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  • 2018 Corporate Responsibility Report

Examples of problematic findings

Area   Findings at suppliers   Initiated improvements Status
(end of 2018)
Child/juvenile labor   According to management and employee interviews as well as document reviews, five young workers were employed at the punching shop, the Maopian (raw materials) shop and the injection shop, where they were exposed to hazardous factors such as noise, dust, etc. This was in violation of the Chinese labor law (1994), Article 64.   According to legal requirements, the factory took action to stop exposing juvenile worker to hazardous work factors. The affected workers were moved to a quieter assembly line. Closed
Environmental protection  

Based on observations made on site, the factory did not provide containment/collection containers for two empty lubricating oil chemicals in the chemical storage facility, two empty cleaning chemicals in the cleaning shop and six empty guide rail oil chemicals on the outdoor site. This was in violation of the following articles of the environmental protection standard for the storage of hazardous waste (GB18597-2001):

Article 6.2.2: The storage facility for hazardous waste must provide a leak indicator, a gas venting system, and a gas purification system.

Article 6.3.9: The storage facility for hazardous waste must be wind-proof, rain-proof and protected from sunlight.

  The factory is to install a containment/collection container for empty chemicals from the area mentioned above. Closed
 

Finding: According to documents reviewed, last year the factory did not transfer hazardous waste (PCB boards and cleaning waste) to qualified sites for processing.

Comment: The factory stored hazardous waste on factory premises and did not transfer it.

It was therefore in violation of the law of the People’s Republic of China to avoid and reduce environmental pollution resulting from solid waste (amended in 2016), Article 55: Facilities that produce hazardous waste must dispose of the hazardous waste in accordance with applicable government regulations and may not store or dispose of them without permission.
  The hazardous waste was transferred at the end of 2018. Closed
Area   Findings at suppliers   Initiated improvements Status
(end of 2018)
Occupational health and safety   There are not enough emergency exit signs on the main routes of the sewage treatment plant to ensure proper evacuation in an emergency. This makes it difficult to find the emergency exit.   
  1. The entire sewage treatment plant will be inspected and new signs will be installed in areas without adequate emergency exit signage.

  2. All other areas of the company will also be checked for emergency exit signs and new signs installed if necessary. 

Closed
 

Fire alarms and alarm systems are tested by a fire safety company once a month.

Finding: One of the fire alarms in the hazardous waste room did not work. This means there is a lack of fire protection.
 
  1. A fire safety company checked the fire alarm system in this area and completed maintenance.

  2. All other areas of the company will also be checked and any improvement measures taken immediately.

Closed
  During the plant tour, it was found that in the storage area for flammable chemicals and in the printing area where work involves chemicals, there was no emergency shower/eye irrigation station.   Every department must identify and provide the appropriate safety equipment. Closed
 

Finding: The factory began operations in October 2017, even though a firefighting certificate had not yet been issued for building no. 4 (25194 square meters, completed in June 2017).

Comment: The factory has completed its fire protection concept for building no. 4. Acceptance for firefighting systems was underway but the acceptance procedures were very complex. This was in violation of the following article of the fire protection law of the People’s Republic of China (2008):

Article 11: For the construction of large facilities intended for use by large numbers of people or special construction projects as stipulated by the national safety authority of the State Council, the employer is required to present the fire protection documents to the fire protection department of the national safety authority for review. The law specifies that the fire protection department of the national safety authority is responsible for the result of the review.

Article 13: When construction work is completed on a project that requires fire protection planning according to national fire protection standards, fire protection acceptance testing or submission of the relevant documents is to be carried out as follows:
  1. For a construction project pursuant to Article 11 of the law, the employer must apply to the fire protection division of the authority for public safety for fire protection acceptance testing;

    or

  2. For any other construction project, the employer must report successful acceptance to the fire protection division of the authority for public safety for archival purposes,  and the fire protection division of the authority will conduct spot checks.  A construction project that is by law subject to a fire protection inventory, but does not undergo or successfully pass the inventory may not begin operation. Construction projects that fail a random inspection may no longer be used.

  We have meanwhile received the certificate for the fire protection concept covering all buildings. Ongoing
 

Finding 1: A metal warehouse with approx. 600 square meters area had just one safety exit at the time of the audit. This is in violation of the Code of Design on Buildings Fire Protection and Prevention (GB50016-2006), Article 3.8.2: Every storage site must have at least two exits. One exit is sufficient for storage sites with an area of less than 300 square meters.

There must be at least two exits leading to a hallway, a stairway or outside from every zone of the warehouse. One door is sufficient for building sections with an area of less than 100 square meters.

The door leading to the hallway or stairway should be a class B fire protection door.

Finding 2: 20% of the emergency exits in building no. 4 had a net width of 0.75 meters. This does not meet legal requirements.

Comment: The factory began implementing corrective measures prior to the final meeting. This was in violation of the Code of Design on Buildings Fire Protection and Prevention (GB50016-2014), Article 3.7.5: The net width of the evacuation stairs should be at least 1.10 m, the net width of the evacuation route at least 1.40 m and the net width of the door at least .90 m.

The width of the evacuation stairs should correspond to the number of workers on all levels. The net width of the lower stairway therefore corresponds to the number of workers on all floors. The net width of the exterior door on the first floor also corresponds to the number of workers on all floors. The net width of the door must be at least 1.20 m.
 
  1. There are two safety exits for the metal warehouse.

  2. Modifications were made to the door width and the contract with the supplier was signed.

  3. The modified doors were installed.

Ongoing
  The evacuation plan in the dormitories did not correspond to the actual layout. This was in violation of the Code of Design of Dormitory Buildings (JGJ36-2005), Article 4.1.4: Dormitories must have an emergency evacuation plan and clearly visible evacuation signs posted.  
  1. The evacuation plan was updated and posted in the dormitories.

  2. The annual internal audits will take account of this item in the future.

Ongoing
Area   Findings at suppliers   Initiated improvements Status
(end of 2018)
Wages and performance-related remuneration  

According to Article 44 of the Labor Law of the People’s Republic of China, under the following circumstances, the employer shall pay workers higher compensation than for regular working time:

  1. at least 150% of the regular wage if an extended working time has been agreed upon;

  2. at least 200% of the regular wage if overtime is worked on days off and no other days off can be taken; and

  3. at least 300% of the regular wage if overtime is worked on legal holidays.

Finding: Inadequate overtime wages paid to employees. In connection with the document review, the auditor determined that one of 20 randomly chosen employees worked on October 4, 2017 (public holiday, Mid-Autumn Festival). However, only 200% of the regular wage was paid. Deadline: December 8, 2017.
  No overtime is planned for public holidays. Should overtime be worked on public holidays, however, employees should be paid 300% of the regular wage. Closed
  Social security. Compliance with this item could not be verified because the auditor did not have access to the payroll accounting of the third-party provider.   This item was corrected for the follow-up audit on July 12, 2018; access was granted. There were no apparent violations. Closed
 

Based on the document review and the management interview, it was determined that the factory paid only 100% of the regular hourly wage for overtime on regular working days and public holidays.

Example a) In April 2018, all 25 employees reviewed were paid only 100% of the regular hourly wage for overtime (100% of employees);

Example b) On April 5, 2018, (Qingming Festival, Tomb-Sweeping Day), 3 out of 25 workers (12% of employees) were paid only 100% of the regular hourly wage for overtime. This was in violation of the Chinese labor law, Article 44.
  The company pays all employees 1.5 times the wage for overtime on working days, 2 times the wage for overtime on weekends and 3 times the wage for overtime on public holidays, based on the actual date worked. Ongoing
Area   Findings at suppliers   Initiated improvements Status
(end of 2018)
Working hours  

Finding: The factory used imprecise manual attendance logs to record employee attendance. Weekly working time and daily/monthly overtime could not be verified. This was in violation of the Chinese labor law, Article 41: The employer can extend the working time due to production or corporate requirements after consulting with the union and the employees. As a rule, the extended working time may not be longer than one hour per day. If an extension is necessary for special reasons, the working time may be extended up to three hours per day as long as the health of the employee is ensured.

However, extended working time may not amount to more than 36 hours per month.

Finding: The factory used manual attendance logs to record worker attendance information. It could not be determined in the manual attendance logs whether the workers had one, two or three shifts and whether they worked 7, 7.5, 8, 9.5 or 12 hours per day. No shift information or working hours per day were recorded for workers. Due to imprecise manual attendance recording, the weekly working times and daily/monthly overtime could not be verified.
 

An electronic attendance system will be introduced to record employee attendance information.

Ongoing
  Compliance with work breaks, public holidays and vacations could not be verified because the auditor did not have access to the payroll accounting of the third-party provider.   This item was corrected for the follow-up audit; access was granted. There were no apparent violations. Closed
 

Employee overtime amounted to more than the legal provisions and the weekly working time more than the SA8000 standards.

Finding based on the present attendance log: Approximately 30% of the employees surveyed worked more than three overtime hours a day. The highest number of overtime hours was four hours/day. Around 90% of the employees surveyed worked more than 36 overtime hours a month. The highest number of overtime hours was 142 hours in January. The weekly working time for all employees surveyed exceeded 52 hours per week in all months. The highest weekly working time was 76.5 hours in January 2018.
  A production plan based on customer demand will be prepared one month in advance to ensure that employees do not work more than 60 hours per week. Closed