supplier name: unicart eood site country: bulgaria ...audit company: intertek ba eood report...

Audit company: INTERTEK BA EOOD Report reference: A4475560 Date: 14-15 May 2015 1

Supplier name: UNICART EOOD

Site country: BULGARIA

Site name: MULTIPRINT OOD

Parent Company name (of the site): N/A

SMETA Audit Type: 2–Pillar 4–Pillar

Date of Audit 14 - 15th of May 2015


Audit Company Name: INTERTEK BA Report Owner (payee): UNICART EOOD

Sedex Company Reference:(only available on Sedex System):

S: Not available – Facility is not yet registered in theSedex System and Sedex platform

Sedex Site Reference:(only available on Sedex System)

P: Not available – Facility is not yet registered in theSedex System and Sedex platform

Audit Conducted By

Commercial Purchaser

NGO Retailer

Trade Union Brand Owner

Multi–stakeholder Combined Audit (select all that apply)

Auditor Reference Number:(If applicable) N/A

SMETA DeclarationI declare that the audit underpinning the following report was conducted in accordance withSMETA best practice guidance.

Any exceptions to this must be recorded here (e.g. different sample size): None

Auditor Name(s) (please list all including all interviewers):Lead auditor: Gergana GeorgievaAuditor: Veronika GrozdanovaInterviewers: Gergana Georgieva – Lead Auditor; Veronika Grozdanova – Auditor.

Date: 15 May 2015


Non–Compliance Table

Issue(please click on the issue title to go direct to

the appropriate audit results by clause)

Area of Non–Conformity(Only check box when there is a non–conformity,and only in the box/es where the non–conformity

van be found)

Record the numberof issues by line*:

ETI BaseCode Local Law

AdditionalElements

(i.e. not partof ETI code )

NC Obs GE

0 Management systems and codeimplementation

0 1 0

1 Employment Freely Chosen 0 0 0

2 Freedom of Association 0 0 0

3 Safety and Hygienic Conditions 3 0 0

4 Child Labour 0 0 0

5 Wages and Benefits 0 0 1

6 Working Hours 0 0 0

7 Discrimination 0 0 0

8 Regular Employment 0 0 0

8A Sub–Contracting andHomeworking

0 0 0

9 Harsh or Inhumane Treatment 0 0 0

10A Entitlement to Work 0 0 0

10B2 Environment 2–Pillar 0 0 0

10B4 Environment 4–Pillar 0 0 0

10C Business Ethics 0 0

*Please note the table above records the total number of Non compliances (NC), Observations (Obs) and GoodExamples (GE). This gives the reviewer an indication of problem areas but does not detail severities of each issue –Reviewers need to check audit results by clause.


Summary of FindingsSummary of main findings: (positive and negative)(Please give a short summary of the main findings per clause)

This audit was conducted by two auditors in 2.5 days.During the audit company operations were assessed against the ETI Base Code and the requirements of Bulgariannational and local legislation. The audit was SMETA 4 PILLAR.

Audit started at 9:00 a.m. on the 14th of May with an opening meeting during which the Lead Auditor explained theaudit process. The factory was represented by:

1. Yordan Bonchev - General Manager;2. Elena Boncheva – Marketing manager3. Temenuga Paunova – HR officer4. Georgi Ivanov – H & S officer

The audit team was presented by:1. Gergana Georgieva – Lead Auditor;2. Veronika Grozdanova – Auditor.

The overall social compliance responsible person at the facility is Elena Boncheva.26 time and payroll records were reviewed as a part of the audit process: for November 2014 (peak); February 2015(low); and March 2015 (last paid period). The main products manufactured by the factory are printed materials –leaflets, books, magazines, postcards, calendars, posters, etc. Processes are receiving the raw materials, pre-press, printing, cutting, folding, binding, quality control, packaging of finished products, storage of the finishedproducts, storage of finished products. . Total number of employees is: 252 (165 production employees and 87management and administrative staff). Male employees are total of 136, female employees are total of 116. Theyoungest employee in the facility is male production worker, 20 years old, who was born in 1995. There are nomigrant workers employed by the facility. All workers are directly employed in the facility, there are no external HRagencies used. There is peak season in production October and November – calendars, Christmas campaigns.Standard maximum regular hours are 8 hours per day, 40 hours per week and 160 hours per month. 5 workingdays, from Monday to Friday, 2 rest days – Saturday and Sunday. During the audit, based on the sampled payrolland time records and workers interviews it was noted, that there are no overtime hours, performed in the facility.Based on the sample the lowest wage observed is 538.35 BGN net per month, and the highest wage observed is1066.79 BGN net per month.

During the audit a nice and calm environment was experienced. Management was very cooperative and supportivefor the conduction of the audit. The attitude toward the auditors was excellent. Access was granted to all facilitypremises and relevant documentation for review. Photos were taken, upon the permission of the Management.Workers interviews were conducted privately, without the presence of the Management. During the audit no forms ofchild labour, forced labour, prison labour, discrimination, sexual harassment or any other forms of criminal behaviourwere observed. There were no forms of bribery attempts, corruption or aggressive behaviour toward the auditors.During the audit 3 non-conformities and one observation were observed and raised. Good examples were alsonoted as below.

Non-conformities:

3: Working Conditions are Safe and Hygienic1) During the facility tour, It was noted that the emergency evacuation escape routes are not marked in

production unit 3.

2) During the facility tour it was noted that 2 out of 84 fire extinguishers were blocked in the main printing hall,


first floor.3) During the facility tour it was noted that there were 3 bottles with chemicals, left unattended and found in

close range to machines in 2 production units.Observations noted:

1) During the audit, it was noted that the new version of ETI Base Code is not communicated to supply chain.

Good examples noted:5: Living Wages are paid

1) Additional bonuses are provided for all workers – food stamps, bonuses.

Additional auditor remark:

This is the first SMETA 4 Pillar audit for the facility. It has passed a Disney Social compliance audit. Facility hasQMS ISO 9001:2008 (certificate issued by Certification International on 31.08.2012 valid until 30.08.2015).


Audit DetailsAudit Details

A: Report #: A4475210

B: Time in and time out(SMETA Best Practice Guidance recommends9.00–17.00 hrs. if any different please state whyin the SMETA declaration )

Day 1 Time in: 09:00Day 1 Time out:18:00

Day 2 Time in: 09:00Day 2 Time out:13:00

Day 3 Time in:N/ADay 3 Time out:N/A

C: Number of Auditor Days Used:(number of auditor x number of days)

1 Lead auditor x 1.5 days1 auditor x 1 day

D: Audit type: Full InitialPeriodicFull Follow–upPartial Follow–UpPartial Other – Define

E: Was the audit announced? (AAGrecommends a window of three weeks for semi–announced, this gives optimum results)

AnnouncedSemi – announced:Unannounced

F: Was the Sedex SAQ available forreview?

YesNo

If No, why not?(Examples would be, site has not completedSAQ, site has not been asked to complete theSAQ.)

Facility is not yet registered in the Sedex System and Sedex platform,therefore the Sedex SAQ was not completed and available for review.

G: Any conflicting information SAQ/Pre-Audit Info to Audit findings?

YesNo

If Yes, please capture detail in appropriate audit by clauseN/A - Facility is not yet registered in the Sedex System and Sedex

platform, therefore the Sedex SAQ was not completed and available forreview.

H: Auditor name(s) and role(s): Gergana Georgieva, Lead auditor; Veronika Grozdanova - Auditor

I: Report written by: Gergana Georgieva, Lead auditor

J: Report reviewed by: Veronika Grozdanova, Tatyana Takeva

K: Report issue date: 22.05.2015

L: Supplier name: UNICART EOOD

M: Site name: MULTIPRINT OOD


N: Site country: BULGARIA

O: Site contact and job title: Yordan Bonchev – General Manager

P: Site address:(Please include full address)

10a Slavyanska Blvd., Kostinbrod / Bulgaria

Site phone: +359-721-66245

Site fax: +359-721-66248

Site e–mail: [email protected]

Q: Applicable business and other legallyrequired licence numbers:for example, business license no, andliability insurance

122013040, no validity period.

R: Products/Activities at site, for example,garment manufacture, electricals, toys,grower

Production of printed materials – leaflets, books, magazines, postcards,calendars, posters, etc.

S: Audit results reviewed with sitemanagement?

Yes

T: Who signed and agreed CAPR(Name and job title)

Yordan Bonchev – General Manager

U: Did the person who signed the CAPRhave authority to implement changes?

Yes

V: Previous audit date: 11 May 2014

W: Previous audit type: SMETA 2–pillar

SMETA 4–pillar

Other

Full Initial

Periodic

Full Follow–UpAudit

Partial Follow–Up

Partial Other*

*If other, please define: Disney Social compliance audit.


Audit Scope/Actual ResultsCriteria Local Law

(Please state legalrequirement)

Actual at theSite

(Record site resultsagainst the law)

Is this part of aCollectiveBargaining

Agreement?

A: Standard/Contracted work hours:(Maximum legal and actual required working hours excludingovertime, please state if possible per day, week and month)

Legal maximum:(As per BulgarianLabour Code,Art.136, Para.1-3)- 8 hours per day- 40 hours perweek

- 8 hours per day- 40 hours perweek

- 161 hours permonth – average- 184 hours permonth - maximum

YesNo

No Trade Unionand no CollectiveBargainingAgreement in thefacility.

B: Legal Overtime hours:(Maximum legal and actual overtime hours, please state ifpossible per day, week and month)

Legal maximum:(As per BulgarianLabour Code,Art.146, Para.1-2)- 6 hours perweek- 30 hours permonth- 150 hours peryear

During the audit,based on thesampled payrolland time recordsand workersinterviews it wasnoted, that thereare no overtimehours, performedin the facility.

YesNo


C: Legal age of employment:(Minimum legal and actual minimum age at site)

Legal minimum:18 years

20 years

D: Legal minimum wage for standard/contracted hours:(Minimum legal and actual minimum wage at site, please stateif possible per hr, day, week and month)

Legal minimum:As per Bulgariangovernment legalact (RegulationNo. 419/17December 2014)the legalminimum wagefor Bulgaria is360 BGN(Bulgarian Leva)gross per month.

Based on thesample taken, thelowest wageobserved is538.35 BGN netper month.

YesNo


E: Legal minimum overtime wage:(Minimum legal and actual minimum overtime wage at site,please state if possible per hr ,day, week and month)

Legal minimum:(As per BulgarianLabour Code,Art.262, Para.1)

As per thesample payrolland time recordsreviewed, and

YesNo

No Trade Union


+50% for weekdays+75% for restdays+100% forholidays

verified by theworkersinterviews and bythe Management,there are noovertime hours inthe facility.

and no CollectiveBargainingAgreement in thefacility.

Audit Scope(Please select the code and additional requirements that were audited against during this audit)

2–Pillar Audit

10B4: Environment 4–Pillar

10C: Business Ethics

All groups of workers are included in the scope of this audit such as; Direct employees, Casualand agency workers, Workers employed by service providers such as security and catering staffas well as workers supplied by other contractors.

All workers aredirectly employedby the facility

Note: The main focus of this ethical audit is on the ETI Base Code and local law. The additional elements will not be audited in suchdepth or scope, but the audit process will still highlight any specific issues.

This report provides a summary of the findings and other applicable information found/gathered during the social audit conductedon the above date only and does not officially confirm or certify compliance with any legal regulations or industry standards. Thesocial audit process requires that information be gathered and considered from records review, worker interviews, managementinterviews and visual observation. More information is gathered during the social audit process than is provided here. The auditprocess is a sampling exercise only and does not guarantee that the audited site prior, during or post–audit, are in full compliancewith the Code being audited against. The provisions of this Code constitute minimum and not maximum standards and this Codeshould not be used to prevent companies from exceeding these standards. Companies applying this Code are expected to complywith national and other applicable laws and where the provisions of law and this Code address the same subject, to apply thatprovision which affords the greater protection. The ownership of this report remains with the party who has paid for the audit.Release permission must be provided by the owner prior to release to any third parties.


Audit OverviewAudit Overview

Management Worker Representatives

Audit attendance Senior management Worker Committeerepresentatives

Union representatives

A: Present at the opening meeting? Yes No Yes No Yes No

B: Present at the audit? Yes No Yes No Yes No

C: Present at the closing meeting? Yes No Yes No Yes No

D: If Worker Representatives were notpresent please explain reasons why(only complete if no worker reps present)

Not applicable

E: If Union Representatives were notpresent please explain reasons why:(only complete if no union reps present)

There is no trade union in the facility.

F: Site description:(Include size, location and age of site. Alsoinclude structure and number of buildings)

MULTIPRINT OOD is located at 10a Slavyanska Blvd.., 2230Kostinbrod, BulgariaThe facility was founded in 1996. The main products manufactured bythe factory are printed materials – leaflets, books, magazines,postcards, calendars, posters, etc. Total number of employees is 252(165 production employees and 87 management and administrativestaff). Male employees are total of 136, female employees are total of116. Production capacity – 250 000 pieces per month.

There are no migrant workers and no agency workers employed in thefacility. All workers are ethnic Bulgarians with Bulgarian citizenship.All workers are directly employed by the facility. There are no externalHR agencies used. The youngest worker is a male employee 20 yearsold who is born in 1995 and hired in February 2015.Working hours are organised as follows: There are two regular shifts forproduction workers from 05:30 to 14:00 and from 14:00 to 22:15, 8hours per day, five days per week, from Monday to Friday, with one 30minutes break and one or two breaks of 15 minutes. Saturday andSunday are rest days.Management and administration, work from 08:00 to 17:00, 8 hours perday, five days per week, from Monday to Friday, with one 30 minutesbreak from 12:00 to 12:30. Saturday and Sunday are rest days.

The facility has 9 buildings. They are made of concrete and metal, verywell maintained and secured. Each production building has sufficientnumber of restrooms; there are also administration offices, canteen andstorage area. The total area of the facility is 23 148 square meters.There is no peak season in production. Pay Period: twice per month –the 10th and 25th date of the following month. Last paid full salary is for


the month of March 2015. Wages are calculated monthly. Electronictime recording system is in use for registration of working hours.

Facility buildingpremises 1

Description Remark, if any

Floor 1 production area ,toilets

Year ofEstablishment: 1994

Floor 2Administrationoffices, conferencerooms, toilets


Is this a sharedbuilding? No none



Floor 1 storage area Year ofEstablishment: 1994












Floor 1 canteen andrestroom





Floor 1 production area Year ofEstablishment: 1994





Is this a shared No none


building?









G: Site function: AgentFactory Processing/ManufacturerFinished Product SupplierGrowerHomeworkerLabour ProviderPack HousePrimary ProducerService ProviderSub–Contractor

H: Month(s) of peak season:(if applicable)

Peak season in production is October and November – calendars,Christmas campaigns

I: Process overview:(Include products being produced, main operations, number of production lines, main equipment used)

The main products manufactured by the factory are printed materials – leaflets, books, magazines, postcards,calendars, posters, etc.Processes are receiving the raw materials, pre-press, printing, cutting, folding, binding, quality control, packaging offinished products, storage of the finished products.

The main machine list of the factory is as following (59 machines):11 pre-press machines11 printing machines7 folding machines18 cutting machines12 machines for packaging

The factory does not use subcontractors.

J: Attitude of workers:(Include their attitude to management, workplace and the interview process. Both positive and negative information should beincluded) Note: Do not document any information that could put workers at risk

General attitude of the employees was very positive.


26 workers were selected for interview including 11 male and 15 female employees; they were interviewed in 6individual interviews and 5 groups of 4 workers.

The workers were assured of confidentiality and they spoke freely of their views of the factory. All workers said theywere very satisfied with their employment at the factory and with the current wages which in their opinion are in linewith the wages in the country. They feel free to leave this employer and understand the notice period required. Theyhave good relationships with their supervisors and managers who treat them with respect.

They are able to make suggestions to their management directly or using the suggestion box, located in the facility.They feel able to complain directly to their supervisors, but also feel free to give their general concerns to the workingconditions committee.

Workers interviews were conducted privately, without the presence of the Management. During the audit no forms ofchild labour, forced labour, prison labour, discrimination, sexual harassment or any other forms of criminal behaviourwere observed.

K: Attitude of workers committee/union reps:(Include their attitude to management, workplace and the interview process. Both positive and negative information should beincluded) Note: Do not document any information that could put workers at risk

General attitude of the Worker representative was very positive.Based on the interview with the worker representative Mr.Georgi Vassilev it was noted that there is no Trade Unionpresented in the facility and no Collective Bargaining agreement in place.Additional bonuses are provided for all workers – food stamps, bonuses.

L: Attitude of managers:(Include attitude to audit, and audit process. Both positive and negative information should be included)

Management was helpful and supportive during the audit process. During the audit a nice and calm environment wasobserved. The attitude toward the auditors was very good. Access was granted to all facility premises and relevantdocumentation for review. Photos were taken, upon the permission of the Management. There were no forms ofbribery attempt, corruption or aggressive behaviour toward the auditors.


Key InformationKey Information

(click on the key information title to go to appropriate section of the report)

A: Do all workers (including migrant workers)have contracts of employment/employmentagreements?(Go to clause 8 – Regular Employment)

YesNo

B: Are maximum standard/contractedworking hours clearly defined incontract/employment agreements?(Go to clause 8 – Regular Employment)

YesNo

C: Were appropriate records available toverify hours of work and wages?(Go to clause 5 – Living Wage)

YesNo

D: Were any inconsistencies found?(if yes describe nature)(Go to Wages Table)

Yes Poor record keepingNo Isolated incident

Repeated occurrence

E: For the lowest paid production workers,are wages paid for standard/contractedhours (excluding overtime) below or abovethe legal minimum?(Go to clause 5 – Living Wage)

Wages found: Please indicate the breakdown of workforceaccording to earnings:

Below legalmin

MeetAbove

__0__% of workforce earning under min wage

_0___% of workforce earning min wage_100___% of workforce earning above min wage

F: % of piece rate workers:(if applicable)

Not applicable

G: Do the standard/contracted hours statedin a contract/employment agreement exceedthe law or 48 hours per week?(Go to clause 6 – Working hours)

YesNo

H: If yes, what are the standard/contractedhours per week as stated in thecontract/employment agreement?(Go to clause 6 – Working hours)

_____ hrs/week

N/A

Approx. ____% of ALL workers on these contactedhours

N/A

I: Combined hours (standard/contracted plusovertime = total hours) over 60 per weekfound?(Go to Working Hours Analysis)

YesNo

J: Are workers provided with 1 day off inevery 7-day-period, or 2 in 14-day-period(where the law allows)?

1 day in every 7-day-period2 days in every14-day-periodOther


If ‘Other’, please explain: N/A

K: Are the correct legal overtime premiumspaid?(Go to Wages Table)

YesNoN/A – no overtime hours were observed during the audit based on

the documents review and the workers’ interviews

L: Please state what actual OT is paid.(As a percentage of the workers standard rate)(Go to Working Hours Analysis)

Please give details of overtime premium as a % of standard wages:0%Up to 115%116% – 124%125% – 199%200%+

N/A– no overtime hours were observed during the audit based on thedocuments review and the workers’ interviews

M: Is there any night production work at thesite?

YesNo

N: % of workers living in site providedaccommodation (if applicable):

Not applicable, no dormitories provided and/or operated by the facility

O: Age of youngest worker found:(Go to clause 4 – Child labour)

20 years

P: Workers under 18 subject to hazardouswork assignments?(Go to clause 3 – Health and Safety)

YesNo

% of under 18’s at this site (of total workers) 0 %

Q: What form of worker representation/unionis there on site?(Go to clause 2 – Freedom of Association)

UnionWorker CommitteeOther (specify)None

R: Is it a legal requirement to have a union?(Go to clause 2 – Freedom of Association)

YesNo

S: Is It a legal requirement to have a workerscommittee?(Go to clause 2 – Freedom of Association)

YesNo

T: Is there any other form of effectiveworker/management communicationchannel?(Go to clause 2 – Freedom of Association)(Other than union/worker committee)

YesNo

Describe: Grievance procedure and suggestion box are in place.Workers are aware of these channels and they know how to use them.

U: Are there any External Processes?(Go to clause 8A – Sub–contracting and Homeworking)

Sub–ContractingHomeworkingOther External ProcessNo external processes


Management SystemsManagement Systems:

A: Nationality of Management Bulgarian

B: Gender breakdown of Management +Supervisors (Include as one combined group)

Male: 60%Female: 40%

C: Majority nationality of workers Bulgarians

D: Number of workers leaving in last 12months as a % of average total number ofworkers on site over the year (annual workerturnover)

44 workers left in January-December 2014 (16%)

57 newly recruited workers in January-December 2014 (20%)

E: Were accurate records shown at the firstrequest?

YesNo

F: If No, why not? N/A

G: In the last 12 months, has the site beensubject to any fines/prosecutions for non–compliance to any regulations?

YesNo

Please describe:

H: Do policies and/or procedures exist thatreduce the risk of forced labour, child labour,discrimination, harassment & abuse?

YesNo

Please describe: Internal Rules Handbook which integrates the mainprinciples and clauses of ETI Base code and relevant local laws andprohibits child labour, forced labour, prison labour, discrimination,sexual harassment and abuse. Grievance procedure for anonymouscomplaints is in place in the facility.

I: If Yes, is there evidence (an indication) ofeffective implementation? Please givedetails.

The Internal Rules Handbook and ETI Base code are respected. Allworkers are aware of their principles. Copies of ID cards are kept in theworkers files. All workers are familiar with their job description.

J: Have managers and workers receivedtraining in the standards for forced labour,child labour, discrimination, harassment &abuse?

YesNo

Please describe: Regular trainings are conducted, with the support ofthe company which conducts the regular risk assessment of the facility.Regular meetings are conducted as well for awareness of the workersand managers in these standards once in every three months.

K: If Yes, is there evidence (an indication)that training has been effective e.g. trainingrecords etc.? Please give details

Written statement for conducted training – 04 July 2014. Following thetraining the procedures for forced labour, child labour anddiscrimination have been updated.

L: Are there published, anonymous and/oropen channels available for reporting anyviolations of Labour standards and H&S orany other grievances to a 3rd party?

YesNo

Please describe: There is a Suggestion box, located in the facility.There is procedure implemented for opening and reviewing the signals


from the suggestion box, which is part of the internal rules of thefacility. The suggestion box is opened regularly – twice per month.

M: If Yes, are workers aware of thesechannels? Please give details.

Yes. Workers are aware of this suggestion box and they know how touse it, which was confirmed during the workers interviews.

N: Have health and safety risks beenidentified e.g. through internal audits, formalrisk analysis process, worker involvementetc.?

YesNo

Please describe: Risk assessment of the workplaces – latest update:February/March 2015.

O: If Yes, has effective action been taken toreduce or eliminate these risks?

Program to reduce the risk is prepared and implemented.Safety instructions are available to workers.PPE are provided to workers.Regular trainings are provided to all workers.

P: Are accidents recorded? YesNo

Please describe: A Injury log is available at the facility, registered withthe local authorities. No accidents are registered.

Q: Has the auditor made a simple calculationto compare capacity with workers’ work loadin order to identify possible unrecorded workhours?

YesNo

Please describe:Workers are operating production machines and there is no norm ofwork for them per day. This means that their work is recorded by thehours worked not by the production. Auditors crosschecked theproduction records with the machinery and workforce on site andconcluded that there are no unrecorded work hours or processes.

R: Does the site have all required land rightslicenses and permissions (see SMETA BestPractice Guidance)?

Business Licence – No. 1220130440 no validity periodBuilding construction and site plan – latest update from March, 2015.Fire Safety certificates and permits – latest update from November,2014.

S; Does the site have any internationallyrecognised system certifications e.g. ISO9000, 14000, OHSAS 18000, SA8000 (orother social audits).Please detail (Number and date).

QMS ISO 9001:2008 (certificate issued by Certification International on31.08.2012 valid until 30.08.2015).

T: Is there a Human Resourcesmanager/department?If Yes, please detail.

YesNo

Please describe: Mrs. Temenuga Paunova is HR manager at thefacility.


Worker Analysis

Worker Analysis

Local MigrantTotal

Permanent Temporary Agency Permanent Temporary Agency Homeworkers

Worker numbers –male 136 0 0 0 0 0 0 136

Worker numbers –female 116 0 0 0 0 0 0 116

Total 252 0 0 0 0 0 0 252

Number of Workersinterviewed 26 0 0 0 0 0 0 26

Contractors:(Individuals supplying workers to site with the workers paid by contractors, not by site)

A: Any contractors on site? YesNo

B: If Yes, how many workers supplied bycontractors N/A

C: Are all contractor workers paid accordingto law?

YesNoN/A

If Yes, Please give evidence for contractorworkers being paid according to law: N/A

Migrant Workers:(Please see SMETA Best Practice Guidance for definitions of migrant workers)

D: OriginatingLocations/Countries:

N/A

E: Type of work undertaken bymigrant workers :

N/A

F: Were migrant workersrecruited through an agency?If yes, please give details.

YesNo

Please describe: N/A


If Yes, is there a contract withthe agency? Provide details ofagencies and contractualarrangements including any feeslodged during the recruitmentprocess.

N/A

G: Does the site have a systemfor checking labour standards ofagencies?If yes, please give details.

YesNo

Please describe: N/A – The facility directly hires employees and does not use alabour agency.

H: Percentage of migrantworkers in company providedaccommodation:

N/A – There are no dormitories provided and/or operated by the facility


Audit Results by Clause0: Management systems and Code Implementation

0: Managements system and Code Implementation(click here to return to NC Table)

0.1 Suppliers are expected to implement and maintain systems for delivering compliance to this Code.0.2 Suppliers shall appoint a senior member of management who shall be responsible for compliance with the Code.0.3 Suppliers are expected to communicate this Code to all employees.0.4 Suppliers should communicate this code to their own suppliers and, where reasonably practicable, extend theprinciples of this Ethical Code through their supply chain.

Current Systems and Evidence ExaminedTo complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, tounderstand, and record what controls and processes are currently in place e.g. record what policies are in place, what relevant

procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail anydocumentary or verbal evidence shown to support the systems.

Current systems:HR matters of the facility are handled by Mrs. Temenuga Paunova – HR manager.The company regularly tracks and analyses the turnover rates, absence rates and number of grievances. 57 workershave started working in the company, since January 2014 until the date of this audit. Mrs. Paunova is responsible toinform the facility management for all legal updates, related to employment.Internal checks of the HR documentation and personal files are conducted regularly, at least once a month. Mrs.Paunova works actively with the Workers Committee. She is also responsible for monitoring the working hours andremuneration of the workers. Facility has adopted its ETI Base Code and workers are aware of its requirements.Management has regular meetings with Workers Committee once in every six months.

During the audit it was observed that the facility has not communicated the ETI Base Code in appropriate manner toall suppliers and subcontractors.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate): Written statement for the establishment of Workers Committee, 07 January 2014 Meeting records of worker committee – 13.05.2015 Training records of worker committee – 04.07.2014 Grievance mechanism and procedures – latest update from January 2015. Internal Rules Handbook from January 2011 – last update from January 2015 Procedure for hiring workers – last update from January 2015 Resignation records for the worker turnover statistics Grievance mechanism and procedures – last update from January 2015 Policy against discrimination part of the Internal Rules Handbook, last update from January 2015 Policy for prohibition of child labor and remediation in cases of child labor part of the Internal Rules Handbook –

last update from January 2015 Anticorruption policy part of the Internal Rules Handbook last update from January 2015 QMS ISO 9001:2008 (certificate issued by Certification International on 31.08.2012 valid until 30.08.2015).

Non–compliance:


1. Description of non–compliance:NC against ETI/Additional Elements NC against Local Law

None observed.

Local law and/or ETI requirement:Not applicable.

Objective evidenceobserved:(where relevant please addphoto numbers)

Not Applicable

Observation:

Description of observation:None observed.

Local law or ETI requirement:Not applicable.

Comments:Not applicable.

Objective evidenceobserved:

Not Applicable

Good Examples observed:

Description of Good Example (GE):None observed.

Objective evidenceobserved:Not Applicable


1: Employment is Freely Chosen

1: Employment is Freely Chosen(Click here to return to NC–table)

ETI1.1 There is no forced, bonded or involuntary prison labour.1.2 Workers are not required to lodge “deposits” or their identity papers with their employer and are free toleave their employer after reasonable notice.

Current Systems and Evidence ExaminedTo complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, andrecord what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, whois/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to

support the systems.

Current systems:Workers are recruited through a job advertisement published in the local newspaper and local state labour authorities.Workers are selected, based on their professional qualification and experience. All employees have a job interview,prior to starting job. All workers have signed individual labour contracts for employment.No Labour Agents are used.Workers resign with 1 month notice.The facility has its own Internal Rules Handbook, which includes prohibition of forced labour and prison labour,discrimination and sexual harassment.Responsible manager for HR matters regularly checks all personal files, to guarantee that no personal documents arekept on site. No loans are given to employees. This was also confirmed during the interviews.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate): Internal Rules Handbook – latest update from January 2015 Procedure for hiring workers – latest update from January 2015. All employees’ files contain Job Description, signed individual labor contract and other documents, as required by

the law. Employees files for 26 workers reviewed. Employees confirmed they are free to leave their employer after reasonable notice, there is no forced labor, no

deposits or withheld ID cards. Policies for prohibition of forced labor, prison labor, discrimination and sexual harassment – latest update from

January 2015 Mrs. Temenuga Paunova – HR, manager is responsible for this chapter of the code

Non–compliance:

1. Description of non–compliance:NC against ETI NC against Local Law:

None observed.

Local law and/or ETI requirementNot applicable.

Recommended corrective action:Not applicable.


Not Applicable


Observation:

Description of observation:None observed



Objective evidenceobserved:Not Applicable.



Objective evidenceobserved:Not Applicable.


2: Freedom of Association and Right to Collective Bargaining are Respected

2: Freedom of Association and Right to Collective Bargaining are Respected(Click here to return to NC–table)

(Click here to return to Key Information)

ETI2.1 Workers, without distinction, have the right to join or form trade unions of their own choosing and to bargaincollectively.2.2 The employer adopts an open attitude towards the activities of trade unions and their organisational activities.2.3 Workers’ representatives are not discriminated against and have access to carry out their representativefunctions in the workplace.2.4 Where the right to freedom of association and collective bargaining is restricted under law, the employerfacilitates, and does not hinder, the development of parallel means for independent and free association andbargaining.



Current systems:Based on the Management interview, workers interview and documents review, it was noted that there is no TradeUnion formed in the facility, and no Collective Bargaining Agreement in place. During the interviews workers statedthat they feel free to join a union if and whenever interested in such representation.There is Worker Committee established in the facility, which deals with all matters, related to workers rights in thework place. The Workers Committee is established on 07January 2014, and it consists of 1 representative of theManagement and 7 members, freely elected by the workers. The current members are Yordan Belchev – GeneralManager, Georgi Vassilev – Chairman, Bisser Vladimirov, Gabriela Georgieva, Petrana Antonova, MarioGrozdanov - workers. The Workers Committee conducts regular meetings, once in every 3 months. Latest meetingwas conducted on 13 May 2015. During the workers interviews it was confirmed that the Workers Committee iseffective. Further effectiveness was assured by the election of 2nd responsible person for the grievance process ofthe facility.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):Facility has policy for Freedom of association, updated in January 2015.There is a suggestion box, located in the facility. There is also procedure implemented for opening and reviewingthe signals from the suggestion box, which is part of the internal rules of the facility. The suggestion box is openedregularly – twice per month. Responsible person for the grievance process is Mrs. Elka GeshevaWritten statement for the establishment of the Workers committee dated 07 January 2014.Last meeting of the Committee on 13 May 2015.

Non–compliance:

1. Description of non–compliance:NC against ETI NC against Local Law

None observed.

Local law and/or ETI requirement:

Objective evidenceobserved:(where relevant please add photonumbers)

None observed.


Not applicable.


Observation:




Objective evidenceobserved:None observed.

A: Name of union and unionrepresentative, if applicable:

N/A Is there evidence of free elections?Yes No

B: If no union what is parallel means ofconsultation with workers e.g. workercommittees?

Worker representative andLabour Committee

Is there evidence of free elections?Yes No

C: Were worker representatives/unionrepresentatives interviewed

Yes NoIf Yes, please state how many: 1

D: State any evidence thatunion/workers committee is effective?Specify date of last meeting; topics covered;how minutes were communicated etc.

Last meeting of the Committee – 13 May 2015Topics - health and safety and fire safety topicsEmployees declared they can communicate with management in caseof any issue.

E: Are any workers covered byCollective Bargaining Agreement (CBA)

Yes No

F: If Yes what percentage by tradeUnion/worker representation

N/A N/A

G: If Yes, does the CollectiveBargaining Agreement (CBA) includerates of pay

YesNoNot applicable.


Description of Good Example (GE):Not observed.

Objective evidenceobserved:Not observed.


3: Working Conditions are Safe and Hygienic

3: Working Conditions are Safe and Hygienic(Click here to return to NC–table)


ETI3.1 A safe and hygienic working environment shall be provided, bearing in mind the prevailing knowledge of theindustry and of any specific hazards. Adequate steps shall be taken to prevent accidents and injury to healtharising out of, associated with, or occurring in the course of work, by minimising, so far as is reasonablypracticable, the causes of hazards inherent in the working environment.3.2 Workers shall receive regular and recorded Health & Safety training, and such training shall be repeated fornew or reassigned workers.3.3 Access to clean toilet facilities and to potable water, and, if appropriate, sanitary facilities for food storage shallbe provided.3.4 Accommodation, where provided, shall be clean, safe, and meet the basic needs of the workers.3.5 The company observing the code shall assign responsibility for Health & Safety to a senior managementrepresentative.



Current systems:The health and safety, as well as the fire safety of the facility are maintained at high level with some exceptions.There is effective risk assessment in place. Health and safety instructions are posted everywhere in the facility,health and safety trainings are regularly conducted for all workers. Machine safety checks are conducted regularly– the facility has a dedicated machine maintenance schedule. Fire safety is well organized along with the firefighting equipment as fire hoses and fire extinguishers. There is a centralized fire alarm system in place. Canteen,toilets and changing rooms are clean and hygienic. All workers are trained and provided with PPEs.Emergency evacuation plans in all 9 buildings are in place. Fire safety plan is implemented. Emergency responseteam is assigned for fire fighting, fire rescue and evacuation.Responsible person for Health and Safety and Fire Safety of the facility is Mr. Georgi Ivanov – H & S officer.

There is a first aid training program. There are total of 19 workers designated and trained for first aid assistance.Emergency evacuation drills are regularly conducted.There is external licensed occupational medical service which provides medicine service to the facility includingannual medical checks.There are adopted procedures for managing of emergency situations like fire, earthquake, flood and otheremergency situation.Procedures for health and safety training of the workers.Procedure for control and maintenance of the equipment in place.Workers Committee is in place and is dealing with health and safety and fire safety issues.Injury log is maintained. Procedure for reporting and investigation of accidents.

The Workers Committee discusses and solves issues, related to health and safety.The Fire fighting equipment is inspected by external company - “MBB Group” OOD.The electrical installation of the facility is maintained and inspected by external company – “ELBI Puls” OOD.The occupational medical service, responsible for the health of the employees of the company is “Medika ” EOOD.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):


Through the factory tour, management interview, workers interviews and documents reviews it was noted that :Responsible for fire safety – Mr. Georgi Ivanov, H & S officer.The members of the Workers Committee are trained in Health & Safety programs at the workplace on 04.07.2014Last periodical inspection of the fire fighting equipment (hydrants,extinguishers) – 24.04.2015Last electricity grounding performed on 28 August 2014There is a fire alarm and a fire detection system installed in the building.The factory has posted evacuation plans at each exit, indicating the escape routes and the location of the fireextinguishers, and hoses.Sufficient first aid kits, stocked with the necessary supplies are provided in the production areas.First aid trained workers – total of 19 people, last training, conducted on 13 May 2015Last fire safety training on 18 November 2014Last emergency evacuation drill – written statement from 18 November 2014Potable water is available in the production area via dispensers with mineral water.Employees have access to clean toilets.Employees are provided with changing rooms and rest rooms.Last health and safety training conducted on 13 May 2015Workers committee, consisting of 8 established in the facility. Last meeting, conducted on 13 May 2015.Documented Risk Assessment of the workplace –February/March 2015.Medical examinations were performed on 13 December 2014Written statements for the measurement of microclimate, noise and lighting of the work environment are available.Last check was conducted in March 2015Injury records log – no accidents are registered.PPE’s are provided and to workers – goggles, plastic gloves, earphones.The fire fighting equipment is inspected by external company - “MBB Group” OOD.The occupational medical service, responsible for the health of the employees of the company is “Medika” EOOD.The electrical installation of the facility is maintained and inspected by external company – “ELBI Puls” OOD.Special equipment operators: 5 forklift operators, trained by “”Elbi Plus”OOD, certificates dated 23 September2013.

Non–compliance:


During the facility tour, it was noted that the emergency evacuation escape routes arenot marked in production unit 3.

Local law and/or ETI requirementBulgarian lawIn accordance with Enclosure 2 to Ordinance RD 07/8, direction of evacuation must benoted with signs showing direction.

ETI Base Code3.1 A safe and hygienic working environment shall be provided, bearing in mind theprevailing knowledge of the industry and of any specific hazards. Adequate steps shallbe taken to prevent accidents and injury to health arising out of, associated with, oroccurring in the course of work, by minimising, so far as is reasonably practicable, thecauses of hazards inherent in the working environment.

Recommended corrective action:The facility will mark the emergency evacuation escape routes in production 3.


Facility tour


Responsible person:Georgi Ivanov – H & S Manager

Corrective action timescale:60 days


During the facility tour it was noted that 2 out of 84 fire extinguishers were blocked inthe main printing hall, first floor.

Local law and/or ETI requirementBulgarian lawIn accordance with Art 23 of BG Ordinance 8121з-647/01102014, fire extinguishers,hydrants and other fire fighting equipment must be easily accessible.


Recommended corrective action:The fire extinguishers will be unblocked and the facility will implement a system tokeep them free and accessible.




During the facility tour it was noted that there were 3 bottles with chemicals, leftunattended and found in close range to machines in 2 production units.

Local law and/or ETI requirementBulgarian lawIn accordance with Art. 7. (1) of the Law on health and safety at work, workplacesmust meet minimum requirements for ensuring healthy and safe working conditions.


Recommended corrective action:

Facility tour

Facility tour


Additional training will be provided for all employees, to enhance the provisions forsafe handling of chemicals and improve the chemicals management system.



Observation:







Objective EvidenceObserved:None observed.


: Child Labour Shall Not Be Used

4: Child Labour Shall Not Be Used(Click here to return to NC–table)


ETI4.1 There shall be no new recruitment of child labour.4.2 Companies shall develop or participate in and contribute to policies and programmes which provide for thetransition of any child found to be performing child labour to enable her or him to attend and remain in qualityeducation until no longer a child.4.3 Children and young persons under 18 shall not be employed at night or in hazardous conditions.4.4 These policies and procedures shall conform to the provisions of the relevant ILO Standards.



Current systems:Main criteria for recruitment are relevant education or/and experience.The facility verifies all workers’ original ID cards at the time of recruitment and keeps photocopies of workers’ IDcards in the personal files.In Bulgaria the minimum age for starting work is 18 years old or 16 years old with restrictions.The facility does not hire people below 18 years old.The youngest at the facility is 20 year old, hired February 2015.There is very strict government control over the age of the workers, hired in facilities in Bulgaria, under thesupervision of the Ministry of Labor and Social Policy.The Factory has its own Ethical Code, which prohibits Child labor. It was confirmed by the management, theworkers and the workers representative that so far there have been no cases of child labor in the facility.Facility has a child remediation policy, January 2015.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):There were no children found in the facility. The youngest employee is 20 years old.26 workers files checked - ach file contains copy of ID, Job Description, Diplomas/ Certificates, signed individuallabour contract etc.Internal rules handbook – January, 2015.Facility follows the principles of ETI Base Code.


Non–compliance:


None observed.




None observed.

Observation:





None observed.





5: Living Wages are paid

5: Living Wages are Paid(Click here to return to NC–table)

(Click here to return to Key information)

ETI5.1 Wages and benefits paid for a standard working week meet, at a minimum, national legal standards or industrybenchmark standards, whichever is higher. In any event wages should always be enough to meet basic needs andto provide some discretionary income.5.2 All workers shall be provided with written and understandable information about their employment conditions inrespect to wages before they enter employment and about the particulars of their wages for the pay periodconcerned each time that they are paid.5.3 Deductions from wages as a disciplinary measure shall not be permitted nor shall any deductions from wagesnot provided for by national law be permitted without the expressed permission of the worker concerned. Alldisciplinary measures should be recorded.



Current systems:All employees reviewed in the sample size were paid above the minimum wage set up for the country which is 360BGN gross per month. The Key Information field shows no (0%) workers paid the minimum wage. The contractedminimum wage for the facility is 360 BGN gross per month.There were no apprentices or trainees, employed by the facility in the reviewed period.As per workers and management interviews and sample payroll and time records reviewed, it was noted that thereis no overtime in the facility.All employees receive paid annual leave.Tax deductions, health and social insurance are calculated correctly and paid monthly to the National RevenueAgency and National Insurance Institute. Record for bank transfer for the last paid social security has beenprovided to the auditor.No deductions from wages are made as punishment (disciplinary measures).No withhold of wages was observed, nor employees report for any withholdings during the interviews.Pay slips are distributed monthly to all workers. The information in the pay slips has been verified and checked withthe manual time records.The information was consistent. This was also confirmed during the workers interviews.Additional bonuses are provided for all workers – food stamps, bonuses

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):Workers pay slips for March 2015, February 2015 and November 2014 for 26 workers.Internal rules handbook – January, 2015Internal rules for calculation of the wages at the facility, January, 2015All employees are given detailed pay slips. This was confirmed also during the interviews.All employees were covered with social security and medical insurances as well as additional insurance.Monthly salaries are paid regularly twice per month – the 10th and the 25th date of the following month, via banktransfer.


Non–compliance:


None observed.




None observed.

Observation:






Description of Good Example (GE):

Additional bonuses are provided for all workers – food stamps, bonuses

Objective EvidenceObserved:Contract with foodstamps provider Tombow;Payslips with bonusesincluded

Wages analysis:

Wages analysis:(Click here to return to Key Information)

A: Sample Size Checked(State number of worker records checkedand from which weeks/months andworker type – should be current, peakand random/low: please see SMETABest Practice Guidance)

26 wages were checked for March 2015 (current)26 wages were checked for February 2015 (low)26 wages were checked for November 2014 (peak)

B: Are there different legal minimumwage grades? If Yes, please specifyall.

YesNo

If Yes, please give details: N/a

C: If there are different legalminimum grades, are all workers

YesNo

If No, please give details: N/a


graded correctly? N/A

D: What deductions are required bylaw, e.g. social insurance? Pleasestate all types:

social securityhealth insuranceincome tax

E: Have all of these deductions beenmade? Please list all deductions thathave been made.

YesNo

If No, please give details:social security; health insurance; income tax.

F: Industry norm for this region:(please include time period e.g.hour/week/month)

360 BGN gross per month as of 01 January 2015340 BGN gross per month until 31 December 2014

Wages table

Wages table(Click here to return to Key information)

Worker Type Process Operator(Lowest paid)

Process Operator(Average paid)

Process Operator(Highest paid)

Select from individual worker records one worker from, lowest, average and highest wages and populate theboxes. Ensure comparison is made for same pay period (peak) and only uses full–time workers. See SMETA Best

Practice Guidance for completing this:

A: Pay period:(State month selected)

March 2015 March 2015 March 2015

B: Anonymous EmployeeReference/Dept.

Binding worker at thepaper production worker

Machine printing operator Binding machine operator

C: Employee Gender Female Male Male

D: Contracted/Standardworking hours:(excluding OT – please includetime period e.g.hour/week/month)

20 working days160 hours per month



E: Contracted /Standardwork pay rate:(excluding OT – please includetime period e.g.hour/week/month)

535 BGN gross permonth



F: Standard day overtime –hours:(please include time period e.g.hour/week/month)

0 hours / month 0 hours / month 0 hours / month

G: Standard day overtime –wage:(please include time period e.g.

0 BGN /month 0 BGN /month 0 BGN /month


hour/week/month)

H: Rest day overtime –hours: (please include timeperiod e.g. hour/week/month)


I: Rest day overtime – wage:(please include time period e.g.hour/week/month)

0 BGN /month 0 BGN /month 0 BGN / month

J: Statutory Holiday overtime– hours:(please include time period e.g.hour/week/month)


K: Statutory holiday OT –wages:(please include time period e.g.hour/week/month)

0 BGN/month 0 BGN /month 0 BGN/month

L: Total overtime hours:(please include time period e.g.hour/week/month)


M: Incentives/Bonus/Allowances etc.:(please include time period e.g.hour/week/month)

60 BGN in food stamps/monthly/Age and experienceallowance – 45 BGNBonus – 46.77 BGN

60 BGN in food stamps/monthlyAge and experienceallowance – 21.89 BGN

60 BGN in food stamps/monthlyAge and experienceallowance – 200.88 BGN

N: Gross wages:(please include time period e.g.hour/week/month)

686.77 BGN gross permonth



O: Social insurance andother deductions; please listwhich and amount.

Social Insurance – 66.62BGNHealth Insurance – 21.98BGNTax – 59.82 BGN



P: Actual wage paid afterdeduction:(please include time period e.g.hour/week/month)

538.35 BGN net permonth

598 BGN net per month 1066.79 BGN net permonth

Comments: none(Please state here any specific reasons/circumstances that explain the lowest and highest gross wages)

Different job positions and responsibilities, different work experience.

Q: Is there a defined living wage:This is not normally minimum legalwage. If answered Yes please stateamount and source of info:

YesNo

Please specify amount/time period: N/A


Please see SMETA Best PracticeGuidance

R: Are workers paid in a timelymanner in line with local law?

YesNo

S: Is there evidence that equal ratesare being paid for equal work:

YesNo

Details: No kind of discrimination was noted regarding the payments. Thiswas confirmed during the interviews with the workers.

T: How are workers paid: CashChequeBank TransferOther

If other explain: N/a


6: Working Hours are not Excessive

6: Working Hours are not Excessive(Click here to return to NC–table)


ETI6.1 Working hours must comply with national laws, collective agreements, and the provisions of 6.2 to 6.6 below,whichever affords the greater protection for workers. Sub–clauses 6.2 to 6.6 are based on international labourstandards.

6.2 Working hours, excluding overtime, shall be defined by contract, and shall not exceed 48 hours per week.*

6.3 All overtime shall be voluntary. Overtime shall be used responsibly, taking into account all the following: theextent, frequency and hours worked by individual workers and the workforce as a whole. It shall not be used toreplace regular employment. Overtime shall always be compensated at a premium rate, which is recommended tobe not less than 125% of the regular rate of pay.

6.4 The total hours worked in any 7 day period shall not exceed 60 hours, except where covered by clause 6.5below.

6.5 Working hours may exceed 60 hours in any 7 day period only in exceptional circumstances where all of thefollowing are met:

– this is allowed by national law;– this is allowed by a collective agreement freely negotiated with a workers’ organisation representing asignificant portion of the workforce;– appropriate safeguards are taken to protect the workers’ health and safety; and– The employer can demonstrate that exceptional circumstances apply such as unexpected productionpeaks, accidents or emergencies.

6.6 Workers shall be provided with at least one day off in every 7 day period or, where allowed by national law, 2days off in every 14 day period.



Current systems:Working hours are stated at the Internal Rules Handbook of the facility and posted on the message boards.Electronic time records are implemented for registration of the working hours. Workers possess cards and swipethem every day upon arrival and work-leaving time. The regular working hours are 8 hours per day, 40 hours perweek, 5 days per week from Monday to Friday. Saturdays and Sundays are days off. Official holidays arerespected.Overtime hours are not observed in the sample size checked.The facility’s policy on the working hours is included in the Internal Rules Handbook. It is posted in the mainproduction are and available to all employees.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):Internal rules Handbook – January 2015Electronic time records checked for 26 employees for November 2014, February and March 2015.


There are two regular shifts for production workers from 05:30 to 14:00 and from 14:00 to 22:15, 8 hours per day,five days per week, from Monday to Friday, with one 30 minutes break and one or two breaks of 15 minutes.Saturday and Sunday are rest days.Management and administration, work from 08:00 to 17:00, 8 hours per day, five days per week, from Monday toFriday, with one 30 minutes break from 12:00 to 12:30. Saturday and Sunday are rest days.Every production unit has its work time schedule posted on the message board. As per documentation review, it isstrictly followed.

Non–compliance:


None observed.




None observed.

Observation:


Local law or ETI requirement:N/AComments:N/A

Objective evidenceobserved:N/A



Objective EvidenceObserved:.Not Applicable

Working hours analysis


Working hours analysisPlease include time period e.g. hour/week/month

(Go back to Key information)

Systems & Processes

A. What timekeeping systems areused: time card etc.

Describe: System to record working time – electronic time-recordingsystem

B: Sample Size Checked(State number of worker recordschecked and from whichweeks/months and type – should becurrent, peak and random/low: SeeSMETA Best Practice Guidance)

26 wages were checked for March 2015 (current)26 wages were checked for February 2015 (low)26 wages were checked for November 2014 (peak)

C: Do ALL workers havecontracts/employment agreements?

YesNo

If NO, state which type of workers do NOT havecontracts:

N/a

D: Are standard/contracted workinghours defined in allcontracts/employment agreements?

YesNo

If NO, please state which type of workers do NOT havestandard hours defined in contracts/employmentagreements.

N/a

E: Are there any other types ofcontracts/employment agreementsused?

YesNo

If YES, Please complete as appropriate:

0 hrs Part time Variable hrs Other

If “Other”, Please define:

N/a - Only permanent workers contracts observed.

Standard/Contracted Hours worked

F: Do standard/contracted standardhours ever exceed the law or 48hours per week?

YesNo

If YES give details and comparison (local law/48 hrsweek)

N/a

G: What are the actualstandard/contracted hours worked insample (State per week/month)

Highest hours: 40 hours per week160 hours per month

Lowest hours: 40 hours per week160 hours per month

H: Any local waivers/local law or Yes If YES, Please give details


permissions which allowaveraging/annualised hours for thissite?

No N/a

Overtime Hours

I: Actual overtime hours worked insample (State per day/week/month)

Highest OThours:

Not applicable – No overtime is observed in the facility

Lowest OThours:


J: Range of overtime hours over allworkers/or as large a sample aspossible. (State per week/month anddetails)

0 hours per month in March 2015 (Current)0 hours per month in February 2015 (low)0 hours per month in November 2014 (peak)

K: Approximate percentage ofworkers on highest overtime hours

0%

L: Is overtime voluntary? YesNoConflicting

Information

Please detail evidence e.g. Wording ofcontract/employment agreement/handbook/workerinterviews/refusal arrangements:


Overtime Premiums

M: Is overtime paid at a premium? YesNo

Please give details of normal day overtime premium as a% of standard wages:

0% Up to115%

116%–124%

125–149%

150–199%

200%+

Any other comments: No overtime is observed.

N: ETI Code requires a prevailingstandard to give greatest workerprotection.If a site pays less than 125% OTpremium and this is allowed underlocal law, are there otherconsiderations? Please complete theboxes where relevant. Multi select ispossible.

NoConsolidated pay (May be standard wages above minimum legal wage, with

no/low overtime premium)Collective Bargaining agreementsOther

Please explain any checked boxes in N above e.g. detail of consolidatedpay CBA or Other.

In accordance to Bulgarian Labor Law, Art.262, Para.1, overtime is paid:150% for week days, 175% for rest days, 200% for holidays

Rest Days


O: Are workers provided with 1 dayoff in every 7–day–period, or 2 in 14–day–period (where the law allows)?

YesNo

Maximum number of days worked without a day off (insample):

5 consecutive days

Total Hours

P: Range of total hours:(Quote highest and lowest please includetime period e.g. hour/week/month)

Highest totalhours

40 hours per week160 hours per month

Lowest totalhours

40 hours per week160 hours per month

R: If more than 60 total hours perweek and this is legally allowed, arethere other considerations? Pleasecomplete the boxes where relevant.Multi select is possible.

Overtime is voluntaryOnsite Collective bargaining allows 60+ hours/weekSafeguards are in place to protect worker’s health and safetySite can demonstrate exceptional circumstancesOther reasons

Please explain any checked boxes in R above

Not applicable.

Comments:(please state here any specific reasons/circumstances that explain the highest working hours)

The above hours information is based on the time records and payroll records provided by the factory, and theworkers interviews.


7: No Discrimination is practiced

7: No Discrimination is Practiced(Click here to return to NC–table)

ETI7.1 There is no discrimination in hiring, compensation, access to training, promotion, termination or retirementbased on race, caste, national origin, religion, age, disability, gender, marital status, sexual orientation, unionmembership or political affiliation.



Current systems:The rules of employment are regulated by the Internal Rules Handbook. In the facility male workers are more thanthe female workers - about 55%. Payment is the same for men and women on the same position.The middle management and supervisor staff is 60% men and 40% women.All workers are ethnic Bulgarians, with Bulgarian citizenship. There are no migrants and/or agency workersemployed in the facility. There was no evidence of sexual harassment.There is a suggestion box with a grievance procedure. Responsible person is Elena Boncheva. The box is openedtwice per month. Last opening of the box was on 02 May 2015. No complaints recorded so far.sEvidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):Policy against discrimination, updated January 2015.Through employees interviews, management interview and documents review, it was noted that there is nodiscrimination in hiring, compensation, access to training, promotion, termination or retirement.Workers have the opportunity to celebrate their religious holidays.

Non–compliance:


None observed.




None observed.

Observation:




None observed.


8: Regular Employment Is Provided

8: Regular Employment Is Provided(Click here to return to NC–table)


ETI8.1 To every extent possible work performed must be on the basis of recognised employment relationshipestablished through national law and practice.8.2 Obligations to employees under labour or social security laws and regulations arising from the regularemployment relationship shall not be avoided through the use of labour–only contracting, sub–contracting, orhome–working arrangements, or through apprenticeship schemes where there is no real intent to impart skills orprovide regular employment, nor shall any such obligations be avoided through the excessive use of fixed–termcontracts of employment.



Current systems:All workers have signed individual labour contracts for employment with the facility, and all of them have a copy ofthis contract. No Apprentices or trainees are employed in the facility. No migrant workers are employed in thefacility. No Labor providers are used. Notice periods, working hours, wages, deductions, breaks, vacations, paidleaves, etc. are noted in the individual labor contracts. Rules for employment and termination of employment arestated also in the Internal rules Handbook of the facility. Facility hires its employees directly.Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):Employment contracts for 26 workers.There is no subcontracting or home working from the site.All employees’ files contain signed individual labour contract, job description and other documents, as required bythe law.

Non–compliance:


None observedLocal law and/or ETI requirement:Not applicableRecommended corrective action:Not applicable


Not applicable

Observation:


8A: Sub–Contracting and Homeworking:

8A: Sub–Contracting and Homeworking(Click here to return to NC–table)


8A.1. There should be no sub–contracting unless previously agreed with the main client.8A.2. Systems and processes should be in place to manage sub–contracting, homeworking and external

processing.Note to auditor on homeworking:

Report on whether it is direct or via agents. How many workers, relationship with site and what control systems arein place.



Current systems:The site tour showed that all production processes were present in the unit.The facility declares that no subcontractors used and it does not allow work to be taken at home as per their policyon sub-contracting. Orders and production records are available. Auditor crosschecked the production records withthe workforce on site and concluded that there is no evidence for subcontracting.It was verified through document review, factory tour, management interview and employee interview that no sub-contracting & Home-working is used at the facility.Facility has a very well organised system for keeping track of inventory and needs.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):Site tour (Calculation on total production and estimated capacity)Production recordsMaterials in/out recordsWorkers daily scheduleManagement interviewPolicy on subcontracting, part of the Internal Rules Handbook of the facility. Last update – January 2015.It was verified through document review, factory tour, management interview and employee interview that no sub-contracting & Home-working is used at the facility.

Non–compliance:


None observed.

Local law and/or ETI /Additional Elements requirement:Not applicable.



None observed.


Observation:


Local law or ETI/Additional elements requirement:Not applicable.







Summary of sub–contracting – if applicable

Summary of sub–contracting – if applicable

A: If sub–contractors are used, isthere evidence this has been agreedwith the main client?

YesNo

If Yes, summarise details:Not applicable.

B: Number of sub–contractors/agents used

0

C: Is there a site policy on sub–contracting?

YesNo

If Yes, summarise details:Not applicable.Policy on subcontracting, part of the Internal Rules Handbook of the facility.Last update – January 2015.

D: What checks are in place toensure no child labour is being usedand work is safe?

Not applicable.

E: What processes are sub–contracted?

Not applicable.

Summary of homeworking – if applicable

F: If homeworking is being used, isthere evidence this has been agreedwith the main client?

YesNo

If Yes, summarise details:Not applicable.

G: Number of homeworkers Male: 0 Female: 0 Total: 0

H: Are homeworkers employed director through agents?

DirectlyThrough Agents

Not applicable.

I: If through agents, number ofagents

Not applicable.

J: Is there a site policy onhomeworking?

YesNo

Not applicable.

K: How does site ensure workerhours and pay meet local laws forhomeworkers?

Not applicable.

L: What processes are carried out byhomeworkers?

Not applicable.


M: Are written agreements in placefor homeworkers that include regularemployment?

YesNo

Not applicable.

N: Are full records available at thesite?

YesNo

Not applicable.


9: No Harsh or Inhumane Treatment is allowed

9: No Harsh or Inhumane Treatment is Allowed(Click here to return to NC–table)

ETI9.1 Physical abuse or discipline, the threat of physical abuse, sexual or other harassment and verbal abuse orother forms of intimidation be prohibited.

Current Systems and Evidence ExaminedTo complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and

record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to


Current systems:During the interviews, employees confirmed that the atmosphere is friendly, they are treated with respect andunderstanding from the Management. They also stated that there is no inhumane treatment of them or theircolleagues.All workers are familiar with the internal rules and job descriptions.

In the Factory’s Internal Rules Handbook and its own Ethical Code is stated that harsh and inhumane treatment isforbidden and will not be allowed at the facility.The disciplinary procedures are as follows:1. Warning;2. Notice of dismissal;3. Dismissal.

Disciplinary sanctions can be applied only by the General Manager, after consulting the Accountant. In thepersonal files, checked by the auditor, there were no records for disciplinary measures. During the interviews,employees reported no disciplinary measures have been applied to them.There is an internal anonymous process for grievance - a suggestion box, where workers can report anygrievances (harassment, discrimination, abuse etc.); received complaints will be handled by the management.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):During the workers’ interviews, they confirmed that there is no inhumane treatment of them or their colleagues.All workers are familiar with the internal rules and job descriptions.Internal Rules Handbook – January 2015

Non–compliance:


None observed.




None observed.


Observation:









10 A: Entitlement to Work and Immigration

10. Other Issue areas: 10 A: Entitlement to Work and Immigration(Click here to return to NC–table)

Additional Elements10A1 Only workers with a legal right to work shall be employed or used by the supplier.10A2 All workers, including employment agency staff, must be validated by the supplier for their legal right to workby reviewing original documentation.10A3 employment agencies must only supply workers registered with them.10A4 the supplier shall implement processes to enable adequate control over agencies with regards the abovepoints and related legislation.



Current systems:There are no migrant workers employed by the facility. However migrants are allowed to work in the facility, onlyafter having all relevant documents and permits, issued for residence and work in the territory of Bulgaria. Allworkers are ethnic Bulgarians, with Bulgarian citizenship. All workers are directly employed by the facility. Thereare no agency workers employed in the facility.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):26 Personal files of employeesHiring policy of the facilityNo workers hired through agency.HR hiring policy for recruitment of workers (including migrant workers) – included in the Internal Rules Handbook –January 2015

Non–compliance:


None observed

Local law and/or ETI /Additional Elements requirement:Not applicable.


Objective evidenceobserved:(where relevant please addphoto numbers)None observed

Observation:



Local law or ETI/Additional Elements requirement:Not applicable.


Objective evidenceobserved:None observed

Good examples observed:

Description of Good Example (GE):None observed

Objective EvidenceObserved:None observed


10. Other issue areas 10B4: Environment 4–Pillar(Click here to return to NC–table)

To be completed for a 4–Pillar SMETA Audit and remove the previous page which is 10B2 environment 2 pillar

B.4. Compliance Requirements10B4.1 Suppliers as a minimum should meet the requirements of local and national laws related to environmentalstandards.10B4.2.Where it is a legal requirement, suppliers must be able to demonstrate that they have the relevant validpermits including for use and disposal of resources e.g. water, waste etc.10B4.3. The supplier shall be aware of their end client’s environmental standards/code requirements and have asystem in place to monitor their performance against these.B4. Guidance for Observations10B4.4. Suppliers should have completed the appropriate section of the SAQ and made it available to the auditor.10B4.5. Suppliers should have an environmental policy, covering their environmental impact, which iscommunicated to all appropriate parties, including its own suppliers.10B4.6. Suppliers shall be aware of the significant environmental impact of their site and its processes.10B4.7. The site should measure its impacts, including continuous recording and regular reviews of use anddischarge of natural resources e.g. energy use, water use (see 4–pillar audit report and audit checks for details).10B4.8. Suppliers shall seek to make continuous improvements in their environmental performance.10B4.9. Suppliers shall have available for review any environmental certifications or any environmentalmanagement systems documentation10B4.10. Suppliers should have a nominated individual responsible for co–ordinating the site’s efforts to improveenvironmental performance.10B.4.11. Has the site recently been subject to (or pending) any fines/prosecutions for noncompliance toenvironmental regulations.

Note for auditors and readers. This environment section is intended to take not more than 0.25 auditor days. It is anassessment only and the main requirement is to establish whether a site is meeting applicable environmental lawsand/or has any certifications or environmental management systems in place. Following this assessment theclient/supplier may decide a full environmental audit is required (see also best practice guidance/environment andguidance for auditor)



Current systems:According to the Bulgarian legislation the facility is not required to obtain special environmental permit. The facilityhas FSC Chain-of-Custody certificate, valid until 09 August 2015, issued by the SmartWood Program of theRainforest Alliance.Responsible Manager for the protection of Environment is Mr. Georgi Ivanov – H & S officer.The environmental awareness of the workers and the Management is regularly improving, by conduction oftrainings, on regularly basis, which are part from the health and safety trainings. Trainings include following topicslike separate collection and recycling of wastes, reaction in cases of chemical substances leakage, introduction tothe MSDS of the chemical substances, etc. Environmental issues are also subject of discussion of the regularmeetings of the Worker Committee.There is a waste disposal procedure implemented in the facility for separate collection and recycling of wastes.Separate collection of solid, industrial and domestic wastes is organized. Containers for different kinds of waste areplaced in several places in the facility. MSDS are available in local language for all chemicals used in the facility.The facility uses the following chemicals – water-based printing ink and developers. The collection and recycling ofall wastes is managed by external licensed company called Repack OOD.


All workers are specially instructed for the usage of chemicals and how to react in cases of emergency situation,caused by chemicals.The facility does not generate air emissions and does not use water in its working process. The discharged water isonly from human usage, not for industrial purposes.The facility does not use gas-powered equipment.

Evidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):Internal Rules Handbook – January, 2015MSDS and Safety instructions available in the local language for the water-based printing inkTraining records dated 07 January 2015 for 19 workersEnvironmental policy – last updated January, 2015, part of the Internal rules.List of chemicals used – last update from 07.01.2015MSDS for water-based printing ink, posted in local language, provided by Kodak.Environmental emergency statement: (e.g. emergency plan, ERT and Security Staff trained in environmentalemergencies, regular drills, etc); Last emergency drill conducted on 18 November 2014Last training conducted for work with chemical agents and reactions in cases of chemical leakages for all workersengaged in chemical usage - 18 November 2014

Non–compliance:

1. Description of non–compliance:NC against ETI/Additional Elements NC against Local law

None observed

Local law and/or ETI/Additional Elements requirement:Not applicable

Recommended corrective action:Not applicable


None observed

Observation:

Description of observation:None observedLocal law or ETI/Additional elements requirements:Not applicableComments:Not applicable


None observed



None observed

Objective EvidenceObserved:None observed


Environmental Analysis

Environmental Analysis(Site declaration only – this has not been verified by auditor. Please state units in all cases below.)

A; Responsible for Environmental issues (Name andPosition):

Mr. Georgi Ivanov – H & S officer

B: Does the site have a recognised environmentalsystem certification such as ISO 14000 or equivalent?Please detail.

Yes NoDetails:

C: Does the site have an Environmental policy?(For guidance, please see Measurement criteria )

Yes No

Does the site have a Biodiversity policy?(For guidance, please see Measurement criteria )

Yes No

E: Is there any other sustainability systems present suchas Chain of Custody, FSC, MSC etc.?Please detail.(For guidance, please see Measurement criteria )

Yes NoDetails:The facility has FSC Chain-of-Custody certificate, validuntil 09 August 2015, issued by the SmartWoodProgram of the Rainforest Alliance.

F: Have all legally required permits been shown?Please detail.

Yes NoDetails: License Permit No 122013040, issued by theTrade register of Bulgaria.

G: Is there a documentation process to recordhazardous chemicals used in the manufacturingprocess?

Yes No N/ADetails: Internal rules and regulations, Environmentalpolicy, List of chemicals used in the facility.

H: Is there a system for managing client’s requirementsand legislation in the destination countries regardingenvironmental and chemical issues?

Yes NoDetails: Internal rules and regulations, Environmentalpolicy, List of chemicals used in the facility.

Usage/Discharge analysis

Criteria Current year: 2015Please state period: 01-31.01.2015

Previous Year: 2014Please state period: 01-31.12.2014

Electricity Usage:Kw/hrs

202 083 kWh 237 500 kWh

Renewable Energy Usage:Kw/hrs

Not applicable - No such sourceused.


Gas Usage:Kw/hrs



Has site completed any carbonFootprint Analysis?

Yes No Yes No

If Yes, please state result N/A N/A


Water Sources:Please list all sources e.g. lake, river,and local water authority.

Kostinbrod Water SupplyMunicipal sewage

Kostinbrod Water SupplyMunicipal sewage

Water Volume Used:(m³)

56 m3/per month 64 m3/per month

Water Discharged:Please list all receiving waters/recipients.

Administration Canteen Toilet facilities

Administration Canteen Toilet facilities

Water Volume Discharged:(m³)

20 m3/per month 24 m3/per month

Water Volume Recycled:(m³)

Not applicable - No grey waterusage

Not applicable - No grey waterusage

Total waste Produced(please state units)

32 090 kg. 29 097 kg.

Total hazardous waste Produced:(please state units)

0 kg. 0 kg.

Waste to Recycling:(please state units)

32 000 kg. 29 000 kg.

Waste to Landfill:(please state units)

90 kg. 97 kg.

Total Product Produced(please state units)

250 000 products/per month 250 000 products/per month


10C: Business Ethics – 4–Pillar Audit

10C: Business Ethics – 4–Pillar Audit(Click here to return to NC–table)

To be completed for a 4–Pillar SMETA Audit

10C. Guidance for “Observations”10C.1. Suppliers should have completed the appropriate section of the SAQ and have made it available to theauditor.10C.2. The supplier should have received and acknowledged– preferably in writing – the Business Ethics policy ofthe auditor/audit company.10C.3. Suppliers shall seek to conduct their business ethically without bribery, corruption, or any type of fraudulentBusiness Practice.10C.4. Suppliers shall be aware of any applicable laws, their end client’s Business Ethics standards/coderequirements and have a system in place to monitor their performance against these.10C.5. Supplier should have a Business Ethics policy concerning bribery, corruption, or unethical BusinessPractice. This should be clearly communicated to all relevant parties.10C.6. Suppliers should have a designated person responsible for implementing standards concerning BusinessEthics10C.7. Suppliers should have a transparent system in place for confidentially reporting, and dealing with unethicalBusiness Ethics without fear of reprisals towards the reporter10C.8. Suppliers should ensure that the staff whose job roles carry a higher level of risk in the area of ethicalBusiness Practice e.g. sales, purchasing, logistics are trained on what action to take in the event of an issue arisingin their area.

Note for auditors and readers. This Business Ethics section is intended to take not more than 0.25 auditor days. Itis an assessment not an audit and the main requirement is to gather information on the relevant Business Ethicsissues in a supply chain. All findings will be recorded as observations not Non– Compliances and the data collectedwill allow the membership to define appropriate standards over time as part of a continuous review process.

Current Systems and Evidence ExaminedTo complete ‘current systems’ Auditors examine policies and written procedures in conjunction with relevant managers, to understand, and

record what controls and processes are currently in place e.g. record what policies are in place, what relevant procedures are carried out, who is/are responsible for the management of this item of the code. Evidence checked should detail any documentary or verbal evidence shown to


Current systems:The facility follows the requirements of the ETI Base Code, and has implemented business ethics and practices,transparency, anti-bribery and anti-corruption systems and approaches.All workers receive training on these policies prior to starting job. The facility has zero tolerance practice againstcorruption, bribery, and other criminal acts in the facility. Additional acts like gifts to state authorities and donationsto governmental structures, political parties, judicial system, NGO’s and/or other 3rd parties are strictly forbidden aswell. The Labour Committee deals with issues related to bribery attempts, corruption, and integrity and businessethicsEvidence examined – to support system description (Documents examined & relevant comments. Includerenewal/expiry date where appropriate):Internal Rules Handbook – latest update from January 2015Anti-bribery and Anti-corruption policy – latest update from January 2015Grievance procedure for anonymous signals – January 2015

Observation



Local law or ETI/Additional elements requirement:

Not applicable

Comments:

Not applicable


None observed



Not applicable

Objective EvidenceObserved:

None observed


10C: Business Ethics – 4–Pillar Audit

Worker Interview SummaryWorker Interview Summary

Worker Interview Summary

A: Were workers aware of the audit? YesNo

B: Were workers aware of the code? YesNo

C: Number of group interviews:(Please specify number and size ofgroups. Please see SMETA BestPractice Guidance)

6 individual interviews5 group interviews x 4 employees

D: Number of individual interviews(Please see SMETA Best PracticeGuidance)

Male: 3 Female: 3

E: Total number of interviewedworkers(Please see SMETA Best Practice

Guidance)

Male: 11 Female: 15

F: Interviews were done in privateand the confidentiality of theinterview process wascommunicated to the workers?

YesNo

G: In general, what was the attitudeof the workers towards theirworkplace?

FavourableNon–favourableIndifferent

H: What was the most commonworker complaint?

No complaints were reported.

I: What did the workers like the mostabout working at this site?

Very good attitude of the management.The environment in the company is friendly and open.

J: Any additional comment(s)regarding interviews:

No additional comments were made.

K: Attitude of workers to hoursworked:

They have no complaints. Working hours are respected. There is no forcedlabour. There is no overtime in the facility declared during interviews.

Agency Workers


Agency Workers(workers sourced from a local agent who are not directly paid by the site)

A: Number of agencies used(average):

N/A No agencies used.

B: Were agency workers’age/pay/hours included within scopeof this audit

YesNo

Not applicable

C: Were sufficient documents foragency workers available for review?

YesNo

Not applicable.


Other findingsOther Findings Outside the Scope of the Code

None observed.

Community Benefits(Please list below any specific community benefits that the site management stated that they were involved in, for example, HIV

programme, education, sports facilities)

None observed.


Photo Form

Factory view (1) Factory view (2) Production area (1)

Production area (2) Production area (3) Production area (4)


Fire extinguishers Fire extinguishers (2) Fire extinguisher and hydrant

Emergency exit sign Emergency exit sign (2) Fire Alarm (1)


Fire Alarm (2) Evacuation plan Evacuation plan (2)

Evacuation exit Evacuation exit Notice boards


First aid kit Lockers Eyewash station

Water dispenser Water dispenser (2) Bicycle stand


Sanitary facilities (1) Canteen (1) Canteen (2)

Stairs railguard installed Raw materials warehouse Raw materials warehouse (2)


Packaging materials warehouse Vending machines Electrical switchboard

Non-conformity 1 Non-conformity 2 Non-conformity 3

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You can leave feedback by following the appropriate link to our questionnaire:

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Your feedback on your experience of the SMETA audit you have observed is extremely valuable.It will help to make improvements to future versions.

You can leave feedback by following the appropriate link to our questionnaire:

Click here for A & AB members:http://www.surveymonkey.com/s.aspx?sm=riPsbE0PQ52ehCo3lnq5Iw_3d_3d

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