosure + Audit within 60 days+ potential business sanction Note: A Critical D score does not necessarily mean that a Critical Violation
  • 57. Re-audits Three strikes policy For insufficient progress andfail re-audit TWICE (asabove),supplier will beautomaticallydelisted from supplying to customer Unannouncedre-audits For failure tosubmitCAPor if CAPcannotbe validated customersinterpretationoftheCoC,CSRauditpolicy andanyauditors reportis bindingandconclusive. Initial Audit Fail (D) 1st Strike 1st Re-Audit Fail (D) 2nd Strike 2nd Re-Audit Fail (D) 3rd Strike 50